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Good Importing Practices for Food
March 31, 2006
First Edition
TABLE OF CONTENTS
Effective hygiene controls are vital to preventing food borne illness, food
borne injury and food spoilage. Good Importing Practices For Food
(GIP) is a voluntary code of practice to be used as a guideline for Canadian
importers. It is designed to encourage them to create their own hygiene
controls to help improve food safety and meet regulatory requirements.
The GIP is broad in
scope and nature. It deals not only with the key controls necessary to limit
safety risks but also provides direction on control measures related to fraud,
and on preventing deviations in standard, grade and composition of imported
food.
The Canadian Food Inspection Agency (CFIA) in consultation with the food
industry has up-dated the June, 1998 version of the GIP. Although some sections of the
GIP may not be applicable
to every importer, it is intended for broad use across the industry. Where
further guidance is needed, the CFIA may develop specific codes of
practice for a variety of situations.
Canadian importers are expected to be aware of the hazards involved in
importing food and of the controls needed to demonstrate that their imported
foods are safe and meet the applicable legislation in Canada. They are also
expected to have access to records that will demonstrate that the foreign
manufacturers of these imported products have the necessary controls in place.
The GIP provides a sound
foundation for the development of a system for ensuring food safety based on
HACCP (Hazard Analysis Critical Control Point) principles. Although the
GIP is not meant to serve
as a complete HACCP plan, it is a useful
reference. Additional reference material be found on the CFIA Web site at:
http://www.inspection.gc.ca.
The GIP: An
Assessment Tool
The GIP will be used by
the CFIA to assist
in assessing importers on their ability to ensure imported food meets Canadian
legislation. The GIP can be
applied to import, storage, transportation and relabelling activities. Any
importers who repackage or process imported products should also refer to the
CFIA General
Principles of Food Hygiene, Composition and Labelling Code of Practice for
further guidance on processing controls.
The GIP is based on the
Recommended International Code of Practice General Principles of
Food Hygiene adopted by the Codex Alimentarius Commission. This is
consistent with the World Trade Organizations Agreement on the
Application of Sanitary and Phytosanitary Measures (SPS Agreement), which directs
members to base their sanitary and phytosanitary measures on international
standards, guidelines and recommendations. The GIP is also consistent with the CFIA Import Control Policy,
since it identifies risk management criteria that are targeted to meet the
specific requirements of food safety and consumer protection.
Using the GIP
Each chapter of the GIP
describes specific criteria and procedures. Each sub-section includes a
principle statement and when necessary, a rationale, followed by CFIAs assessment
criteria.
Principle Statement
Principle statements are outcome-based generic statements of objectives
similar to those found in the Codex Code. They are intended to capture the
intent of the guideline while allowing flexibility in addressing specific
products or processes.
Rationale
Rationales are included only when the principle statement needs explanation.
They are included in several chapters (Control of Imported Product, Equipment
and Records) to explain the nature of the concern or potential hazard(s) and
the need for control.
Assessment Criteria
Assessment criteria included in the GIP will provide information on the
factors that may be considered in assessing adherence to the objectives, as
expressed in the principle statements of the GIP. The CFIA considers these factors during
the course of its risk-based investigation or inspection activities.
The assessment criteria are intended to guide the importer. The CFIA recognizes that there
may be "alternate means" of meeting the intent of the principle
statement other than those specified in the assessment criteria. These
"alternate means" may include a specific process step which will be
used to control an associated food safety risk or meet a regulatory
requirement. Therefore, CFIA has carefully worded the
document to accommodate "options or equivalents".
1.1.1 Shipment Information
The importer has controls in place to ensure that a current written
description is available for each imported product and each imported
shipment. |
Rationale
The importer requires basic written information to identify each imported
product in order to ensure that the finished product meets the requirements of
Canadian legislation.
Assessment Criteria
Commodity Specific Regulatory Requirements
- Importers obtain and maintain current licences, permits and other specified
documentation as evidence of compliance with commodity specific regulatory
requirements.
- Where required the importer provides suppliers/shippers with written
specifications of commodity specific regulatory requirements with which they
are expected to comply.
NOTE: Certain agricultural commodities are subject to
additional regulatory requirements, such as import documentation, licensing,
etc. The following are some of the pertinent
regulations: Processed Products Regulations, Fresh Fruit and Vegetable
Regulations, Licensing and Arbitration Regulations, etc.,
Product Information
- A written product description is available and current for each product.
The following information may apply:
- common name of the product,
- brand name,
- net quantity declaration,
- product variety,
- grade,
- product specifications and characteristics,
- container size,
- copy of the Canadian label,
- list of ingredients,
- packaging material,
- final use of the product,
- origin of the product,
- labelling instructions when further labelling is required,
- handling and storage instructions when special requirements exist.
(Examples include the following: do not store with non-food items; keep
refrigerated; keep frozen; store at room temperature; etc.)
NOTE: When an imported product regulated under the Food
and Drugs Act and Regulations does not meet Canadian requirements,
importers may avail themselves of Section A.01.044 of the Regulations which
permits the importation of a product that violates the Act or Regulations
provided that the product may be brought into compliance after its relabelling
or modification. Two conditions apply: the importer must notify a CFIA inspector prior to
importation, and the product must be corrected before sale.
Tracing Products and Shipments
- A product code and/or lot code is available for each product. (For products
such as low acid canned foods, this is a regulatory requirement.)
- The total net quantity of the shipment is available (the number of units
times the unit weight).
- Written flow documentation is available for each imported product. This is
necessary to trace products and shipments, and to identify and locate the
points where control measures and monitoring procedures are required. The
importer requires knowledge of the following:
- the controls to which the product has been subjected,
- the product flow (i.e., the port of
entry, the carrier, and (if applicable) the import broker),
- the supplier list and relevant supplier information,
- purchase records (the quantity, the product code, the date, the
buyer),
- the adequacy of the conditions of transportation and storage to which the
product has been exposed.
- The importer is able to obtain the above information upon request.
NOTES:
i. Not all the requirements listed
above apply to all food commodities. However, Canadian food legislation may
specify further requirements for some products. When different lots of bulk
product have been blended and it is not possible to trace specific lots, all
product involved is treated as a single product.
ii. For information about downstream traceability (tracing
a products record of sale and distribution), see Section
7.6.2, Distribution Records, in this document. Downstream traceability is
necessary in cases where product is recalled.
1.1.2 Assessment of Foreign Manufacturers/Suppliers
Prior to importation, the importer verifies that the
manufacturers/suppliers are capable of providing food products that comply with
Canadian legislation. |
Rationale
The safety of food products and their compliance with Canadian regulatory
requirements is dependent upon the processing procedures and controls in place
at the manufacturing facility. Manufacturing facilities should comply with good
manufacturing practices (GMP) equivalent to the Codex Alimentarius General
Principles of Food Hygiene, and where required, the manufacturer should have a
HACCP (Hazard Analysis Critical Control Points) system in place. These controls
are necessary to prevent such problems as microbiological, physical and
chemical contamination (including contamination with undeclared allergens), and
to prevent misrepresentation and fraud.
Assessment Criteria
- The importer can obtain information on request to demonstrate that the
critical steps of the manufacturing process are adequately controlled to ensure
safety and quality, and to prevent misrepresentation and fraud.
- Evaluation of foreign manufacturers/suppliers is conducted by technically
competent personnel.
- In the absence of these controls, the importer conducts increased product
control (e.g., sampling, product and
laboratory evaluation, third party review) to ensure risks are controlled.
1.1.3 Product Labelling and Composition
The importer has controls in place to ensure compliance with the
composition, labelling, nutritional labelling and claims provisions of the
Food and Drugs Act and Regulations, the Consumer Packaging and
Labelling Act and Regulations and other commodity specific legislation,
such as the Canada Agricultural Products Act and Regulations. |
Rationale
Compliance with Canadian food safety standards and compositional
requirements promotes a safe food supply and helps ensure that consumers
expectations are met with respect to food composition and quality. The declared
composition, compositional standards, nutrition information and claims must be
adequately controlled to prevent misrepresentation and fraud, and to prevent
such health hazards as the presence of undeclared food allergens.
