A Draft Guide for Preparing a Preventive Control Plan – For Importers

Disclaimer

The information in this draft guide is based on requirements set out in the proposed Safe Food for Canadians Regulations (SFCR). It is important to note that the SFCR is not applicable at this time. The information is intended to help regulated parties understand the requirements they would need to comply with once the SFCR comes into force. The proposed requirements are subject to change as the regulatory process advances through its various stages. In the interim, current laws applicable to your food and business continue to apply.

Table of Contents

  1. 1.0 Introduction
  2. 2.0 What this document contains
  3. 3.0 Developing your written Preventive Control Plan
    1. 3.1 Step 1 – Getting Started
      1. 3.1.1 Are you knowledgeable about the food that you are importing?
      2. 3.1.2 Have you chosen an appropriate foreign supplier?
      3. 3.1.3 Do you have all the information you need to complete your written PCP?
    2. 3.2 Step 2 – Developing and completing your written PCP
    3. 3.3 Step 3 – Putting your written PCP into action
      1. 3.3.1 Implementation
      2. 3.3.2 Maintenance
      3. 3.3.3 Verification
  4. 4.0 PCP Self-Assessment Checklist
  5. 5.0 PCP Draft Templates
    1. 5.1 Template (1A) Preventive Control Measures – Template for Importers
    2. 5.2 Template (1B) Content of a Preventive Control Plan for Importers – Description of hazards, control measures, critical control points and critical limits
    3. 5.3 Template (2) Content of a Preventive Control Plan for importers – Market Fairness
  6. 6.0 Annexes
    1. 6.1 Annex I – Questions and Answers
    2. 6.2 Annex II – Draft example templates
      1. 6.2.1 Template (1A) Preventive Control Measures – Template for Importers
      2. 6.2.2 Template (1B) Content of a Preventive Control Plan for Importers – Description of hazards, control measures, critical control points and critical limits

1.0 Introduction

This guide is intended for importers that would be required to have a preventive control plan (PCP) under the proposed Safe Food for Canadians Regulations (SFCR). A preventive control plan is a written plan outlining how you ensure that the food you import is safe and fit for consumption and that it meets applicable regulatory requirements (safety, grading, standards, labelling, packaging, net quantity).

A written PCP is also used to demonstrate how hazards that present risks to food products are eliminated or are being effectively controlled. Preventive controls are an internationally accepted approach to prevent or mitigate hazards associated with food products. They are based on the CODEX Alimentarius General Principles of Food Hygiene PDF (176 kb). PCP details may vary depending on the risk(s) associated to the product you are importing. The focus of an importer written PCP is on:

  1. the conditions in which the food is prepared and handled before it arrives in Canada; and
  2. the requirements of your import operation in Canada.

Upon the coming into force of the SFCR, it will be your responsibility as an importer, whether or not you are required to have a written PCP, to ensure that the food you import was manufactured, prepared, stored, packaged and labelled in the foreign country under conditions that provide at least the same level of protection as that provided under the SFCR – and that you meet requirements relating to how you conduct your import operation. Please use the Would you need a Preventive Control Plan tool to determine if you would require a written PCP for the food you import based on the proposed SFCR.

Please refer to Annex I – Questions & Answers (Q&A's) for additional information that can be useful to you in developing your written preventive control plan, as well as information to keep in mind for you as an importer.

Keep in mind

  • It is possible that an importer may rely on a third party such as an accredited body for the information and documentation required to ensure that the imported food has at least the same level of protection as that provided by the applicable preventive control requirements, and not on the foreign supplier directly. When the term "foreign supplier" is used in this guide, it could also refer to the third party you are relying on for such information.
  • In addition to the proposed requirement for a written preventive control plan, there are other requirements for importers in the proposed SFCR. These cover areas such as licencing, traceability, etc.
  • As a holder of a licence to import under the proposed SFCR, you would also be required to have procedures in place for investigation, complaints and recall, along with relevant documentation. You would also need to ensure that your foreign supplier has similar procedures in place that provide at least the same level of protection. This would be the case even if you are not required to have a written PCP. Additional information regarding investigation, complaints and recall can be found in Q7.
  • If you have other activities for which you need a licence (for example, packaging and labelling for interprovincial trade or export), you would need to have a written PCP in relation to those activities. If so, refer to the domestic A Draft Step-by-Step Guide for Domestic Food Businesses and Exporters – Preparing a Preventive Control Plan for additional information.

2.0 What this document contains

This document contains a self-assessment checklist and draft PCP templates based on the current proposed SFCR, which can be used to help you determine whether you would comply with the SFCR once it comes into force. The self-assessment checklist can be used to identify the key preventive control components of your written PCP that need to be addressed in your plan. Since you, as an importer, are reliant upon your foreign supplier's ability to provide much of the information to complete this self-assessment checklist, it may also serve useful in selecting an appropriate foreign supplier(s).

Careful consideration should be given to each element within the draft templates that applies to the food being imported and how you will assure yourself that the elements applicable to the food you import are effectively applied by you and your foreign supplier, where applicable.

Under the proposed SFCR requirements, your written PCP would be completed prior to obtaining a licence from the CFIA to import food. Once your written PCP is complete and you have obtained your licence to import, your written PCP will need to be reviewed and, if necessary, updated to reflect any changes to your foreign suppliers and/or to the foods you import.

It's your choice

You may use preventive control plan approaches that have been developed by the CFIA, yourself or other food safety authorities, industry associations, international partners, or academia. Always ensure that the information in your written preventive control plan is tailored for your particular business, foods, and market requirements. You are responsible for ensuring that your written preventive control plan meets the requirements of the Safe Food for Canadians Regulations once they come into force.

3.0 Developing your written preventive control plan

3.1 Step 1 – Getting Started

Based on the proposed SFCR, there are several important factors you should consider before completing your written PCP.

3.1.1 Are you knowledgeable about the food that you are importing?

Importing safe food starts with having a good understanding of the food you import. You are encouraged to work with your foreign supplier to ensure:

  • you can describe the food you import (e.g. the type of food, its common name, the quantity you intend to import, the packaging of the food);
  • you know and can describe the hazards associated with the food you are importing and how these hazards are being addressed;
  • you can demonstrate that the food is manufactured, prepared, stored, packaged and labelled under conditions that provide at least the same level of protection as provided in the SFCR.

