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Food Safety Enhancement Program Manual

Chapter 1 - Introduction and Background

Section 1 - Introduction to FSEP

The objective of the Food Safety Enhancement Program (FSEP) of the Canadian Food Inspection Agency (CFIA) is to ensure that the conditions under which food products are manufactured and the ingredients used in their manufacture lead to the production of safe food. FSEP applies to the following commodity groups: meat and poultry, dairy, processed fruit and vegetables, shell eggs, processed eggs, honey, maple, and hatcheries.

The safety of food products produced in Canada is ultimately the responsibility of the food industry. Food inspection programs administered by the CFIA confirm that establishments have taken the appropriate steps to produce safe food products.

In the past, food manufacturers relied almost entirely on end-product testing to determine the safety of their products. Now, industry representatives and government together have developed scientifically sound principles to control production. These principles allow operators to react quickly to hazards that arise during production. As scientific developments continue in the areas of food production and inspection, Canadian regulatory programs will evolve accordingly.

Hazard Analysis Critical Control Point (HACCP) was conceived in the 1960s when the US National Aeronautics and Space Administration (NASA) asked Pillsbury to design and manufacture the first foods for space flights. Since then, HACCP has been recognized internationally as a logical tool for adapting traditional inspection methods to a modern, science-based, food safety system. Based on risk-assessment, HACCP plans allow both industry and government to allocate their resources efficiently in establishing and auditing safe food production practices.

FSEP encourages establishments to adopt HACCP principles. An establishment's HACCP system includes its HACCP plans and prerequisite programs as well as procedures for the maintenance of the HACCP system.

The HACCP system prevents food safety problems by providing control throughout the manufacturing process at critical steps identified as Critical Control Points (CCPs). These points permit operators to detect and control hazards before products are distributed.

Under FSEP, establishments are required to monitor and verify manufacturing processes, maintain records of their HACCP System and update the HACCP system regularly. Although FSEP focusses on food safety issues, other non-food safety regulatory requirements and obligations will continue to be monitored by the CFIA.

Section 2 - Benefits of FSEP

2.1 - International and national

2.1.1 - International acceptance

Internationally, FSEP is consistent with the principles and application of the Hazard Analysis Critical Control Point (HACCP) system developed by Codex Alimentarius. As HACCP systems are accepted worldwide, FSEP will help the Canadian industry to maintain and expand its international markets.

2.1.2 - National acceptance

FSEP meets national expectations that HACCP principles would be included in food safety programs. FSEP is consistent with the CFIA's Quality Management Program (QMP) for fish and seafood products and with HACCP initiatives being developed by provincial governments.

2.2 - Industry and government

2.2.1 - Responsibilities

FSEP clearly delineates the responsibilities of both government and industry for the production of safe food in Canada. While establishments are responsible for the food that they produce and market, the government oversees industry compliance with regulatory requirements.

2.2.2 - Communication

In developing and implementing FSEP, the industry and the CFIA have had to communicate on an ongoing basis. This practice involves both informal and formal methods as the Agency evaluates HACCP systems.

2.2.3 - Resources

FSEP allows government to use risk-management techniques in which the government allocates its resources proportionately to low-risk and high-risk establishments, on the basis of product type and establishment complexity. By focussing on food processing establishments or production lines that are considered higher risk, the CFIA and industry will use resources more effectively.

2.2.4 - Product recall/destruction

FSEP improves employee awareness and responsibility by ensuring a rapid and efficient response to deviations at Critical Control Points. On-line monitoring throughout the production process results in fewer recalls and/or reduced product destruction.

2.2.5 - Equivalency

With the implementation of FSEP, the Agency is able to negotiate the acceptance of equivalent food safety programs with other governments in Canadian export markets. It may be possible to agree with specific trade partners to reduce requirements for direct inspection control over certain products.

Section 3 - Background

In 1986, after considering the Nielsen Report recommendations, the federal Cabinet concluded that Canada's food inspection system is effective and warrants a high degree of confidence among Canadians. Cabinet reconfirmed Agriculture Canada as the primary regulatory contact for food manufacturers that fall under the authority of the Canada Agricultural Products Act, and asked Agriculture Canada to focus on food safety, in addition to food quality and to work more closely with other federal agencies responsible for food inspection (Health and Welfare Canada, Fisheries and Oceans Canada, and Consumer and Corporate Affairs Canada). To this end, the federal departments concerned with food safety agreed to establish minimum federal food safety inspection standards based on HACCP principles. These were to be applied in all registered and non-registered food processing establishments.