Mandatory information on food labels allows consumers to make informed
choices by:
Assessment Criteria
Composition
- Control factors that are critical to the safety and integrity of the
product are identified. (This includes microbiological, chemical or physical
concerns, as well as concerns related to allergens, extraneous matter, etc.) Their specifications and limits are identified
(e.g., thermal process, pH and water activity for ready-to-eat fermented
meats, salt content for brined mushrooms, sulphur content on dried fruit,
freedom from Salmonella, etc.)
- Procedures are in place to ensure that imported food which is sold in
Canada complies with Canadian nutrient composition and nutrition labelling
requirements. This may concern the following:
- added nutrients (i.e., vitamins and
minerals) permitted in the specific foods are added at appropriate levels as
set out in the Food and Drug Regulations;
- foods for which there are nutrient composition requirements (e.g., meal replacements, nutritional supplements, flour,
etc.) meet these requirements;
- the nutrient content of the product is accurately reflected on the label
and in compliance with the Food and Drug Regulations (i.e., the list of ingredients and Canadian Nutrition
Facts table);
- products for which there are nutrient content claims and/or diet-related
health claims meet the Canadian compositional and labelling requirements under
the Food and Drug Regulations. (See Section 7, Nutrient Content
Claims, and Section 8,
Diet-Related Health Claims, in the 2003 Guide to Food Labelling and
Advertising.)
- Procedures are in place to enable the verification of a products
formulation, its list of ingredients, its nutrient content and nutrient values
as stated on the label. These procedures may include, but are not limited to:
- a documented communication system with suppliers which permits access to
product specific information (e.g., names and
amounts of ingredients, components, additives, and if applicable, added
nutrients);
- an overview of the method(s) used to determine nutrient values (e.g., laboratory analysis, the use of a database for
finished foods, the use of an ingredient/recipe data base, published values,
the use of a consultant or other technical expertise, etc.);
- the name and address of the person responsible for the values;
- possession of, or ability to obtain, complete and current written
specification sheets detailing product ingredient and nutrient
information;
- product testing and/or information linkages with suppliers of products that
are sole sources of nutrients (such as baby formula) and foods for special
dietary use (such as meal replacements and nutrition supplements).
- Products are periodically reviewed against the Nutrition Labelling
Compliance Test to assess the accuracy of nutrient values. The Compliance Test is
available on the CFIA Web site:
www.inspection.gc.ca.
Food Standards
- Controls are in place to ensure that standardized products meet
labelling and/or legislative compositional requirements (e.g., Brix for jam). These controls may include, but are
not limited to:
- vendor certification,
- product testing (including testing some products to Canadian and/or
international standards).
- For products that are subject to intentional adulteration, such as olive
oil, the importer has more stringent verification controls in place. This
should include testing for authenticity at a Canadian laboratory certified with
the Canadian Standards Board for testing of the specific food, or another
scientific organization, such as AOAC, etc.
Labelling
- The importer has procedures in place to ensure that all mandatory
information is properly declared on food labels in compliance with Canadian
food labelling requirements, and that all label claims are accurate and not
misleading. Examples of such procedures are listed below.
- Labels are reviewed both for compliance with Canadian legislation (e.g., presence of mandatory labelling), and for
accuracy and correctness of information. This assessment includes, but is not
limited to:
- mandatory information, quality claims (e.g., organic, natural, fresh, Kosher, etc.), compositional claims (e.g., no preservatives, etc.), nutrition claims, and standards of identity.
- Any changes to labels (e.g., changes to
artwork, text and layout) and packaging (e.g.,
changes in the size of the principle display surface, available display surface
or the location of the principle display panel) are reviewed, in conjunction
with suppliers, for compliance with Canadian legislation.
- Any changes in formulations are assessed, in conjunction with suppliers,
for their impact on product labelling. This includes any changes in suppliers
or brands of ingredients, which can have an impact on labelling, composition,
or claims (for all formats of the specific product).
- In the case of corrective labels applied in Canada, incoming labels from
labelling and/or printing companies are reviewed against signed-off
proofs.
- All pamphlets, posters, handouts and other Canadian advertising materials
developed and/or distributed by the importer are reviewed and verified for
accuracy and compliance with Canadian legislation. (See Section 3 of the 2003 Guide to
Food Labelling and Advertising.)
- The importers have obtained allergy-related information from their
suppliers and manufacturers. This information can be used to conduct hazard
analysis and assess the need for label changes, including the need for any
precautionary statements on the label (e.g.,
"may contain peanuts").
NOTE:
i. Labelling requirements are set
out in the 2003 Guide to Food Labelling and Advertising. The above is
not a complete listing of all labelling requirements.
ii. The following guidance
documents provide further direction on compositional and labelling issues and
are available on the CFIA Web site at
www.inspection.gc.ca.
- For a list of
allergens to be assessed, see the Letter dated March 31, 1998, to food
manufacturers, importers, distributors and their associations on Labelling of
Food Causing Allergies and Sensitivities.
- For the labelling requirements for nutrition labelling, see the CFIA document Evaluation Standard for
Nutrition Labelling.
1.1.4 Food Additives
With respect to the use of food additives, the importer ensures that all
imported food meets the requirements of the Food and Drug Regulations
as well all other applicable regulatory requirements. |
Rationale
Inadequate control of food additives could result in chemical/biological
hazards and violation of Canadian regulations.
Assessment Criteria
- The importer ensures that all food additives contained in an imported food
product are permitted for use in the particular food and meet the requirements
of the Food and Drug Regulations (Division 16) and other applicable
regulations.
- The importer has access to specifications for all food additives.
- Where there are no specifications in the Food and Drug
Regulations, the importer requires that all food additives meet the
specifications of the Food Chemical Codex (FCC) or equivalent. For example,
suppliers may use specification sheets or blanket guarantees.
- The importer can demonstrate that any food additive which is used is within
the maximum level specified in the Food and Drug Regulations.
1.1.5 Net Quantity
The importer ensures that net quantity declarations are accurate and comply
with the Consumer Packaging and Labelling Act and Regulations (CPLA/R)
and other commodity specific legislation, such as the Canada Agricultural
Products Act and Regulations. |
Rationale
The net quantity declaration provides important information which consumers
use in making their purchasing decisions. Since the declaration helps consumers
to know how much food is in a container, it enables them to compare prices.
Consumers rely on net quantity declarations, trusting importers to provide the
quantity declared on a products label. Companies that do not declare
accurate net quantities for their products have an unfair competitive advantage
within their market sector, and do not contribute to the fair and effective
operation of the marketplace.
Canada, as a member of Organisation Internationale de Métrologie
Légale (OIML), uses an international measurement standard as its method of
determining the accuracy of net quantity declarations. The Average System is
set out in Section 39 of the Consumer Packaging and Labelling
Regulations.
Assessment Criteria
- The importer has procedures in place to ensure that the products net
quantity is in compliance with the Average System of Net Quantity Determination
as outlined in Section 39 of the Consumer Packaging and Labelling
Regulations. These procedures may include, but are not limited to:
- documented communication systems with suppliers, from which the importers
can obtain, upon request, detailed net quantity verification information (e.g., results of net quantity verifications, sample
scheduling and protocol, corrective actions on failed lots, etc.);
- in-house net quantity verifications of imported products. The frequency of
these verifications is determined by several factors, such as the type of
product, its packaging technology and its source. (For example, has the
supplier a track record for reliability?)
1.1.6 Grade
The importer has controls in place to ensure that products comply with the
applicable grade standards prescribed by Canadian legislation. |
Rationale
Inadequate control of grade may result in misrepresentation of the product.