Having a good understanding of the food you import will provide you with a strong foundation for developing your written PCP and provide you with confidence that your import process is effective at importing safe food that meets Canadian requirements.

3.1.2 Have you chosen an appropriate foreign supplier?

A professional relationship with your foreign supplier and confidence in the safety and quality of the food they supply are key elements to a successful PCP. It is important that your foreign supplier is aware of Canadian requirements and that they are willing and able to provide the information you need to comply with the proposed SFCR requirements applicable to importers. You will need to know the foreign supplier's name and address as well as information about the conditions under which the food is manufactured, prepared, stored, packaged and labelled.

Note: There are additional requirements on foreign suppliers for imported meat and shellfish.

3.1.3 Do you have all the information you need to complete your written PCP?

The draft PCP templates – for importers can aid you in the development of your written PCP. To help ensure you have the information you need, it is recommended that you complete the PCP Self-Assessment Checklist first. This self-assessment checklist provides a list of the preventive control measure elements in the proposed SFCR that may need to be addressed in your written PCP to ensure that your foreign supplier has at least the same level of preventive control protection. It will help you identify the key components of your written PCP and any gaps that need to be addressed before completing it. It is recommended that you work closely with your foreign supplier to complete the self-assessment checklist. This way, you can determine early on whether the foreign supplier is capable of providing you with the evidence and information you would need to meet your preventive control measure obligations as a food importer once the SFCR come into force.

In addition to preventive control measures, your written preventive control plan would also need to describe the measures taken to ensure that any applicable requirements related to grading, standards, labelling, packaging and net quantity and the food commodity in general are met (as set out in section 87(1)(a), (b) and (c)). Refer to Template (2) Content of a Preventive Control Plan for importers – Market Fairness.

3.2 Step 2: Developing and completing your written PCP

Once you are confident that you have all the required information, you can begin developing your written PCP. It is recommended that you work closely with your foreign supplier to obtain the information you need to ensure that all applicable preventive controls and other applicable measures are in place and that the measures are being effectively implemented. This information does not necessarily need to be detailed technical process documents. It could consist of other document types that demonstrate that an applicable measure has been evaluated by a competent oversight body and is found to be effectively implemented by the foreign supplier. Examples include procedures, records, communications, attestations, evidence of system recognition for imported meat or shellfish, etc.

The CFIA has developed Draft PCP templates for importers that help illustrate the information to be included in your written preventive control plan, and how it could be assembled. In completing templates like this and assembling the supporting documentation for each applicable element – you would have the major elements of your written PCP completed.

3.3 Step 3: Putting your written PCP into action

Once the SFCR comes into force, you are responsible for implementing your written PCP, maintaining it, and verifying that it is working properly.

3.3.1 Implementation

Considerations for effective implementation of a written PCP:

  • There is always at least one person in your food operation who understands the contents of the written PCP and ensures it is being implemented effectively.
  • The PCP is being followed as written.
  • You have documentation from your foreign supplier and are generating documentation yourself to demonstrate that the written PCP is being implemented properly.

3.3.2 Maintenance

Your written PCP should be viewed as a living document – one that is reviewed regularly and, if necessary, revised as your import operation grows and changes. The requirement to maintain your PCP means that you need to ensure it is up to date at all times. Ask yourself:

  • Does my written PCP reflect my current import operations?
  • Are all the foreign suppliers from which I currently source food from captured in my written PCP?
  • Does my written PCP cover all of the food I import?
  • Am I confident that the evidence and information provided by my foreign supplier is still current – or do I need to ask my foreign supplier to provide me with updated documentation?
  • Have there been any changes to my import operation that aren't captured in my written PCP but should be?

3.3.3 Verification

Your written PCP must be complete and effective. To verify this, ask yourself:

  • Is my import process working? Does it result in the import of safe food that meets Canadian requirements?
  • Have there been issues with my foreign supplier or with any of the food I import that would indicate I need to revisit parts of my written PCP to make sure it is working properly?

4.0 PCP Self-Assessment Checklist for Importers

Disclaimer:

This self-assessment checklist is a brief summary of some of the elements of the preventive control requirements (sections 44 to 82) based on the proposed Safe Food for Canadians Regulations (SFCR) that, if applicable to the food your import, would need to be addressed in your written PCP. It is not a substitute for the actual regulatory requirements that must be met once the SFCR comes into force.

The PCP self-assessment checklist is a resource that can be used to identify the key components of your written PCP, as may be applicable to the food you import and your operations.

The content of the self-assessment checklist briefly summarizes some of the elements of the regulatory requirements of sections 44 to 82 of the proposed SFCR. The subsequent Draft PCP templates for importers contain more detailed text in reference to the proposed regulatory requirements that would be required for your written PCP when the SFCR comes into force.