In its 1988 report on the Food Production and Inspection Branch of Agriculture Canada, the Office of the Auditor General made specific recommendations concerning inspection and food safety. The following are excerpts from its summary of the Main Points section:

• The Branch shares responsibility with industry and with provincial and other federal departments for the safety, health and wholesomeness of agricultural food products. It conducts a wide range of activities to protect the health and safety of Canadians and the viability of large sectors of Canada's food, plant and animal industries. Work remains to be done to fully determine which risks are most serious, so that resources can be better concentrated where risk is greatest. (paragraph 8.2)
• The Branch needs to strengthen several key inspection practices to provide reasonable assurance that human health and safety threats posed by chemical and bacterial hazards associated with food and agricultural products are prevented or removed. Although it does extensive sensory inspections, it needs to use additional laboratory testing, generally the only way of detecting these hazards. (paragraphs 8.26 to 8.40, and 8.44 to 8.48)

The Department's Agricultural Policy Review (1989) confirmed that, in the minds of consumers, food safety ranks as very important. The review concluded that:

• responsibility for food safety must be shared by all participants in the food chain, including processors and consumers;
• Canada's food inspection system should adopt an open model, enabling consumers and industry to become directly involved; and
• to maintain consumer confidence, Canada should adopt internationally recognized food safety standards focussing on food safety risk assessment.

The Food Production and Inspection Branch of Agriculture Canada responded to the program review with the announcement of the Food Safety Enhancement Program (FSEP). This program translates the recommendations into practical terms, with the focus on food safety. It is consistent with international trends, emphasizing cooperation between government and industry, whose members are ultimately responsible for the safety of their own products.

The Agricultural Policy Review (APR) outlined the department's strategic priorities and the pillars of reform. These included the following:

• more market response
• greater self-reliance in the agri-food sector
• regional diversity
• an increase in environmental sustainability

The following initiatives resulted from the Review:

• Fisheries and Oceans Canada developed the Quality Management Program (QMP), based on HACCP principles. The QMP was subsequently implemented in all that department's registered establishments.
• Agriculture Canada developed the Food Safety Enhancement Program (FSEP), which incorporated HACCP principles. Pilot projects and expert committees were used to develop generic models to guide both industry and government.
• Federal departments developed a common approach for inspection activities in both registered and non-registered establishments. These principles were incorporated into FSEP.

In 1997, the food inspection components of Agriculture and Agri-food Canada, Health Canada and Fisheries and Oceans were amalgamated to create the Canadian Food Inspection Agency (CFIA). Responsibility for implementing FSEP and the QMP was transferred to the Agency.

Section 4 - Public perception of food safety

The food inspection programs provided by the Canadian Food Inspection Agency have evolved into a highly respected, multi-faceted service to industry and consumers that has earned international acclaim. These programs have come under scrutiny as a result of two factors: consumers' concern about the food they eat, and government's decision to use resources where risks are greatest.

The CFIA works jointly with international and domestic governments and industry to implement a food safety enhancement program based on HACCP principles as outlined by Codex Alimentarius.

Section 5 - FSEP and the marketplace

To maintain or expand its international trade markets, Canada must meet the standards and trade requirements of foreign countries (HACCP). The CFIA, in cooperation with industry, communicates proactively with these countries to ensure their acceptance of FSEP as equivalent to their own standards.

To maintain or expand their domestic markets, establishments will have to meet the expectations of consumers, who demand a safe food product. By implementing FSEP, federally registered establishments demonstrate to consumers their commitment to using the most effective food safety system available.

Section 6 - Program description

FSEP encourages all federally registered establishments with the exception of fish and seafood establishments, to develop, implement and maintain a HACCP system.

FSEP takes a preventive approach to controlling food safety. It applies control throughout the food manufacturing process, while ensuring that all food safety regulations are being met.

Most companies will find that many of the controls required in a HACCP system are already in place and operating in their establishments.

HACCP plans must follow seven basic principles:

1. List the hazards associated with each step and incoming materials
2. Apply the HACCP decision tree to determine CCPs
3. Establish critical limits
4. Establish monitoring procedures
5. Establish deviation procedures
6. Establish verification procedures
7. Establish record keeping and documentation for Principles 1 through 6.

6.1 - References

For more details, please refer to the following documents:

• Recommended International Code of Practice General Principles of Food Hygiene, developed by Codex Alimentarius
• HACCP Principles and Application Guidelines, developed in 1997 by the National Advisory Committee on Microbiological Criteria for Foods
• Developing HACCP Plans, published by the International Association for Food Protection.

Section 7 - Program responsibilities

Under FSEP, members of the food industry are responsible for designing and implementing their HACCP systems. The role of the CFIA is to define the requirements in consultation with the food industry and to verify the effectiveness of the HACCP system in each federally registered establishment.

Industry is responsible for:

• providing a corporate commitment to HACCP;
• developing and implementing prerequisite programs, HACCP plans and HACCP system reassessment procedures;
• maintaining the necessary records;
• ensuring that appropriate staff are trained in their areas of responsibility;
• submitting any new HACCP plans to the CFIA for review; and
• providing necessary assistance to CFIA staff during the recognition process, and during subsequent system audit activities.

The Canadian Food Inspection Agency is responsible for:

• recognizing establishments;
• auditing establishment records;
• assessing corrective actions taken by establishments;
• observing on-site monitoring and verification activities;
• ensuring that establishments continue to maintain their HACCP systems; and
• ensuring that establishments comply with all acts, regulations and program requirements.

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