It may also may lead to the increased importation of sub-standard product.
Grades exist under the Canada Agricultural Products Act and
Regulations.
Assessment criteria
- Controls are in place to ensure that imported products meet the grade
requirements prescribed by the pertinent Canadian regulations. These control
mechanisms may include the following:
- the importer has written purchasing specifications to ensure product meets
the prescribed grade;
- the importer retains copies of written grade specifications for shipments
of product purchased;
- where required, the importer ensures that each shipment is accompanied by a
valid foreign grade certificate from sources prescribed by the
regulations;
- where applicable, the importer obtains the appropriate Canadian grade
inspection certificate to verify compliance with the legislated
requirements;
- where grade certificates are not available from foreign or local inspection
services, the importer has a system to monitor the grade and/or quality
requirements of arriving product;
- the importer has access to trained personnel (such as graders and quality
control personnel) to assess the grade of incoming product.
- For imported products arriving in damaged or deteriorated condition, the
importer follows procedures to ensure that products or commodities are brought
into compliance by:
- re-grading the produce and providing evidence that the re-graded lot meets
the specified grade (by providing a valid CFIA grade inspection certificate,
for example);
- providing evidence of the disposal or dumping of deteriorated product which
does not meet grade (by providing a CFIA dump certificate, for
example);
- providing evidence of the use of the shipments for processing (by providing
an invoice from the processor indicating the quantity used for processing, and
a letter on company letterhead confirming the use of the product for
processing);
- providing evidence of disposition of the products for charitable use (by
providing a letter on the letterhead of a charitable organization acknowledging
the disposition of the shipment to charity).
- For other graded product, the importer employs qualified graders and/or
inspectors to sample and grade the contents of each shipment, and retains a
copy of the Grade Inspection report for each shipment.
1.2.1 Incoming Food Product Control
The importer controls incoming products so that foods are not exposed to
safety hazards (biological, physical or chemical) and labelling inaccuracies
are prevented. |
Rationale
Importers are responsible for ensuring that imported products meet the
specifications set out in the Section 1.1 of this document, Product
Information/Specification. Prevention of health hazards and fraud begins with
control of incoming materials. Inadequate incoming product controls (e.g., lack of appropriate product testing and
sorting, lack of verification of labels, etc.)
could result in the sale of contaminated products, misrepresented products or
products that do not meet grade, composition or quality standards.
NOTE: Not all Incoming Food Products require the same
degree of control. The degree of control exercised should be appropriate to the
level of risk posed by the food product.
Assessment Criteria
- All incoming product is visually inspected to ensure each product meets
specifications and Canadian requirements.
- The importer has identified, for each product, the specific concerns that
apply, considering various types of hazards (microbiological, chemical and
physical hazards, and extraneous matter) and issues such as fraud, grade, etc.
- The importer has set "Acceptance/Rejection" criteria for each
product.
- Personnel involved in the inspection of incoming material have adequate
technical knowledge and understanding of the significance of the concerns.
- Packaging material is suitable for the product. Packaging will vary with
the product and process and the associated contamination risks. Packaging
material which may affect the quality of the product is listed in the Reference Listing of Accepted
Construction, Packaging Materials and Non-Food Chemical Agents
published by CFIA,
which can be found on the CFIA Web site.
http//www.inspection.gc.ca/english/ppc/reference/cone.shtml.
- The importer controls incoming products through one of the following
programs or equivalent, listed as Options 1 - 4
below.
NOTE:
i. The above controls may be
carried out by the importer or by a designate, e.g., a public warehouse representative, a client or a
third party.
ii. The nutrition information may be
conveyed on an accompanying hard copy document with the delivery of the
food.
iii. In the case of foods that are
shipped to a purchaser on a continual basis, with no change to
the formulation, documentation may be provided on the basis of the first
shipment. The purchaser should be advised of any change to the nutrition
information as a result of formulation changes or other influences.
Controlling Incoming Products: Options 1 - 4
The first three options apply to products where the risks to safety are
high. The fourth option applies only to food products which
are not likely to pose a safety risk, but may require controls of quality and
composition.
OPTION 1: Periodic Evaluation of Incoming
Products
- The importer obtains a certificate of analysis (in English or French) for
each lot ,which includes the following:
- the sampling procedure(s) and analytical method(s) used to ensure the lots
are acceptable by the CFIA;
- the date, the type of determination to which the food was submitted, the
individuals/organizations conducting the analysis, product identification
(including the brand and lot number), and the name and signature of the
analyst;
- a verification that the lot was recently sampled and was stored under
appropriate conditions to prevent any changes which may render the product
unacceptable for sale.
- A representative sample is regularly taken and analysed to verify the
accuracy of the certificates of analysis. Samples are taken at a scheduled
frequency (e.g., monthly).
- The importer maintains a documented history for each supplier, indicating
the suppliers adherence to specifications (e.g., documenting analytical results).
- A new history of adherence to specifications is established when a firm
changes suppliers, purchases product from a new supplier, purchases a new
product from an existing supplier or when the importers sample results do
not agree with the certificate of analysis.
OPTION 2: 100% Lots Inspected
- Each incoming lot is sampled according to a pre-determined sampling plan
and analysed for adherence to specifications.
OPTION 3: Vendor Certification
- When the importer relies on vendor certification, the importer has data to
demonstrate the capability of the supplier's process to consistently
manufacture within specifications. This may include process capability studies.
Statistical process control charts for each critical control point must be
available upon request from each supplier.
- Prior to implementing a periodic monitoring program, the importer has
analyzed an appropriate number of consecutive lots to establish an historical
data base to confirm adherence to specifications.
- The importer conducts periodic monitoring to verify adherence to
specifications (e.g., annually).
- The importer conducts vendor audits to validate the status of the vendor
certification program.
OPTION 4: Specification Requirements (to be
utilized only when food safety risks are
unlikely)
Non-Conforming Incoming Products
- When products fail to meet specifications, the importer investigates and
identifies the root cause. Procedures are in place to ensure that
non-conforming products are not sold in Canada, or that the non-conformance is
corrected prior to sale. (See Section 1.4 of this document,
Deviations and Corrective Action.)
1.3.1 Product Code
Each package of food is identified with code marks, lot numbers and
expiration dates or best before dates (when applicable) on the label or
container. |
Rationale
Coding permits products to be traced through the distribution chain and
facilitates recalls. Where the code is also a best before date or an expiry
date, it provides information on shelf life and safe consumption of the
product.
NOTE: Mandatory coding requirements vary between
commodities, and are specified in appropriate legislation. To confirm specific
requirements governing various food products, importers should consult with
inspection authorities.
Assessment criteria
- The importer ensures that, where required or applicable, imported food has
been permanently marked with a legible code or lot identification. The coding
system:
- identifies the establishment, as well as the day, month and year in which
the food was produced.
- The importer ensures that the code marks used and the exact meaning of the
code (e.g., colour codes) are available.
- Where used, case codes are legible and represent the container code
within.
- Where applicable, the code accurately reflects the best before date,
expiration date, or shelf life of the food.
- Where applicable, the manufacturer controls the application of codes to
ensure that the integrity of the container is not compromised.
1.4.1 Deviation Control
When critical limits are exceeded or defects occur which could affect
product safety, composition or net quantity, procedures are in place to
identify, isolate and evaluate products. |
Rationale
Inadequate deviation procedures or non-adherence to procedures could result
in the sale of unsafe products, misrepresented products or products of inferior
grade.
NOTE: Deviation procedures apply to all
sections of this standard, where appropriate.
Assessment Criteria
- The importer has a pre-determined and documented deviation procedure to
identify deviations in products and procedures, to
isolate affected products, and to evaluate
them. Criteria are described below.
Identification of Deviation
- The importer has a system in place to identify deviations when they
occur.
