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Improved Food Inspection Model
Final Model

Annex C: Basic inspection steps

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Details of basic inspection steps for inspectors

The following outlines the basic inspection steps that may be used by CFIA inspectors. It provides a consistent approach to performing inspections under the improved food inspection model.

Step 1: Prepare for the inspection

a. Determine preliminary scope of inspection.

Once a facility has been identified for inspection, based on the work plan and priorities, the scope of the inspection may be adjusted in response to:

Over time, the regulated party's entire system should be inspected to verify compliance with all food safety and other regulatory requirements.

b. Determine whether the inspection will be announced or unannounced.

Inspections may be announced or unannounced, at the inspector's discretion. Both approaches will be used.

c. Review the applicable Acts and regulations and other reference documents.

d. Gather inspection documents and tools, sampling equipment, protective wear, safety equipment and applicable supplies.

Step 2: Conducting the inspection

During the inspection, record all findings, including any discussions. Additional objective evidence, such as physical samples, photographsFootnote 16 and copies of documents may also be gathered.

a. Opening meeting

b. Initial walk-through inspection

This part of the inspection serves to identify areas that should be added to the scope of the inspection or targeted for more intensive inspection. It can also confirm the accuracy of the profile.

When outside the facility observe the general cleanliness of the surrounding area and any conditions that could contribute to food contamination.

Consider:

When inside the facility, begin at the finished product area and progress towards incoming product and ingredients areas. Observe the general cleanliness and any conditions that could contribute to food contamination.

Consider:

Document all observations. Make note of any questions to ask personnel that arise during the inspection or records that should be reviewed to help confirm observations.

c. Confirm the scope of inspection

Based on recorded observations from the walk-through, consider whether the scope of the inspection should be adjusted.

d. Complete the inspection

Review records

Review the preventive control plan and records for the elements that fall within the scope of the inspection. The number of records selected reflects performance over time. Focus on records for food commodities that will be prepared during the inspection so that employee actions can be observed and on-site interviews can be conducted.

Address the following for each element examined:

Review monitoring records to determine if:

Review verification records to determine if:

If there are repeated deficiencies, determine if the regulated party has implemented additional measures or made changes to the preventive control plan.

Any records supporting the preventive control plan can be checked during an inspection (for example, training records, consumer complaints). Be clear in describing the types of records to which access is required.

Use judgement to decide whether it is necessary to take samples of the food commodity or swabs of the equipment and environment to verify inspection observations and to help determine whether the regulated party is compliant. Send any samples collected to the appropriateCFIA laboratory for analysis.

Observe activities and conduct interviews

Use judgement to decide what to do first: observe operations or conduct interviews. There is no prescribed order to using these techniques–the objective is to collect the most accurate information possible.

During observations, confirm that the employees are following the preventive control plan procedures. Interview employees to gather further information to support the observations. Use open-ended questions such as:

If compliance is achieved with regulatory requirements, go to section f. Inspection report. If non-compliance is identified, the level must be assessed.

e. Assign a level of non-compliance

Assign a level of non-compliance to each element, based on its potential impact on food safety.

There are three levels of non-complianceFootnote 17:

Any other observations that do not have an impact on food safety or regulatory requirements may be noted in the report as "opportunities for improvement".

If any serious or critical non-compliance is detected, issue a corrective action request that indicates which regulatory requirement(s) have not been met. Record technical non-compliance. Though these must be corrected, a corrective action request need not be issued. All non-compliance, including technical, must be corrected by the regulated party.

Where critical food safety issues are observed, take the following steps:

f. Inspection report

The inspection report includes the inspection findings, corrective action requests issued, technical non-compliance observed and actions taken.

Documentation of the records reviewed includes the following:

Documentation of observations and interviews includes the following:

Record all incidents of non-compliance in the final inspection report. The nature of the non-compliance must be described in clear, factual and concise terms.

Step 3: Communicate the inspection results

Hold closing meeting with the regulated party to discuss the outcomes of the inspection, including any incidents of non-compliance and next steps. Share the written inspection report, once completed.

At the closing meeting:

Step 4: Conduct a follow-up inspection

A follow-up inspection may be needed to confirm that the corrective action has been completed, is effective, and that any changes to the preventive control plan are documented. An extension of the deadline for completing corrective actions may be granted in certain circumstances, including the following:

When reviewing corrective actions:

If the corrective actions have been implemented effectively, close the corrective action request.

If the corrective actions have not been implemented effectively and an extension is not granted, take the appropriate compliance and enforcement action.

a. Continued or repeated non-compliance

The following table shows guidelines for compliance and enforcement action in the case of continued or recurring incidents of non-compliance.
Continued or repeated non-compliance The inspector The regulated party is required to
For a critical non-compliance Initiates enforcement action (for example, suspension of licence) Take immediate action to address the non-compliance, and control the affected food commodity, if necessary
For a serious non-compliance Elevates to a critical corrective action request Control the affected food commodity immediately and address the non-compliance to prevent recurrence
For a technical non-compliance Initiates corrective action and appropriate enforcement (for example, AMPs, product seizure and detention) Correct the affected food commodity
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