Preventive Control Plan – Self-Assessment Checklist

Name of foreign supplier: space

Address of foreign supplier: space

Additional foreign supplier information: space

Product information (e.g. product name, etc.): space

SFCR section number(s) Preventive Control Measure (as may be applicable to the imported food and your foreign supplier's operations) Do you have written details OR written evidence demonstrating that this preventive control is being adequately addressed?
Determination and Control of Hazards of the Imported Food
44, 45, 46 The biological, chemical and physical hazards are identified AND the food is treated or processed to eliminate any such hazards that present a risk of contamination. Box Yes
Box No
Box Not applicable
Sanitation and Pest Control at the Foreign Supplier's Establishment
48 The establishment, conveyances, and equipment used are clean and in sanitary condition, and the cleaning and sanitation is conducted in a manner that does not present a risk of contaminating the food. Box Yes
Box No
Box Not applicable
49 The establishment is protected against the entry of animals that could contaminate the food (e.g. insects and rodents) and such measures do not present a risk of contamination of the food. Box Yes
Box No
Box Not applicable
50 Non-food chemicals agents (sanitizers, etc.) are labelled, suitable, and used in a way that does not pose a risk of contamination of the food. Box Yes
Box No
Box Not applicable
Conveyance and Equipment at the Foreign Supplier's Establishment
51 Conveyances and equipment are appropriate for the food and activity being conducted and are designed, constructed, and maintained to function as intended and prevent contamination of the food. Box Yes
Box No
Box Not applicable
52 Separate conveyances or equipment are used strictly for handling contaminated material, waste or any other inedible substances and identified accordingly. Box Yes
Box No
Box Not applicable
53 There is restraining equipment for animals being examined and inspected for slaughter. Box Yes
Box No
Box Not applicable
Foreign Supplier's Establishment
54 The area around the establishment does not pose a risk of contamination of the food (e.g., pollution, garbage, rodents, insects). Box Yes
Box No
Box Not applicable
55 The interior of the facility or conveyance is designed, constructed and maintained to prevent the food from being contaminated. Box Yes
Box No
Box Not applicable
56 An establishment where food animals are slaughtered must have:
  • separate areas for activities set out in section 56(1)(a) to (d);
  • an enclosed area where inedible meat products are handled;
  • secure footing for food animals during movement; and
  • inspection stations for conducting ante-mortem and post-mortem examinations
Box Yes
Box No
Box Not applicable
57, 58, 59 The facility or conveyance is designed, constructed and maintained so that the movement of people and things within, into and out of the facility or conveyance are controlled and do not present a risk of contamination of the food. Physical or other effective means are used to separate incompatible activities or anything that does not meet the requirements of the SFCA and SFCR, in order to prevent contamination of a food. Box Yes
Box No
Box Not applicable
60 Food that presents a health risk, that is exempt from the Act and Regulations under section 21 and/or does not meet the SFCA and SFCR is labelled and kept in a designated area to prevent contamination of any other food. Box Yes
Box No
Box Not applicable
61 Lighting is sufficient, can be cleaned and food is protected from lighting breakage. Box Yes
Box No
Box Not applicable
62 Ventilation is sufficient and can be maintained and cleaned to prevent unclean air from affecting the food. Box Yes
Box No
Box Not applicable
63 Temperature and humidity are maintained as appropriate for the food and if applicable, food animals to be slaughtered are properly equipped and can be cleaned. Box Yes
Box No
Box Not applicable
64 Contaminated material and waste, including sewage, are removed in a way and at a frequency that does not pose a risk of contamination of the food. Box Yes
Box No
Box Not applicable
65 Hand cleaning stations and washrooms are sufficient to meet the needs of the establishment and are cleaned and maintained. Box Yes
Box No
Box Not applicable
66 An area is provided for inspectors conducting oversight/verification activities related to the food (e.g., government food inspection services). Box Yes
Box No
Box Not applicable
67 Appropriate accommodation and equipment is provided in the establishment to inspectors of imported meat products, processed egg products and food animals. Box Yes
Box No
Box Not applicable
68, 69 Water, ice, or steam that comes in contact with a food does not pose a risk of contamination of the food and its supply is adequate for the activity being conducted. Box Yes
Box No
Box Not applicable
Unloading, Loading and Storing at the Foreign Supplier's Establishment
70 Conveyances used to transport food to or from the establishment are designed, constructed, and maintained to prevent contamination of the food. The conveyances are in good condition, temperature/humidity controlled as appropriate for the food, and used in a manner to prevent contamination of the food. Box Yes
Box No
Box Not applicable
71, 72 Unloading, loading, and storage of a food, food animals, and non-food (e.g., cleaning agents, packaging materials, sanitizers, equipment) are done in a way that does not present a risk of contamination of a food. Box Yes
Box No
Box Not applicable
Competency of Employees at the Foreign Supplier's Establishment
73 Employees are competent and qualified to carry out their duties. Box Yes
Box No
Box Not applicable
Hygiene at the Foreign Supplier's Establishment
74-78 Everyone in an area where food is manufactured, prepared, stored, packaged, or labelled follows hygienic practices as per sections 74 to 78. Box Yes
Box No
Box Not applicable
Communicable Diseases Control at the Foreign Supplier's Establishment
79 Anyone suffering from a communicable disease or open infected lesion is prevented from being in an area where the person's condition presents a risk of contamination of the food. Box Yes
Box No
Box Not applicable
Investigation and Notification, Complaints and Recall
80 There are procedures in place for investigation and they are implemented. Box Yes
Box No
81 There are procedures in place for complaints and they are implemented. Box Yes
Box No
82 There are procedures in place for recall and a recall simulation and they are implemented. Box Yes
Box No

Preventive Control Plan – Draft templates for importers

Disclaimer

These templates are provided in draft form to support the consultation on the proposed Safe Food for Canadians Regulations (SFCR). They are intended to help regulated parties understand the proposed SFCR requirement for written preventive control plans. These draft templates constitute a work in progress and are subject to change and refinement as the regulatory process on the SFCR advances through its various stages towards implementation.

The draft preventive control plan (PCP) templates provided below are documents you can use to help develop your written PCP. We recommend that careful consideration be given to each element within the templates that applies to the food being imported and how you will assure yourself that the elements applicable to the food you import are being effectively applied by you and your foreign supplier, where applicable.

Note: To satisfy the proposed PCP requirements, you will need more than just "yes/no" answers; you will need supporting documents, in many cases obtained from your foreign supplier, evidencing that each of the applicable elements is being effectively implemented. This documentation does not necessarily need to be detailed technical process documents. It could consist of documents (e.g. written documentation, procedures, records, communications, attestations, evidence of system recognition for imported meat or shellfish, evaluation by a competent oversight body) that describe or explain the applicable measures taken to meet the regulatory requirement and confirm that the requirement has been effectively implemented. Refer to Annex II for examples of completed draft PCP Templates which also contain examples of what these supporting documents could be.

Once you are confident that you have all the required information, you can begin developing your written PCP.

It's your choice – you can choose to use templates provided by the CFIA or you may use preventive control approaches that have been developed by other food safety authorities, industry associations, international partners, academia, or yourself. Always ensure that the information in your written preventive control plan is tailored for your particular business, foods, and market requirements; PCP details may vary depending on the risk associated to the product you are importing.