Isolation of Affected Product
- The importer has effective procedures in place to isolate all product
manufactured during the deviation period. All unsatisfactory product is
isolated back to the point where the process was last in control. This could be
beyond the last satisfactory record.
- Isolated product is clearly marked (e.g.,
firmly attached tags contain the following information: hold number, product,
the amount, the date held, the reason for the hold, and the name of the person
holding the product).
- The importer maintains control of all product manufactured during the
deviation period (i.e., from the time the
product was first put on hold until final disposition).
Evaluation of Affected Product
- Product evaluation is conducted by a qualified person.
- Disposition of affected product (e.g.,
sorting of suspect lots, disposal, etc.) is
conducted in an appropriate manner by adequately trained personnel.
- Evaluation is adequate to detect potential health hazards, or to identify
misrepresentation or product that does not meet quality or grade requirements.
For example:
- sampling is adequate to identify the extent of the problem, the tests are
appropriate, the judgement is based on sound science and the product is not
released until the evaluation has determined that the product is in compliance
with appropriate legislation.
1.4.2 Corrective Action
Corrective action taken following any deviation is effective to rectify the
problem and to prevent recurrence of the deviation. |
Rationale
Corrective action procedures are necessary to determine the cause of the
problem and to take action to prevent recurrence. It is essential to follow-up
any corrective action with monitoring and reassessment, to ensure that the
correction has been effective. Appropriate corrective action will address the
root cause of any deviations of critical control points, thereby minimizing
health risks and product misrepresentation.
Assessment Criteria
- As part of the deviation procedure, the importer has a set of documented
corrective actions that include:
- an investigation to determine the cause of the deviation;
- effective measures taken to prevent recurrence of the deviation;
- verification by the importer of the effectiveness of the corrective action
taken.
See Section 7.2.3, Deviations and Corrective Action
Records.
1.5.1 Verification Procedures
The importer uses supplementary methods of evaluation to verify the
effectiveness of controls affecting product safety, composition,
representation, quality and compliance with Canadian legislation. |
Rationale
The purpose of verification is to assess the effectiveness of existing
controls in preventing health hazards, economic fraud and deviations from
Canadian regulatory requirements, and to indicate areas where improvements are
required.
Assessment Criteria
- The importer verifies the effectiveness of controls affecting product
safety, misrepresentation and other concerns.
NOTE: The verification methods will vary with the product
and process, since the methods must be appropriate to the specific hazards and
risks which may be encountered. Verification applies to all
sections of this standard (e.g., from
receiving product to training personnel), where appropriate.
Examples of Verification Methods
- Verification methods may include the following:
- sampling and analysis of finished product for the appropriate chemical,
microbiological or physical hazards;
- sampling and analysis of finished product for composition and net
quantity;
- independent, external audits;
- internal audits;
- incubation testing to confirm commercial sterility/hermetic seal;
- visual/mechanical/electronic screening;
- analysis of consumer complaint trends;
- vendor audits.
Frequency of Verification
- The importer conducts verification to validate the effectiveness of the
manufacturing controls at a frequency appropriate to the hazards associated
with the product and process.
Responsibility for Verification
- Individuals or organizations responsible for verification are identified.
These individuals or organizations are suitably qualified.
See Section 7.2.4, Verification Records.
NOTE: In import premises, "equipment" refers
primarily to refrigeration units, freezers and relabelling equipment. The
requirements outlined in this section are similar to those in the domestic
General Principles of Food Hygiene, Composition and Labelling Code of
Practice.
2.1.1 Equipment Maintenance
An effective maintenance and calibration program is in place to ensure that
equipment consistently performs as intended and prevents contamination of
product. |
Assessment Criteria
- The importer has an effective written preventative maintenance program to
ensure that equipment that may impact on food safety and on the accuracy of net
quantity, functions as intended. This includes:
- a list of equipment requiring regular maintenance;
- a program of maintenance procedures including frequencies (such as
equipment inspection, adjustments and part replacements) which is based either
on the equipment importer's manual or equivalent, or based on operating
conditions that could affect the condition of the equipment.
- The preventative maintenance program is adhered to.
- Written protocols, including calibration methods and frequencies, are
established by the importer, for monitoring equipment and/or controlling
devices that may impact on food safety, net quantity and quality.
- Equipment is maintained to ensure there is no potential for physical or
chemical hazards (e.g., no inappropriate
repairs, no flaking paint and rust, no excessive lubrication).
- Maintenance and calibration of equipment is performed by appropriately
trained personnel.
2.1.2 Instrumentation Maintenance and Calibration
Program
Instrumentation is designed, constructed, installed and maintained such
that equipment is capable of delivering the required procedure to ensure
product safety, quality and net quantity accuracy. |
Rationale
Control of environmental conditions (temperature and humidity) may be
crucial to the safety, quality and integrity of specific foods.
Assessment criteria
- Instruments which control factors critical to product safety and to the
maintenance of quality and net quantity are designed, installed, constructed
and calibrated as necessary to ensure that they function as intended. The
following are some examples of instrumentation that may be required to control
critical factors.
Temperature Measuring Devices
- Temperature measuring devices are installed, calibrated and maintained as
necessary to ensure accuracy, based on the equipment manufacturers
specifications and instructions.
MIG
Thermometers
- Mercury in glass thermometers is calibrated against a known standard just
prior to installation, and thereafter a minimum of once per year, or more
frequently as necessary to ensure accuracy, based on the equipment
manufacturers specifications and instructions. If there is a deviation of
more than 0.5°C (1°F) from the standard thermometer, corrective action is
taken.
- Thermometer scales are within the operating range, are easily readable to
0.5°C (1°F) and do not contain more than 4°C/cm (17°F/in).
Temperature Recorders
- The accuracy of temperature recorders is verified upon installation, and
thereafter a minimum of once per year, or more frequently as necessary to
ensure their accuracy, based on the equipment manufacturers
specifications and instructions.
Scales/Metering Devices
- The sensitivity is appropriate to the use.
- Scales are designed and installed to withstand the environmental conditions
or are adequately protected (e.g., away from
drafts, rust, corrosion, etc.)
- Scales and meters are calibrated as necessary to ensure accuracy at all
times, based on the equipment manufacturers specifications and
instructions.
Other Instrumentation
- Other specialized instrumentation necessary for the control of critical
factors is in place and calibrated as necessary, based on the equipment
manufacturers specifications and instructions.
NOTE: The importer should initiate corrective action as per
Section 1.4 of this document, Deviations and Corrective Action, whenever
products could have been affected as a result of a deviation in the accuracy of
instrumentation. Importers should consider not only the lot which was found to
be faulty, but all lots that might have been affected by the instrument
inaccuracy.
NOTE
Section 3.0, Premises Section 5.1.2,
Communicable Diseases/Injuries inclusive
These sections apply both to premises owned and operated by the
importer, and to other premises which are utilized by the importer (e.g., rented refrigerated warehouses).
|
3.1.1 Outside Property and Building
Buildings and surrounding areas are designed, constructed and maintained in
a manner to prevent conditions which may result in the contamination of
food. |
Assessment Criteria
Grounds, Roadways and Drainage
- The surrounding land is maintained to control sources of contamination such
as debris and pest harbourage areas.
- The building is not located in close proximity to any environmental
contaminants.
- Roadways are properly graded, compacted, dust proofed and drained.
- The surrounding property is adequately drained.
Exterior Building Structure
- The building exterior is designed, constructed and maintained to prevent
entry of contaminants and pests. For example, the exterior has no unprotected
openings; air intakes are appropriately located, and the roof, walls and
foundation are maintained to prevent leakage.
3.2.1 Design, Construction and Maintenance
Building interiors and structures are designed, constructed and maintained
to prevent conditions which may result in the contamination of food. |
Assessment Criteria
Floors, Walls and Ceilings
- Floors, walls and ceilings are constructed of material that is durable,
impervious, smooth, cleanable, and suitable for handling and storing foods in a
manner which will not result in the contamination of the environment or
food.
