Improved Food Inspection Model
Revised Draft

4.0 Overview of inspection

• Introduction
• 4.1 Inspection work planning and priorities
• 4.2 Inspection procedures

Introduction

The purpose of the CFIA’s inspection is to assess whether a licence holder has developed, documented, implemented and maintained written preventive control measures, whether these measures are effective, and whether regulatory requirements and licence conditions have been met.

Inspection activities related to a preventive control plan would be organized by the seven elements of the preventive control plan. Inspectors would use a combination of traditional inspection where the focus is on the end-product and processing environment and audit techniques (such as record review, interviews, and observation) for assessing compliance and evaluating the impact of non-compliance.

4.1 Inspection work planning and priorities

The CFIA’s inspection activities are determined from a national work plan. As a government agency, the CFIA is accountable to the public for showing how it allocates its resources. In terms of CFIA’s inspection activities, this is accomplished through the work planning process.

Work plans indicate the number of inspectors the CFIA has and the amount and type of inspection activities they will perform each fiscal year. The various CFIA District Offices across Canada use the national work plan as a basis of their individual office work plans.

4.1.1 National work plan

As the national work plan is developed, inspection priorities would be based on risk and compliance data and could consider

• inspection and surveillance data
• environmental scanning
• recalls and illness investigations

There are a number of triggers that could initiate an inspection that is not part of the work plan. These include

• food safety complaints or illness investigations
• results of an inspection process or sampling
• information about a potential issue received from
  • a third party
  • another government department
  • an international trading partner
• a request for inspection by a licence holder (for export or marketing purposes)

If the CFIA observes a trend in non-compliance, the work plan could include targeted surveillance activities. For technical incidents of non-compliance, a targeted inspection response might be developed—which could include further clarification of the requirements or policy—followed by a compliance and enforcement strategy.

4.2 Inspection procedures

Inspection procedures provide a systematic way to approach inspections. Inspection activities could include making visual observations, evaluating records, interviewing personnel, sampling and testing.

The procedures would provide inspectors with the flexibility to adapt to different situations that may arise during an inspection; the inspector would be able to assess the potential impact of non-compliance to determine whether and what further actions are required.

There are four basic steps to inspection:

Step 1: Preparing for an inspection

Preparation for an inspection would include determining a preliminary scope. Scope can be based on the national work plan but may be adjusted for a variety of reasons (for example, changes in activity, compliance history). Preparation would also include determining whether an inspection would be announced or unannounced, reviewing the applicable Acts, regulations and other reference materials, and finally, gathering all tools, equipment and supplies needed.

Step 2: Conducting an inspection

During an inspection, all findings would be recorded, including any discussions. Additional objective evidence, such as physical samples, photographs, and copies of documents or records would also be collected. The process of conducting inspections would include the following activities:

a) Opening meeting: An opening meeting would introduce all CFIA staff and outline the scope of the inspection. It would provide the licence holder with the opportunity to confirm any changes to his or her company profile and preventive control plan (since last inspection). It would also provide the CFIA with an opportunity to update the licence holder on any changes to the inspection process and/or relevant regulations.

b) Initial walk-through inspection: This part of the inspection would serve to identify areas that should also be added to the scope of the inspection or targeted for more intensive inspection.

c) Confirmation of scope: Based on recorded observations from the initial walk-through inspection, the scope would be confirmed or amended accordingly.

d) Completion of inspection: Conducting an inspection would include using traditional and audit techniques. Namely, visual inspection, record review, interviews, sampling, etc.

e) Assigning a level of non-compliance: There are three levels of non-compliance that could be used, based on the impact on food safety:

• critical : immediate impact on food safety or repeated serious non-compliance
• serious : potential impact on food safety
• technical : non-compliance with regulatory requirements that are not related to food safety

If serious or critical non-compliance were detected, a corrective action request would be issued, indicating which regulatory requirement(s) had not been met. Technical non-compliances would be recorded and corrected by the licence holder, but a corrective action request would not need to be issued.

f) Completion of inspection report: The inspection report would include the inspection findings, corrective action requests issued, technical non-compliance observed and actions taken.

Step 3: Communicating the inspection results

A closing meeting would be held with the licence holder to discuss the outcomes of the inspection, including any incidents of non-compliance and next steps. The inspection report would also be shared once completed.

Step 4: Conducting a follow-up inspection:

A follow-up inspection would be conducted to confirm that the corrective action has been completed and is effective, and that any changes in the preventive control plan are documented.

For additional information on the basic inspection steps and a draft template of an inspection report, see Annex C.1.

For details on inspection activities in relation to the elements of the preventive control plan, see Annex B.

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