5.0 Draft PCP Templates

Template (1A) Preventive Control Measures – Template for Importers generally describes the preventive controls that would need to be in place in the foreign country, as applicable to the food you import, to ensure at least the same level of preventive control protection as that provided under the SFCR and the type of supporting evidence you have that these control measures are being implemented.

Template (1B) Content of a Preventive Control Plan for Importers – Description of hazards, control measures, critical control points and critical limits is used to help to identify and describe the preventive control requirements relating to hazards, control measures, critical control points and critical limits that may be applicable to the food you import in relation to the applicable provisions set out in 87(1)(c), as per section 87(2).

Template (2) Content of a Preventive Control Plan for Importers –  Market Fairness describe the requirements that, depending on the food you import, may apply in relation to grading, standards, labelling, packaging and net quantity, as set out in section 87(1)(a), (b) and (c).

5.1 Template (1A) Preventive Control Measures – Template for Importers

Name of foreign supplier: space

Address of foreign supplier: space

Additional foreign supplier information: space

Product information (e.g. product name, etc.): space

SFCR section number Preventive Control Measure (as may be applicable to the imported food and your foreign supplier's operations) Evidence that this preventive control measure is being implemented effectively Frequency that evidence is verified Date last verified
Determination and Control of Hazards of the Imported Food
44 Biological, chemical and physical hazards that may present a risk of contamination of a food are identified and you are assured that these hazards have been prevented or eliminated control measures shown by evidence obtained from your foreign supplier to be effective, (see template 1B for further information).
45, 46 The food is subjected to a process or treatment necessary to eliminate any biological, chemical or physical hazard that might be present and that presents a risk of contamination to the food (as set out in sections 45 and 46)
Sanitation and Pest Control at the Foreign Supplier's Establishment
48 The establishment, equipment and conveyances are clean and in a sanitary condition, and the cleaning and sanitation is conducted in a manner that does not present a risk of contamination of the food.
49 The establishment is protected against the entry of animals that could contaminate the food (e.g. insects and rodents), non-essential animals are barred entry into the facility or conveyance and measures taken in this regard do not present a risk of contamination of the food.
50 Non-food chemicals (sanitizers, etc.) are properly and clearly identified, are suitable for its intended use, do not present a risk of contamination of a food, and are handled and used in a way that does not pose a risk of contamination of the food.
Conveyances and Equipment at the Foreign Supplier's Establishment
51 Conveyances and equipment must be appropriate for the food and activity being conducted and meet the requirements of paragraphs 51(b) to (i).
52 Separate conveyances or equipment are used for handling contaminated material, waste or any other inedible substances, be identified as reserved for that purpose and meet the applicable requirements of section 51.
53 There is restraining equipment for food animals being examined and inspected for slaughter.
Supplier's Establishment
54 Unless measures are taken to eliminate the risk, the land forming part of the establishment must not present a risk of contamination of a food and the establishment must not be located near any place or thing (e.g., pollution, garbage, rodents, insects) that presents a risk of contamination of a food.
55 The interior of the facility or conveyance is of sanitary design to prevent the accumulation of contaminants (e.g., dust, dirt, micro-organisms, food products) and to permit effective maintenance, cleaning and sanitizing. They must also be designed and constructed in accordance with paragraphs 55(b) to (d).
56 An establishment where food animals are slaughtered must have:
  • separate areas for activities set out in section 56(1)(a) to (d);
  • an enclosed area where inedible meat products are handled;
  • secure footing for food animals during movement; and
  • stations for conducting post-mortem examinations.
57 The facility or conveyance must be designed, controlled and maintained in a manner so that the movement of people and things are controlled and the movement does not present a risk of contamination of the food.
58, 59 Incompatible activities and anything that presents a risk of contamination of a food, as well as any food that does not meet the requirements of the Safe Food for Canadians Act or its Regulations and any non-food item that is manufactured, prepared, stored, packaged or labelled in the establishment, must be separated by physical or other effective means.
60 Upon arrival at an establishment, food that presents a risk of injury to human health, or has been returned after export, or does not meet the requirements of the Safe Food for Canadians Act or its Regulations, is identified as such and kept in a designated area within the establishment. Any other measures necessary to prevent contamination of any other food in the establishment must be taken.
61 Lighting is appropriate for the food (or food animals) and activity being conducted, can be repeatedly cleaned (and, if applicable, sanitized) and not present a risk of contamination of the food in the event of breakage.
62 The facility or conveyance is equipped with a ventilation system that:
  • functions as intended;
  • provides sufficient air exchange to provide clean air and to remove unclean air and odours that might affect the food;
  • is accessible;
  • can be maintained and is capable of withstanding repeated cleaning; and
  • if necessary, is able to be disassembled for cleaning, maintenance and inspection.
63 Temperature and humidity in a facility or conveyance are maintained at levels appropriate for the food (or food animals to be slaughtered) and the activity being conducted. Any heating, cooling or humidity-control system must:
  • function as intended;
  • be equipped with necessary instruments that control, indicate and, if required, record the temperature and humidity levels;
  • be accessible;
  • be capable of withstanding repeated cleaning; and
  • if necessary, be able to be disassembled for cleaning, maintenance and inspection.
64 The establishment is equipped with means to remove and dispose of contaminated materials and waste, including a drainage, sewage and plumbing system capable of withstanding repeated cleaning and that functions as intended. Contaminated materials and waste must be removed and disposed of at sufficient frequency to prevent contamination of a food and in a way that does not present a risk of contamination of the food.
65 There are hand cleaning and sanitizing stations, drinking water stations, break rooms, change rooms and washrooms (including lavatories and showers) in the establishment as necessary to meet the needs of the establishment. They must:
  • be appropriately equipped and appropriate in number and size for the number of persons using them;
  • be located in the establishment and reasonably accessible to the persons using them;
  • be capable of withstanding repeated cleaning and, if applicable, sanitizing;
  • for the hand cleaning and sanitizing stations, supply water at a temperature and pressure for effective cleaning of hands; and
  • for the lavatories, not provide direct access to any area where a food is manufactured, prepared, stored, packaged or labelled or where food animals are slaughtered.
66 An appropriately sized area that is readily accessible and properly equipped is provided for CFIA inspectors conducting oversight/verification activities related to the food upon their request.
67 Appropriate accommodation and equipment as described in section 67 is provided in the establishment to inspectors of imported meat products, processed egg products and food animals.
68 Water, ice or steam that comes in contact with a food, any system that supplies water and any water given to food animals to be slaughtered, must meet the requirements of section 68.
69 As appropriate for the food, the activity conducted and for food animals slaughtered, the establishment must be supplied with:
  • water adequate in quantity, temperature, pH and pressure to meet the needs of the establishment;
  • steam and ice that is adequate in quantity and steam that is adequate in pressure to meet those needs.