- Where appropriate, wall, floor and ceiling joints are sealed and angles are
coved to prevent contamination and facilitate cleaning.
- Floors, walls and ceilings are composed of materials that will not result
in the contamination of the environment or food.
- Floors are sufficiently sloped to permit liquids to drain to trapped
outlets.
- Ceilings, overhead structures, stairs and elevators are designed,
constructed and maintained to prevent contamination.
Windows and Doors
- Windows are sealed or equipped with close-fitting screens.
- Where there is a likelihood of breakage of glass windows that could result
in the contamination of food, the windows are constructed of alternative
materials or are adequately protected.
- Doors have smooth, non-absorbent surfaces and are close fitting and
self-closing where appropriate.
Area Separation
- Activities, food and non-food products are adequately separated by physical
or other effective means, where cross contamination may result.
3.2.2 Lighting
Lighting is adequate for the activity being conducted. Where appropriate,
light bulbs and fixtures are protected to prevent contamination of food. |
Assessment Criteria
- Lighting is appropriate such that the intended production or inspection
activity can be effectively conducted. Note that inspection areas are defined
as any point where the food product or container is visually inspected or
instruments are monitored, including product sorting areas. The lighting should
not be less than the following:
- 540 lux (50 foot candles) in inspection areas;
- 220 lux (20 foot candles) in work areas;
- 110 lux (10 foot candles) in other areas.
- Lighting does not alter the perception of food colour for purposes of
grading.
- Light bulbs and fixtures located in areas where there is exposed food are
of a safety type or are protected to prevent contamination of food in case of
breakage.
3.2.3 Ventilation
Adequate ventilation is provided to prevent excessive heat, steam,
condensation and dust, and to remove contaminated air. |
Assessment Criteria
- Ventilation provides sufficient air exchange to prevent unacceptable
accumulation of steam, condensation or dust.
- Ventilation openings are equipped with close-fitting screens or filters as
appropriate to prevent the intake of contaminated air. Filters are cleaned or
replaced as necessary.
3.2.4 Waste Disposal
Sewage, effluent and waste storage and disposal systems are designed,
constructed and maintained to prevent contamination. |
Assessment Criteria
- Drainage and sewage systems are equipped with appropriate traps and
vents.
- Establishments are designed and constructed so that there is no
cross-connection between the sewage system and any other waste effluent system
in the establishment.
- Effluent or sewage lines do not pass directly over or through packaging
areas unless they are controlled to prevent contamination.
- Adequate facilities and equipment are provided and maintained for the
storage of waste and inedible material prior to its removal from the
establishment. These facilities are designed to prevent contamination.
- Containers used for waste are clearly identified, leak proof and covered
where appropriate.
- Waste is removed and containers are cleaned and sanitized at an appropriate
frequency to minimize contamination potentials.
3.3.1 Employee Facilities
Employee facilities are designed, constructed and maintained to permit
effective employee hygiene and to prevent contamination. |
Assessment Criteria
- Premises are provided with an adequate number of conveniently located hand
washing stations with trapped waste pipes to drains.
- Washrooms have hot and cold potable running water, soap dispensers, soap,
sanitary hand drying equipment or supplies and a cleanable waste
receptacle.
- Washrooms, lunch rooms and change rooms are maintained in a clean
condition.
- Hand washing notices are posted in appropriate areas.
3.4.1 Water and Ice
The potability of hot and cold water is controlled to prevent
contamination. |
Assessment Criteria
- Potable water meets the requirements of Health Canada's Guidelines
for Canadian Drinking Water Quality. Water is analysed by the importer or
municipality at a frequency adequate to confirm its potability.
- There are no cross-connections between potable and non-potable water
supplies or all hoses, taps and other similar sources of
possible contamination are designed to prevent back-flow or back
siphonage.
- Where it is necessary to store water, storage facilities are adequately
designed, constructed and maintained to prevent contamination (e.g., covered).
- Water treatment chemicals, where used, are listed in the Reference
Listing of Accepted Construction Materials, Packaging Materials and Non-Food
Chemical Products published by CFIA, or the
importer has a "letter of no objection" from Health Canada.
- The chemical treatment is monitored and controlled to deliver the desired
concentration and to prevent contamination.
- Ice used as an ingredient or in direct contact with food is made from
potable water and is protected from contamination. Ice purchased by the
importer is treated as an incoming ingredient and is assessed under Section
1.2.1, Incoming Food Product Control.
4.1.1 Sanitation Program
An effective sanitation program for equipment and premises is in place to
prevent contamination of food. |
Assessment Criteria
- The importer has a written cleaning and sanitation program for all
equipment which includes:
- the identification of the responsible person;
- the frequency of the activity;
- the chemicals and concentrations used;
- the temperature requirements;
- the procedures for cleaning and sanitizing. For example, procedures
identify Cleaned Out of Place Equipment (C.O.P.) such as hand-cleaned equipment
and utensils, and outline disassembly/reassembly instructions as required for
cleaning and inspection. Areas on equipment which require special attention are
identified, and the methods of cleaning, sanitizing and rinsing are
outlined.
- The importer has a written cleaning and sanitation program for the premises
(packaging and storage areas) which specifies the areas to be cleaned, the
method of cleaning, the person responsible and the frequency of the
activity.
- Chemicals are used in accordance with the chemical manufacturers
instructions and are listed in the Reference Listing of Accepted Construction,
Packaging Materials and Non-Food Chemical Agents published by CFIA, or the
importer has a "letter of no objection" from Health Canada. The
Reference Listing can be found on the CFIA Web site,
http://www.inspection.gc.ca/english/ppc/reference/cone.shtml.
- Cleaning and sanitizing equipment is designed for its intended use and is
properly maintained.
- The sanitation program is carried out in a manner that does not contaminate
food or packaging materials during or subsequent to cleaning and sanitizing
(e.g., no contamination from aerosols or
chemical residues).
- Effectiveness of the sanitation program is monitored and verified (e.g., by routine inspection of premises and
equipment and/or microbiological testing) and where necessary, the program is
adjusted accordingly.
- Packaging operations begin only after sanitation requirements have been
met.
See Section 7.5.1, Sanitation Records.
4.2.1 Pest Control Program
Effective pest control programs are in place to prevent pest entry, to
detect and eliminate pests and to prevent the contamination of food. |
Assessment Criteria
- There is an effective written pest control program for the premises and
equipment that includes:
- the identification of the person to whom the importer has assigned
responsibility for pest control;
- where applicable, the name of the pest control company or the name of the
person contracted for the pest control program;
- the list of chemicals used, the concentration, the location where applied,
and the method and frequency of application;
- a map of trap locations;
- the type and frequency of inspection to verify the effectiveness of the
program.
- Pesticides used are registered under the Pest Control Products Act and
Regulations and are listed in the Reference Listing of Accepted Construction,
Packaging Materials and Non-Food Chemical Agents, published by
CFIA. Pesticides are
used in accordance with the label instructions. The Reference Listing can be
found on the CFIA
Web site,
http://www.inspection.gc.ca/english/ppc/reference/cone.shtml.
- Treatment of equipment, premises or ingredients to control pests is
conducted in a manner to ensure that the maximum residue limit of the Food
and Drugs Act and Regulations is not exceeded (e.g., the number of fumigation treatments per lot is
limited).
- Poisonous rodenticides are not used in food packaging or storage
areas.
- Birds and animals are excluded from establishments.
5.1.1 Cleanliness and Conduct
All persons entering food handling areas maintain an appropriate degree of
personal cleanliness and take the appropriate precautions to prevent the
contamination of food. |
Assessment Criteria
- All persons wash their hands upon entering unprotected food handling areas:
before starting work, after handling contaminated materials, after breaks and
after using toilet facilities. Where necessary to minimize microbiological
contamination, employees use disinfectant hand dips.
