CHAPTER 5 - MANUFACTURING CONTROLS

Allergens include milk, eggs, fish, crustaceans, shell fish, tree nuts, peanuts, soy, wheat, sulphites, sesame seed.

Ingredients which may cause sensitivities include lactose, MSG (monosodium glutamate).

The following are examples of such procedures:

• New label review
• Incoming label review for accuracy/correctness
• Formulation changes/substitutions

Inadequate control of label accuracy (e.g. no new label review but no listed allergens used in the plant).

Honey Regulations: Sections 5(1); 5.1; 6; 7; 8; 21(1)(b); 25(a); 34(a), (b) and (d); 35(1), (2), (3), (4) and (5); 36(1), (2) and (3); 37(1), (2) and (3); 52(1) and (2); Schedule I Table I, II, III, IV.
http://laws.justice.gc.ca/en/C-0.4/C.R.C.-c.287/index.html

• Written specifications for honey, incoming ingredients, food additives and processing aids. Specifications include a provision for compliance with the Food and Drugs Act and Regulations.
• The requirements for a letter of guarantee from the supplier.
• Monitoring and testing to verify adherence to specifications.

The establishment that extracts honey must ensure that:

• Medications used have been approved for use for treating bees.
• The recommended preparation and dosage level of the medications have been followed.
• The withdrawal time for the medication has been followed before the honey is harvested.
• Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).

Medications used for treating bees are not approved.

Dosages and/or withdrawal times for medications have not been followed.

The establishment has specifications for critical ingredients but cannot demonstrate adherence (refer to allergen list).

No program or documentation to verify adherence to specifications for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).

Food and Drug Regulations
http://laws.justice.gc.ca./en/F-27/C.R.C.-c.870/124782.html#rid-124825

Appendix 1 - Incoming Honey and Ingredient Controls.

Packaging materials/containers in use for foods must comply with Division 23 of the Food and Drug Regulations and the Honey Regulations.

Every container for honey shall be in clean, sanitary and sound condition and have a tightly fitting lid.

In addition all bulk containers shall be free from severe dents or buckling and from obvious signs of internal rusting.

Every container for prepackaged honey shall be new.

All empty containers are adequately protected from contamination and damage upon arrival and departure.

Containers are only used for their intended purpose.

Container is not free from severe dents or buckling.

Containers are not only used for their intended purpose.

Packaging material/containers does not comply with the Honey Regulations (e.g. non-standard container sizes).

Empty containers are not adequately protected from contamination and damage.

Food and Drug Regulations: Division 23.
http://laws.justice.gc.ca./en/F-27/C.R.C.-c.870/124782.html#rid-124825

Appendix 1 - Bulk Empty Container Program

The establishment has in place an effective cleaning system.

The establishment has an effective system in place to prevent the use of damaged or defective containers. This can be accomplished by ensuring that:

• Empty containers are visually or electronically examined to identify, remove and segregate defective containers during depalletizing or on-line
• There is a back-up system in place in case the electronic inspection system fails
• The establishment has controls in place to prevent contamination of clean containers. For example:

  - No containers and lids are left on the line at breaks, during clean-up or extended downtime unless adequate measures are in place to prevent contamination.
  - Containers are used only for their intended purpose.

Deficiencies in the container handling control program which may result in use of seriously damaged containers.

Containers are not used for their intended purpose.

The container handling damage control or visual monitoring program is absent or deficient such that defective containers may be used.

Containers being used with evidence of contamination.

Appendix 2 - Bulk Empty Container Program.

• Colour
• Moisture
• Absence of Foreign Material
• Characteristic Flavour
• Floral Source (if declared)
• Lot numbers
• Country of Origin

The establishment has signed verifications of all batch/lot evaluations

The owner or operator of each registered establishment shall keep and make available to the CFIA at all times, an accurate, up-to-date record of his honey pack that shows:

• The quantity of honey pooled or purchased and the persons from whom it was received or purchased.

Evaluations performed but no signed verification.

Incomplete/inaccurate evaluations of each batch.

The establishment has controls in place to prevent contamination of clean containers and product, for example:

• Filled containers without lids are not left on the line at breaks, during clean-up or extended downtime unless adequate measures are in place to prevent contamination.

The establishment does not have adequate controls in place to prevent hazards associated with product filling (glass).

The damaged container control or visual monitoring program is absent or deficient such that defective containers may be used.

The establishment does not have adequate controls in place to prevent hazards associated with product filling.

• Protecting the cap/lid hopper from contamination
• Adjusting closing equipment to avoid damage to containers
• Adequate container closure.

Inadequate container closure.

Typical controls should be:

• Container size for product to be sold in Canada.
• Effective separation of products during changeovers with records.
• At the labeler different product labels are effectively separated and the number of product label types are kept to a minimum.
• Tops and bottoms of label bundles are visually checked for mixed labels prior to use.
• Prevention of mixing of individual or bundles of labels during storage e.g. storage in separate boxes, no loose labels, and ensuring that unused labels are returned to the correct boxes.
• Effective weight control system to ensure proper filling at the declared weight.
• Effective grading system to ensure correct grade evaluations.

No effective weight verification system in place.

No effective grade evaluation system in place.

1. Medications used have been approved for use for treating bees.

2. The recommended preparation and dosage level of the medications have been followed.

3. The withdrawal time for the medication has been followed before the honey is harvested.

4. Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control.)

1. Cleaning, handling, storing and using of bulk containers received.