The above must be applied in a manner that does not present a risk of contamination.

Unloading, Loading and Storing at the Foreign Supplier's Establishment
70 Conveyances used to convey food to or from the establishment and that are unloaded or loaded at the establishment must be:
  • designed, constructed, and maintained to prevent contamination of the food
  • constructed of, and maintained using materials that are suitable, for their intended use and, if the materials present a risk of contamination, that are durable, capable of withstanding repeated cleaning and, if applicable sanitizing, and free of any noxious constituent
  • capable of maintaining the temperature and humidity at levels that are appropriate for that food and, if necessary, be equipped with instruments that control, indicate and record those levels
  • of sound construction and in good repair
  • clean and in sanitary condition at the time of unloading or loading.

In addition, the conveyance must not contain or have contained animals, pest control products or any other material or substance that represents of a risk of contamination of the food.

71 Unloading and loading of a food and food animals for slaughter from or onto a conveyance must be conducted in a manner that does not present a risk of contamination of a food.
72 Storage of a food, and of non-food items used in the manufacture, preparation, storage, packaging or labelling of a food (e.g., cleaning agents, packaging materials, sanitizers, equipment, starter products [as defined in s. 72(3)]), are conducted in a way that does not present a risk of contamination of a food.
Competency of Employees at the Foreign Supplier's Establishment
73 Employees and others involved in the manufacturing, preparing, storing, packaging or labelling of a food, or in the slaughter of food animals, are competent and qualified to carry out their duties.
Hygiene at the Foreign Supplier's Establishment
74-78 Everyone in an area where food is manufactured, prepared, stored, packaged, or labelled, or where food animals are slaughtered, follows hygienic practices as set out in sections 74-78.
Communicable Diseases Control at the Foreign Supplier's Establishment
79 Anyone suffering from a communicable disease or open infected lesion is prevented from being in an area of the establishment where a food is manufactured, prepared, stored, packaged, or labelled, or where food animals are slaughtered, if the condition presents a risk of contamination of the food.
Investigation and Notification, Complaints and Recall
80 There are procedures in place for investigation and they are implemented.
81 There are procedures in place for complaints and they are implemented.
82 There are procedures in place for recall and a recall simulation and they are implemented.

5.2 Template (1B) Content of Preventive Control Plan for importers – Description of hazards, control measures, critical control points and critical limits

The preventive control plan must include the preventive controls outlined in template 1A that could be used by your foreign supplier as a measure to prevent or eliminate an identified biological, chemical or physical hazard that presents a risk of contamination of an imported food. In such case, the PCP would describe the elements set out in the template below in relation to how the imported food provides at least the same level of protection required under section 9 with respect to the applicable requirements of sections 44-82. As an importer, it is important that you are aware of the hazards associated with the food you are importing.

Name of foreign supplier: space

Address of foreign supplier: space

Additional foreign supplier information: space

Product information (e.g. product name, etc.): space

SFCR section number Principle
(in relation to the applicable requirements of sections 45-79)
Describe how this principle is being implemented effectively through actions taken by you, your foreign supplier or other means. Frequency that this is verified Date last verified
87(1)(c)(i) Describe all biological, chemical and physical (BCP) hazards that have been identified under section 44 as presenting a risk of contamination of the food to be imported
87(1)(c)(i) Describe the control measures used to prevent or eliminate the BCP hazards and that there is evidence that such measures are effective
87(1)(c)(ii) Describe any applicable critical control points and related control measures
87(1)(c)(ii) Ensure you have evidence showing that related control measures are effective at each critical control point
87(1)(c)(iii) Describe the critical limits for each critical control point
87(1)(c)(iv) Ensure there are procedures for monitoring the critical control points in relation to their critical limits
87(1)(c)(v) Ensure there are corrective action procedures for each critical control point
87(1)(c)(vi) Ensure there are procedures to verify the preventive control plan complies with the Act and applicable Regulations
87(1)(c)(vii) You have documents that substantiate that the preventive control plan has been implemented as per above steps

5.3 Template (2) Content of a Preventive Control Plan for Importers – Market Fairness

In addition to what is listed in templates 1A and 1B, your preventive control plan would need to describe the measures taken to ensure that any applicable requirements related to grading, standards, labelling, packaging and net quantity and the food commodity in general, as set out in section 87(1)(a), (b) and (c) are met.

Where such measures are taken by a foreign supplier in respect of imported food, you would need to describe the measure in your PCP and provide assurance that the imported food met the applicable regulatory requirements. Where the applicable measures are taken by you after the import and within 3 months after the day it was imported as per section 15, then if the food will be further prepared for interprovincial trade or export, you would require a licence in respect of that activity and you would need to document the measures taken as a licence holder for that activity in your PCP. Please refer to the domestic A Draft Step-by-Step Guide for Domestic Food Businesses and Exporters – Preparing a Preventive Control Plan for additional information.

Keep in mind that in addition to the below template and as per section 87(1)(b), your PCP would need to include a description of the measures that will be taken to ensure that the food is packaged and labelled in a way that is not false, misleading or deceptive or is likely to create an erroneous impression regarding its character, quality, value, quantity, composition, merit, safety or origin or the method of its manufacture or preparation.