- Protective clothing, hair covering, footwear and/or gloves appropriate to
the operation in which the employee is engaged, are worn and maintained in a
sanitary manner (e.g., employees in packaging
areas wear effective hair coverings).
- Any behaviour which could result in contamination of food, such as eating,
use of tobacco, chewing gum, or unhygienic practices such as spitting are
prohibited in food handling areas.
- All persons entering unprotected food handling areas remove jewellery and
other objects which may fall into, or otherwise contaminate, food. Jewellery
which cannot be removed, including wedding bands and medical alerts, is
covered.
- Personal effects and street clothing are not kept in unprotected food
handling areas and are stored in a manner that prevents contamination.
- Access of personnel and visitors is controlled to prevent contamination.
The traffic pattern of employees prevents cross-contamination of the
product.
5.1.2 Communicable Diseases/Injuries
No person who is known to be infected with a disease likely to be
transmitted through food, or who has an open cut or wound, is permitted to work
in food handling areas where there is a likelihood of the person directly or
indirectly contaminating the food. |
Assessment Criteria
The importer has a policy, and enforces the policy, to prevent personnel who
are known to be suffering from a disease, or who are known to be carriers of a
disease transmissible through food, from working in food handling areas.
- The importer requires that employees advise management when they are
suffering from a communicable disease likely to be transmitted through food.
Conditions which are to be reported include:
- jaundice;
- diarrhoea;
- vomiting;
- fever;
- sore throat with fever;
- discharges from the ear, eye or nose.
- Employees having open cuts or wounds do not handle food or food contact
surfaces unless the injury is completely protected by a secure waterproof
covering (e.g., rubber gloves).
5.2.1 General Food Hygiene Training
Every food handler is trained in personal hygiene and the hygienic handling
of food such that they understand the precautions necessary to prevent the
contamination of food. |
Assessment Criteria
- The importer has a written training program for employees which is
delivered as follows:
- appropriate training in personal hygiene and hygienic handling of food is
provided to all food handlers at the beginning of their employment;
- the original food hygiene training is reinforced and updated at appropriate
intervals.
5.2.2 Technical Training
To ensure food safety, accuracy of product representation and net quantity,
personnel are trained such that they have adequate technical knowledge and
understanding of the operation(s) or process(es) for which they are
responsible. This technical knowledge is essential for personnel who assess
foreign manufacturers. |
Assessment Criteria
- Training is appropriate to the level of risk associated with the product
and the tasks assigned. For example:
- personnel are trained to understand the manufacturing process involved in
the production of the product, the importance of the critical limits, the
procedures for monitoring, the action to be taken if the limits are not met and
the records to be kept;
- personnel are trained to understand labelling requirements;
- personnel responsible for the maintenance of scales and metering devices
for net quantity controls are trained to identify deficiencies and to take the
appropriate corrective action;
- personnel and supervisors responsible for the sanitation program are
appropriately trained to understand the principles and methods required for
effective cleaning and sanitizing.
- Training is appropriate to ensure that personnel have a current
understanding of Canadian food legislation and importing policies. For example,
the importer has trained personnel responsible for:
- label development, design and sign-off;
- import documents and administrative regulatory requirements.
6.1.1 Food Carriers
Carriers used by the importer are designed, constructed, maintained,
cleaned and utilized in a manner to prevent food contamination. |
Assessment Criteria
- The importer verifies that carriers are free of contamination and suitable
for the transportation of food. For example:
- carriers are inspected by the importer prior to loading and upon receipt of
products to ensure they are free from contamination and suitable for the
transportation of food;
- the importer can demonstrate that the carrier has an adequate cleaning and
sanitizing program (e.g., for bulk carriers, a
written cleaning and sanitizing procedure is available).
- Where the same carriers are used for food and non-food loads (e.g., dual use), procedures are in place to restrict the
type of non-food loads to those that do not pose a risk to food loads in the
same shipment, or in subsequent shipments (after an acceptable clean out). For
example:
- the importer receives a cleaning certificate and a record of the previous
material transported prior to loading or unloading dual use tankers;
- the importer has a program in place to verify the adequacy of cleaning
(e.g., tanker inspections, sensory evaluation
of ingredients and/or analysis as appropriate).
- Carriers are loaded, arranged and unloaded in manner that prevents damage
and contamination of the food.
- Bulk tanks are designed and constructed to permit complete drainage and to
prevent contamination.
- Where appropriate, materials used in carrier construction are suitable for
food contact.
6.1.2 Temperature Controls
Products requiring temperature controls are transported in a manner to
prevent temperature abuse that could result in deterioration of the product and
affect its safety. |
Assessment Criteria
- Products requiring refrigeration are transported at 4°C (39°F) or less and are
appropriately monitored. Frozen products are transported at temperatures that
do not permit thawing.
- Products are transported under conditions to minimize microbiological,
physical and chemical deterioration (e.g.,
thermophilic spoilage, rusting or corrosion of the container in the case of low
acid canned foods).
6.2.1 Food Product Storage
Storage and handling of food products are controlled to prevent damage,
deterioration and contamination. |
Assessment Criteria
- Products requiring refrigeration are stored at 4°C (39°F) or less and are
appropriately monitored. Frozen products are stored at temperatures that do not
permit thawing and are appropriately monitored.
- Products are handled and stored in a manner to prevent damage and/or
contamination (e.g., thermophilic spoilage,
rusting or corrosion of containers, protection of susceptible products from the
effects of light, control of stacking heights and forklift damage).
- Stock rotation is controlled to minimize deterioration and prevent spoilage
that could present a health hazard (e.g.,
rusting of containers, container corrosion resulting in leakage, products
exceeding shelf life).
- Humidity sensitive products are stored under appropriate conditions to
prevent deterioration.
- Defective or suspect products that have been returned are clearly
identified and isolated in a designated area for appropriate
disposition/sorting.
6.2.2 Non-Food Chemicals Receiving and
Storage
Non-food chemicals are received and stored in a manner that will prevent
contamination of food, packaging materials and food contact surfaces. |
Assessment Criteria
- Non-food chemicals are received and stored in a dry, well-ventilated
area.
- Non-food chemicals are stored in designated areas such that there is no
possibility for cross-contamination of food or food contact surfaces.
- Where required for ongoing use in food handling areas, these chemicals are
stored in a manner that prevents contamination of food, food contact surfaces
or packaging materials.
- Non-food chemicals are stored and mixed in clean, correctly labelled
containers.
- Non-food chemicals are dispensed and handled only by authorized and
properly trained personnel.
7.1.1 General Record Requirements
Information is recorded and an accurate history of the product is
maintained. Records are retained for the required period of time. |
Assessment Criteria
- Records kept by the importer are legible, permanent and accurately reflect
actual events, conditions or activities.
- Errors or changes are identified so that the original record remains clear
(e.g., strike out with a single stroke and initial the correction/change).
- Each entry on a record is made by the responsible person at the time that
the specific event occurred. The completed records are signed and dated by the
responsible person.
- Critical records are signed by a qualified individual designated by
management prior to distribution of the product. All other records are reviewed
at an appropriate frequency to provide an early indication of potentially
serious deficiencies.
- Records are retained for at least one year after the expiry date on the
label or container, or if there is no expiry date, for at least two years after
the date of sale.
- Records are maintained and are available upon request.
- Importers are expected to have access to the foreign manufacturers
records, upon request, concerning critical control points in the manufacturing
process.
7.2 RECEIVING OF IMPORTED PRODUCT RECORDS
7.2.1 Incoming Imported Product Control Records
The importers records demonstrate the adequacy of incoming product
control. |
Rationale
Records are necessary to verify the importer's control over biological,
physical or chemical hazards, representation, composition and quality.
Assessment Criteria
- The minimum record requirements for the four monitoring and/or
certification options (Periodic Evaluations, 100% Lot Inspection, Vendor
Certification, and Non-Conforming Imported Product) are outlined below.
Periodic Evaluations
- The importer has records to:
- document the history of adherence to specifications (i.e., analytical results);
- state the results of spot checks (i.e.,
analytical results).
100% Lot Inspection
- The importer has analytical results for each incoming lot.
Vendor Certification
- The importer has records which:
- demonstrate knowledge of the supplier's process (e.g., process flow charts, critical control point
identification, process specifications, critical limits, monitoring and
verification reports, corrective action plans and reports, and on-site
evaluation reports);
- demonstrate the capability of supplier's process (e.g., capability studies), with statistical process
control charts available upon request;
- provide an historical data base (e.g.,
analytical results on consecutive lots);
- record results of periodic monitoring (e.g., analytical results);
- state the results of supplier audits (e.g., audit reports).
Non-Conforming Imported Product
- The importer keeps records which:
- identify the imported product;
- identify the deficiency;
- specify the preventative and corrective action taken.
7.2.2 Net Quantity Records
Records are available to demonstrate the adequacy of procedures and methods
used in net quantity determination. |
Rationale
Records are required to verify that the net quantity declarations are
accurate.
Assessment Criteria
- Records are available to verify that reliable procedures have been followed
in determining the net quantity of pre-packaged products.
- Records are available to demonstrate that the net quantity protocol is
being followed.
7.2.3 Deviations and Corrective Action
Records
Records are available to demonstrate the control of deviations and the
effectiveness of corrective actions taken. |
Rationale
Records are required to verify that the importer has control of deviations
and that corrective action has been effective.
Assessment Criteria
- The importer supplies records of deviations and corrective actions which
contain the information specified below.
Deviation/Hold
- Records contain the product/code, the date the product was held/released,
the reason for the hold, the amount of product held (e.g., back to the point where the process was last in
control), the results of the evaluation/sort (e.g., the amount analysed and an analysis report of the
number and nature of defects).
- The records further contain information about the disposition of the held
product (e.g., the amount sorted, amounts
destroyed, amounts reconditioned, amounts disposed of through employee sales,
distress or salvage, and retail sales).
- Records include the signature of personnel responsible for the hold and
evaluation, and the signed authorization for disposition.
Corrective Action
- Records identify the cause of deviation, the corrective action taken to
correct the deficiency, and a follow-up/assessment to gauge the effectiveness
of the corrective action.
- Records include the date the corrective action was taken and verified and
the signature of person responsible.
- Records further include the preventative action plan that was developed as
a result of the product deviation.
7.2.4 Verification Records
Records are available to demonstrate the adequacy of verification
procedures. |
Rationale
Records show the results of verification and confirm the effectiveness of
control measures.
Assessment Criteria
- Records of verification include the methods utilized, the date, the
individuals/organizations responsible, the results/findings and the action
taken.
7.3.1 Equipment and Instrumentation Maintenance and
Calibration Records
Records are available to demonstrate adherence to the maintenance program
for critical equipment. |
Rationale
Records permit verification of the effectiveness of the equipment
maintenance and calibration program.
Assessment Criteria
- In Maintenance Records for critical equipment, the
importer typically includes an identification of the equipment, the maintenance
activity, the date of maintenance, the person responsible, and the reason for
the activity.
- In Calibration Records for critical equipment, the
importer typically includes an identification of equipment, the date of
calibration, the person responsible, the calibration results, the reference
standard and the materials used.
7.4.1 Water/Ice Quality Records
Written records that adequately reflect control of water quality and
treatment are available upon request. |
Assessment Criteria
- The importer has records available to demonstrate the adequacy of the
microbiological and/or chemical safety of the water supply, including Water
Potability Records and Water Treatment Records.
- Water Potability Records include identification of the
water source and the sample site, the date the sample was taken, the analytical
results, the name of the analyst and his/her certification/accreditation.
- Water Treatment Records include identification of the
method of treatment, the date of the treatment, the sample site, the analytical
results, the name of the analyst and his/her certification/accreditation.
7.5.1 Sanitation Records
Records are available to demonstrate the effectiveness of the sanitation
program. |
Assessment Criteria
- The records of sanitation activities include the date, the person
responsible, the findings, the corrective action taken, and the microbiological
test results where appropriate.
7.5.2 Pest Control Records
Records are available to demonstrate the effectiveness of the pest control
program. |
Assessment Criteria
- Minimum pest control records include:
- the results of the inspection programs and the corrective action taken
(e.g., the findings in traps, the location of
insect infestations);
- a record of pest control activities (e.g.,
the pesticide used, the method and location of application, the dates of
fumigation, etc.), including the date;
- the person responsible and their qualifications.
7.6.1 Complaint Records
Records of product complaints, investigation findings and action taken are
available upon request. |
Rationale
Records provide verification that the appropriate action was taken within a
reasonable time frame.
Assessment Criteria
- The establishment maintains detailed records of consumer complaints
received and the investigation, including corrective action taken.
Consumer Complaints
- The importers records contain, at a minimum
- the name, address and telephone number of the complainant, and the date the
complaint was received;
- details of complaint and/or illness;
- the products name, code and size;
- the retail outlet where the product was purchased.
Investigation
- The importers records contain, at a minimum
- the name of person responsible for the investigation;
- the action taken (concerning the product and/or the process) as a result of
the investigation;
- the corrective action taken to prevent a recurrence;
- a follow-up/assessment of the effectiveness of the corrective action.
7.6.2 Distribution Records
Product distribution records are available to enable the importer to recall
any lot of food in a timely fashion. |
Assessment Criteria
- Distribution records contain sufficient information to permit a product to
be traced to a particular code or lot number. The importer has, at a minimum,
distribution records containing:
- the product identification (e.g., the
products common name, its code marks or lot numbers, the manufacturing
establishment where it was produced, its date of production, its date of
importation, its size).
- Records further specify the purpose of the recall and the amount of
recalled product(s), broken down as follows:
- the total quantity of the recalled food originally in the importer's
possession;
- the total quantity distributed at the time of the recall;
- the total quantity remaining in the company's possession.
- Records further include the areas where the recalled food was distributed
by regions, cities and provinces:
- including retailers' and wholesalers' names and addresses;
- including customer names, addresses and phone numbers to the initial level
of product distribution.
- Records also provide information on any other product which could be
affected by the same hazard.
8.1.1 Product Complaints
The importer has an effective system for handling and investigating
complaints. |
Rationale
Product complaints are an important indicator of possible deficiencies in
manufacturing controls and/or deficiencies in the distribution handling system.
When the complaint handling system itself is deficient, it could result in
failure to identify and eliminate risks.
Assessment Criteria
- The importer has a system in place to handle and investigate product
complaints as follows:
- the importer has identified the person or persons responsible for
receiving, evaluating, categorizing and/or investigating complaints;
- complaints are accurately categorized according to safety, composition,
quality and other regulatory concerns;
- potentially serious complaints are forwarded immediately to appropriate
personnel for action;
- safety and contamination complaints are investigated by appropriately
trained technical personnel;
- examination of the complainant's specimen, the retail product or other
product of the same code is conducted on complaints related to food
safety;
- complaints pertaining to composition, quality, fraud and other regulatory
concerns are investigated in an effective manner;
- the depth of the investigation is appropriate to the risk and similar
complaint trends;
- appropriate corrective action is taken for deviations identified during the
investigation.
See Section 7.6.1, Complaint Records
8.2.1 Recall Procedure
Every importer of a food establishes a written procedure to permit the
complete, rapid recall of any lot of food from the market. |
Assessment Criteria
- The written procedure identifies the person or persons responsible (e.g.,
recall coordinators) and the roles and responsibilities of those who coordinate
and implement a recall.