Name of foreign supplier: space

Address of foreign supplier: space

Additional foreign supplier information: space

Product information (e.g. product name, etc.): space

SFCR section number(s) Summary of requirement of SFCR (as may be applicable to the imported food) Does this requirement apply to the food you are importing? If yes, what evidence do you have that confirms this requirement has been met?
Standards of Identity
197 Food meeting standard
A food that is imported, whether prepackaged or not, whose label bears a common name, must meet the Canadian standard that applies in respect of that common name.
Box Yes
Box No
Labelling
203 Prepackaged food
A label that is applied or attached to a prepackaged food must bear the following information:
(a) the common name of the food, on the principal display panel;
(b) the name and principal place of business of the person by or for whom the food was manufactured, prepared, stored, packaged or labelled, on any part of the label except the part, if any, that is applied or attached to the bottom of the container of the food; and
(c) any other information that is required to be shown on the label of the prepackaged food in accordance with the requirements of the Food and Drug Regulations for prepackaged productswithin the meaning of the those Regulations.
Box Yes
Box No
206 Consumer prepackaged food – declaration of net quantity
A label that is applied or attached to a consumer prepackaged food must bear, on its principal display panel, a declaration of net quantity of the food.
Box Yes
Box No
288, 289(1) Prepackaged food
The information that a label of a prepackaged food, other than a consumer prepackaged food, is required to bear must, unless otherwise provided by this Part, be shown in at least one official language.
Consumer prepackaged food
The information that a label of a consumer prepackaged food is required by this Part to bear must be shown in both official languages in accordance with subsections B.01.012(1) to (10) of the Food and Drug Regulations, except as otherwise provided by those subsections.
Box Yes
Box No
290 General criteria for label
The information that a label is required by these Regulations to bear must be:
(a) clearly and prominently shown; and
(b) readily discernible and legible to the purchaser under the customary conditions of purchase and use.
Box Yes
Box No
Grade and labelling
301(1)(3) Mandatory grading
Subject to subsections (7) and 305(1), any egg, fish, fresh fruit or vegetable, processed fruit or vegetable product, honey, maple syrup or beef carcass in respect of which grades are prescribed by these Regulations must be graded, must meet the requirements that are set out in the Compendium or the Grades Document in respect of the applicable grade of that food and must be labelled with the applicable grade name in accordance with the Compendium or the Grades Document.
Graded foods
If a food does not require mandatory grading but there is a grade set out in the Compendium or the Grades Document in respect of the applicable grade of that food, that food must be labelled with the applicable grade name in accordance with the Compendium or the Grades Document.
Box Yes
Box No
305 Foreign state grade designation
(1) If the Compendium indicates that an imported food is to be labelled with a grade designation that is established by the foreign state of origin, the imported food must be labelled with that grade designation rather than with a grade name, and the grade designation must be shown in accordance with subsections 301(5) and (6) as if it were a grade name.
Certain foods graded by licence holder
(2) Despite subsection (1), if an imported processed fruit or vegetable product, an imported dairy product or imported fish is graded by a licence holder, it must be labelled with the applicable grade name that is set out in the Compendium for processed fruit or vegetable products, dairy products or fish that are not imported.
Maple syrup
(3) Maple syrup that is imported and that is graded and packaged in Canada may, if it is graded in an establishment that is identified in a licence, other than an establishment where maple syrup is prepared directly from maple sap, be labelled with the applicable grade name that is set out in the Compendium for maple syrup that is not imported.
Box Yes
Box No
307(a) Imported beef
Despite section 301, a beef carcass, or a complete side, hind quarter, front quarter, primal cut or sub-primal cut of a beef carcass, that is not prepackaged may be imported if it is graded and labelled in accordance with the requirements, in respect of grades of beef carcasses, that are established by the foreign state of origin.
Box Yes
Box No
Size designation and labelling
310 Prepackaged fish
Prepackaged fish must be labelled in at least one official language, in close proximity to the grade name, with the applicable class and size designation, if any, that are set out in the Compendium.
Box Yes
Box No
312 Eggs – Canada A
Eggs that are graded Canada A must be labelled with the applicable size designation that is set out in the Compendium. The size designation must be shown on the container in both official languages, in close proximity to the grade name.
Box Yes
Box No
314 Fresh fruits or vegetables – size designation
Fresh fruits or vegetables must be labelled with the applicable size designation, if any, that is set out in the Compendium. The size designation must:
(a) be shown in close proximity to the grade name;
(b) in the case of prepackaged fresh fruits or vegetables, other than consumer prepackaged fresh fruits or vegetables;
(i) if their container is a reusable plastic container, be shown in characters that are at least 1.6 mm in height; or
(ii) in any other case if their container is not a reusable plastic container, be shown in characters of at least the minimum height that is set out in the Compendium for the grade name;
(c) in the case of consumer prepackaged fresh fruits or vegetables, be shown in characters of at least the minimum height that is set out in column 3 or 4 of Schedule 5 for the area of a principal display surface that is set out in column 1 or 2 or be shown in the manner set out in the Compendium; and
(d) be shown in accordance with sections 288 and 289 of the proposed SFCR, as if it were information that the label of the food is required by Part 11 be shown on the label.
Box Yes
Box No
315 Processed fruit or vegetable products
(1) A processed fruit or vegetable product must be labelled with the applicable size designation, if any, that is set out in the Compendium. The size designation must be shown in close proximity to the grade name in characters that are at least 1.6 mm in height.
Ungraded as to size or mixed sizes
(2) Despite subsection (1), green or wax beans, peas, lima beans, asparagus tips or spears, whole white potatoes, whole carrots or cut carrots-whole style – in a hermetically sealed package – that have not been size graded or that are not all of the same size may be labelled, respectively as the case may be, with the expressions
(a) "Ungraded as to Size" and "non calibré"; or
(b) "Assorted Sizes" and "grosseurs assorties" or "Mixed Sizes" and "grosseurs mixtes".
Official languages
(3) The size designation referred to in subsection (1) and the expressions referred to in paragraphs (2)(a) and (b) must be shown in accordance with sections 288 and 289 of the proposed SFCR, as if it were information that the label of the food is required by Part 11 of the proposed SFCR, to be shown on the label of the food.