- The procedure specifies methods to identify, locate and control recalled
product, and includes a requirement to investigate other products that may be
affected by the hazard, and should be included in the recall.
- The procedure requires that the recall be monitored to assess its
effectiveness (e.g., an "effectiveness
check" is conducted to the appropriate level of distribution specified in
the recall notice).
- Records on the recall and on the effectiveness check are available.
- The Canadian Food Inspection Agency is immediately notified in the region
where the importer is located. This notification includes the following:
- the amount of product produced, the amount in inventory and the amount
distributed;
- the name, size, code or lot numbers of the food recalled;
- the area in which the product was distributed (e.g., local, national, international);
- the reason for the recall.
8.2.2 Recall Capability
Recall procedures are tested periodically to verify the capability to
rapidly identify and remove product from the market. |
Assessment Criteria
- The importer demonstrates the capability to provide accurate information on
a timely basis, to verify the companys capability to rapidly identify all
affected product and remove it from the marketplace. For example, the importer
conducts periodic testing (e.g., internal
simulations) to verify capabilities to control a code lot and to reconcile the
amount of product produced imported, in inventory and in distribution. (Note:
Importers should also be able to verify that their procedure will identify
other lots that might have been affected.) Any deficiencies in the recall
procedure are identified and corrected.
Allergens for the purposes of this document, those
substances that may cause serious or life threatening reactions in sensitive
segments of the population. Allergens include: peanuts; tree nuts (almonds,
Brazil nuts, cashews, hazelnuts [filberts], macadamia nuts, pecans, pinenuts,
pistachios, walnuts); sesame seeds; milk; eggs; fish, crustaceans (e.g., crab, crayfish, lobster, shrimp) and shellfish
(e.g., clams, mussels, oysters, scallops);
soy; wheat; sulphites.
Capability a standardized evaluation of the inherent
capability of equipment to consistently perform a specified function under
actual operating conditions, after significant causes of variation have been
eliminated.
Certification the procedure by which official
certification bodies and other officially recognized bodies provide written or
equivalent assurance that foods or food control systems conform to
requirements. Certification may be, as appropriate, based on a range of
inspection activities which may include continuous on-line inspection, auditing
of quality assurance systems and examination of finished products. (Codex)
Control - means that an operation performs consistently
within pre-determined limits based on process capability, meets process
requirements, provides a mechanism to maintain the stability of the process and
consistently results in a safe product with a constant composition, quality and
net quantity.
Control (noun) - the state wherein correct procedures are
being followed and criteria are being met.
Country of Origin for the purposes of food
labelling, that country where 51% or more of the cost of the product was
incurred, including manufacturing and labour, and where the product came into
being.
Corrective action the actions to be taken when the
result of monitoring a Critical Control Point (CCP) indicates a loss of
control. This term refers to any action taken to bring the process into control
and deal with any affected product when critical limits or other criteria are
not met. The action should be prompt and appropriate to the seriousness of the
deficiency.
Critical Control Point (CCP) a point, step or
procedure at which control can be applied and a food safety hazard can be
prevented, eliminated or reduced to acceptable levels.
Critical factor any property, characteristic,
condition, aspect, or other parameter, variation of which may affect the
safety, quality, composition or quantity of the product or the process beyond
critical limits.
Critical limit a value which separates acceptability
from unacceptability.
Container size for the purposes of this document,
container size includes the full range of sizes from the smallest size of the
containers sold at retail to include bulk amounts in packages sold per litre,
kilogram, etc.
Deterioration for the purposes of food products
discussed in this document, deterioration can be used interchangeably with
spoilage. However, non-food products such as packaging materials can also
deteriorate. For non-food items, deterioration is a physical or chemical change
in the material that may adversely affect the safety or quality of the
food.
Deviation failure to meet the critical limits or
other specified requirements for a critical factor.
Deviation procedure a pre-determined and documented
set of corrective actions which are implemented when a deviation occurs. The
goal is to re-establish control of the process and hence, of the affected
product.
Documents for the purposes of this text, documents
refer to written formulae, procedures or specifications used by, or required
of, an importer or manufacturer.
Final use of product the nature of the product at
the time of sale (for example, ready-to-eat, re-processed, repackaged).
Food please refer to definition in the CFIA Import Policy
document.
Handling instructions instructions on the label or
in the product description document explaining how the consumer should store or
handle the food in preparation for eating (i.e., keep refrigerated after opening, keep frozen,
cooking instructions microwave or oven cooking).
Hazard the potential to cause harm. A biological,
chemical or physical property that may cause an unacceptable consumer health
risk, or a problem/situation that may cause a deviation in the composition or
quality of a food product.
Incubation tests in which the heat processed
products are kept at a specific temperature for a specified period of time in
order to determine if outgrowth of microorganisms or other problems occur under
these conditions.
Inspection areas for the purposes of the Section
3.2.2 of this document dealing with lighting requirements, any point where food
products or containers are visually inspected or instruments are monitored.
Labelling instructions details required on the label
and in the product description document as per the Consumer Packaging and
Labelling Act & Regulations, or applicable labelling sections in other
Acts and Regulations enforced by the CFIA.
List of ingredients a listing of ingredients and
components (ingredients of ingredients) of a food product, listed in descending
order of their proportion by weight.
Lot the amount of product of a specific container
size, product style and code produced by a food establishment during a
specified period of time.
Low acid food a food, other than an alcoholic
beverage, where any component of the food has a pH greater than 4.6 and a water activity greater
than 0.85.
Monitoring a planned sequence of observations or
measurements to assess whether a CCP (or other activity) is under
control.
Origin of product for the purposes of the Product
Information described in Section 1.1.1, the country in which the product was
manufactured or grown.
Packaging material the type of container in which
the product is packaged (e.g., glass, wood,
plastic, cardboard).
Product specifications and characteristics for the
purposes of Section 1.1, Product and Shipment Information/Specification Product
Description, including the Shipment Information sub-section, those features
that characterize the product by identifying safety and quality risks, and
handling and storage requirements. Examples include frozen foods, canned foods,
low-acid canned foods, acidified-low-acid-canned foods, marinated foods, foods
with > 4.3 pH., foods packed in 6%
sugar or packed in light syrup, etc.
Product description the defining characteristics of
a product that enables its identification.
Product name the common name of the food as set out
by the Food and Drug Regulations: a) the name of a food printed in
bold name type in the Food and Drug Regulations; b) the name
prescribed by any other Regulations; or c) if the name is not so printed or
prescribed, the name by which it is commonly known. Examples include: canned
apple sauce, milk chocolate, whiskey, bottled water, (naming the fruit) juice,
frozen mixed vegetables, dried kidney beans, etc.
Product specifications are the measurable levels and
tolerances of characteristics which influence the level of risk associated with
each product.
Product variety the specific type of the commodity
(where applicable), such as Macintosh apples, 1/a pears.
QMS Quality Management System one of the six
principles outlined in the CFIA Import Policy document.
Recall: periodic testing internal activities
conducted on a periodic basis to verify the capability of the importer to
rapidly identify and control a given lot of product. These activities do not
necessarily require the importers to contact customers.
Records for the purposes of this document,
observations and measurements recorded by an importer and a manufacturer to
determine adherence to critical limits or other specified requirements for
critical factors or critical control points.
Health Risk an estimate of the likelihood of the
occurrence and the likely magnitude of the consequences of an adverse event to
animal or human health in the importing country during a specified time.
Spoilage a process whereby food is rendered
unacceptable through microbiological or chemical reaction.
Vendor for the purpose of this text, vendor is
equivalent to supplier.
Vendor certification the process of acceptance of
incoming materials that does not rely on 100% inspection of incoming lots. The
importer conducts a series of events prior to receipt of the material that
ensures the material meets the required specification.
Verification examination of the accuracy,
correctness or effectiveness of validated processes or process controls through
testing, investigation or comparison against a standard.
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