Box Yes
Box No
Colour class and labelling
318 Honey – colour class
(1) Honey must be labelled with the applicable colour class that is set out in the Compendium. The colour class must be shown on the container, in close proximity to the grade name, either in characters of at least the minimum height that is set out in column 3 or 4 of Schedule 5 for the area of a principal display surface that is set out in column 1 or 2 or in the manner set out in the Compendium.
Official languages
(2) The colour class referred to in subsection (1) must be shown in accordance with sections 288 and 289 of the proposed SFCR, as if it were information that the label of the food is required by Part 11 of the proposed SFCR, to be shown on the label of the food.
Box Yes
Box No
319 Maple syrup – colour class
Maple syrup that is graded Grade A must be labelled with the applicable colour class that is set out in the Compendium. The colour class must be shown on the container in both official languages in characters of at least the minimum height that is set out in column 3 or 4 of Schedule 5 for the area of a principal display surface that is set out in column 1 or 2.
Box Yes
Box No
321 Prepackaged cut of beef
A grade name that is applied to a prepackaged primal cut or sub-primal cut of a beef carcass must correspond to the grade of the beef carcass from which it is cut.
Box Yes
Box No
323 Livestock carcass – removal of marking
(1) A grade stamp, roller brand or yield stamp must not be removed from a livestock carcass or a primal cut of a livestock carcass unless the removal is at the direction of and under the supervision of a grader or the livestock carcass or primal cut is being trimmed for further processing.
Removal of marked fat
(2) If fat that is marked with a grade stamp, roller brand or yield stamp is removed from a livestock carcass or a primal cut, the fat must be disposed of under a grader's supervision unless the fat is:
(a) reapplied to the same livestock carcass or primal cut from which it was removed; or
(b) applied, under a grader's supervision, to another livestock carcass or primal cut that bears the same grade stamp, roller brand or yield stamp.
Box Yes
Box No
Commodity specific
104(b) Frozen fish
The holder of a licence to preserve must maintain any storage area of a conveyance where frozen fish is stored at a temperature of -18°C or less.
Box Yes
Box No
124(1)(f) Identification of edible meat products
(1) A licence holder may identify a meat product as edible only if the meat product does not contain any specified risk material.
Box Yes
Box No
125 Inedible meat products
A licence holder must not identify any of the following meat products as edible:
(a) a heart – other than the heart of a domesticated rabbit or of a bird that is not an ostrich, rhea or emu – unless it is opened or inverted and has all blood clots and attached blood vessels removed;
(b) a liver, unless the gallbladder is removed;
(c) a gizzard, unless its contents and lining are removed and the gizzard is washed;
(d) a meat product that contains a urinary bladder, an intestine or any part of a urinary bladder or intestine, unless the bladder, intestine or part is used as a natural casing for the meat product and meets the requirements of section 126 of the proposed SFCR; and
(e) a meat product with an artificial casing, unless the casing is manufactured from a material that is free of any noxious constituent.
Box Yes
Box No
126 Natural casings
A urinary bladder, an intestine or any part of a urinary bladder or intestine may be used as a natural casing for an edible meat product if:
(a) the contents and mucous lining of the bladder, intestine or part were removed and the bladder, intestine or part was washed;
(b) in the case of a bladder, it was inverted and placed in brine for at least 12 hours and was subsequently rinsed with water; and
(c) the casing is clean.
Box Yes
Box No
155(b)(c) Trichinella spp. – pork
A licence holder may identify as edible a meat product that is derived from a pig and that does not require further preparing before consumption other than washing or thawing or exposing it to sufficient heat to warm it without cooking it, only if:
(b) the pork is derived from a carcass that tests negative for the detection of Trichinella spp. larvae using a method that is shown by evidence to be effective; or
(c) the pig originates from a farm that operates an on-farm food safety program under which the risk of Trichinella spp. infection is negligible.
Box Yes
Box No
156 Trichinella spp. – equine
A licence holder may identify as edible a meat product that is derived from an equine if its carcass tests negative for the detection of Trichinella spp. larvae using a method that is shown by evidence to be effective.
Box Yes
Box No
157(a) Bovine cysticercosis
A licence holder may identify as edible a meat product that is derived from a bovine whose carcass is affected by or shows evidence of bovine cysticercosis only if the licence holder removes the parts of the carcass that are affected and identifies them as inedible.
Box Yes
Box No
Packaging
183 Requirements for packages
A prepackaged food must meet the following requirements:
(a) its package:
(i) must be suitable for its intended use and appropriate for the food;
(ii) must be capable of protecting the food against moisture, loss, damage, contamination and deterioration during normal handling, storing and conveying;
(iii) must be clean and in sanitary condition;
(iv) must be of sound construction,
(v) must be free from odours that might affect the food;
(vi) must not impart any undesirable substance to the food;
(vii) must not have a design or mark, or be of a colour, that enhances the appearance of the food with respect to its quality or composition; and
(viii) must be new, in the case of:
(A) a liner that is used in connection with a processed egg product,
(B) a package of a processed egg product, if the package is made of corrugated fibreboard,
(C) a carton of eggs that are graded under these Regulations, and
(D) a tray of eggs that are graded Canada A or Canada B that is made of molded pulp;
(b) in the case of a processed egg product, its package must, if it has previously been used and is not constructed of corrosion-resistant material, be lined with a sanitary plastic or equivalent liner;
(c) in the case of eggs that are graded under these Regulations, its package must, if it is a plastic tray that has previously been used, be sanitized and dry before re-use; and
(d) in the case of eggs that are graded Canada A or Canada B, its package must not have previously been used to package ungraded eggs or eggs that are graded Canada Nest Run.
Box Yes
Box No
278(b) Uncooked meat products
The following information must be shown on the principal display panel of a prepackaged edible meat product that is not a ready-to-eat product but could be mistaken for one:
(b) comprehensive cooking instructions such as an internal temperature-time relationship that, if followed, will result in a ready-to-eat meat product.
Box Yes
Box No
311 Ungraded eggs
(1) All ungraded eggs that are received at an establishment where eggs are graded by a licence holder must be graded and labelled with the applicable grade name or, if they do not meet the requirements in respect of any grade that are set out in these Regulations, they must be rejected.
Rejected eggs
(2) Eggs that are rejected must be destroyed or be placed in a container that is labelled with the words "Rejects" and "rejetés".
Box Yes
Box No

6.0 Annexes

6.1 Annex I – Questions & Answers

Below is additional information on the self-assessment checklist and draft PCP templates and how they can be useful to you in developing your written PCP, as well as information to keep in mind for you as an importer.

Q1. Who are the self-assessment checklist and draft PCP templates intended for?

The self-assessment checklist and Draft PCP templates for importers are intended for food importers who would require a PCP based on the proposed SFCR. Use of the self-assessment checklist and draft PCP templates is intended to help you understand the proposed requirements and help in preparing your written PCP. Use of the CFIA checklist and templates is voluntary. You will need to develop and tailor your PCP for your particular operation and products.

Some food importers may not require a written PCP. For example, the proposed SFCR would not require importers of certain foodsFootnote 1 who have total sales related to food of $30,000 per year or less to have a written PCP. Please use the Would you need a Preventive Control Plan tool to determine if you would require a written PCP for the food you import based on the proposed SFCR.

Note: If you do not require a written PCP, preventive controls must still be met. This means that the food you are importing must still meet Canadian safety requirements and must have been manufactured, prepared, stored, packaged and labelled in the foreign country under conditions that provide at least the same level of preventive control protection as that provided under the proposed SFCR. In addition, investigation, recall and complaints procedures must be in place. Q7 contains more detail on your requirements regarding investigation, recall and complaints procedures.

Q2. What do I do if an element of the template does not apply?

Elements in the self-assessment checklist and Draft PCP templates that do not apply to the imported food, or the activity being conducted in the foreign country in relation to the food, do not need to be included in your written PCP. For example, the preventive controls that relate to meat products or the slaughter of food animals would not apply to an imported food that is not meat or that is not related to the slaughter of food animals. For these elements, you may indicate an "NA" (not applicable) on the template.

Q3. What type of evidence and/or documentation should I obtain from my foreign supplier to complete my written PCP?

The proposed SFCR do not specify the type of records you need to keep to ensure that appropriate control measures are being applied in the foreign country. This means that you would have flexibility in the type of records you can use to demonstrate that the food you import meets the requirements of the proposed SFCR.

You are encouraged to work collaboratively with your foreign supplier to identify the key components of your PCP and any preventive control gaps that need to be addressed. In this regard, you may wish to review your self-assessment checklist with your foreign supplier. It is also beneficial for you and your foreign supplier to agree on the written documents that your foreign supplier will provide in order for you to demonstrate that each of the applicable elements in the self-assessment checklist and PCP templates are properly addressed. Examples of documentation could include procedures, records, communications, attestations, evidence of system recognition for imported meat or shellfish, etc. There must be sufficient and appropriate documentation to demonstrate that the appropriate control measures are in place and that they are effective.

Q4. How often do I need to update my written PCP?

The proposed SFCR do not specify how often your PCP needs to be updated. Nevertheless, you would want to be confident that your written PCP is being implemented to effectively address the preventive control requirements by being up to date at all times. To do this, you may wish to establish a "check-in" schedule with your foreign supplier in the foreign country to determine what a reasonable and appropriate frequency is to keep your written PCP up to date. As part of these "check-ins", it is recommended that you ensure that there have not been any significant changes to your foreign supplier's process(es) which could impact your PCP, and that you obtain written evidence demonstrating that requirements continue to be met.

Q5. Does my written PCP need to cover everything that happens to my food before I import it?

Based on the proposed SFCR, you would be responsible for ensuring that the food you import is manufactured, prepared, stored, packaged and labelled in the foreign country under conditions that provide at least the same level of protection as that provided under the preventive controls in the SFCR. This means that your written PCP would need to address all foreign suppliers who manufacture, prepare, store, package or label the food before it is imported into Canada. For example, if you have one foreign supplier who manufactures the food you import and another who packages and labels it, you are responsible for ensuring the requirement for a clean and sanitary establishment is met for both the establishment where the food is manufactured and the establishment where it is packaged and labelled.

Q6. Where does my role as an importer begin and where does it end?

As an importer, you would be responsible for identifying any biological, chemical and physical hazards with the food you import and for ensuring that those hazards are analyzed and controlled by you and/or the foreign manufacturer, using measures that are shown by evidence to be effective.

You would also need to ensure that the food you import was manufactured, prepared, stored, packaged and labelled under conditions that provide at least the same level of protection as that provided under the preventive control requirements in the SFCR. This could be accomplished, for example, through communication with, and documentation provided by, your foreign supplier, or reliable information provided by a 3rd party or an accredited body.

It is your responsibility to ensure that in all cases, the food you are importing arrives in a state in which its safety has not been compromised. Below are examples of things to consider and verify when the food you are importing arrives in Canada:

  • Is your food product in its expected state upon arrival? (e.g. packaging is intact and the product is not exposed to dirt or contaminants that may have been in the transportation vehicle).
  • Does the food correspond to the food you intended to import? (i.e. label states what the food is and is in fact that food).
  • Has the temperature of the food been maintained upon delivery? (i.e. frozen product arrives frozen and the transportation vehicle has maintained an appropriate temperature during delivery. Taking the temperature of the food upon arrival and verifying the temperature of the truck's cargo area is an example of a control measure that can be taken to ensure the product's safety has not been compromised upon delivery).
  • Are there other products in the transportation vehicle that have been segregated from your imported food product to avoid the possibility of contamination of your imported food product? (e.g. if there are chemicals in the transportation vehicle, ensure they are separated from the food product and that they have not leaked or come in contact with the food product).

Once your product is at its intended destination (either in storage, to be distributed for sale or with the person who will further handle the product for sale), your role as an importer of that food ends. You would however be required to keep and maintain documents in relation to investigations, complaints and recalls, and document how any applicable PCP requirements were met.

Note: As an importer, if you have domestic operations once your food arrives in Canada (for example, processing, labelling, repackaging, etc.) and such food is to be exported or to cross provincial borders, you would need to meet the regulatory requirements relating to the domestic operations. This would include those relating to preventive controls and written preventive control plans, as may be applicable to the food and domestic activity. This also applies to imported ingredients where the food is further manufactured in Canada for export or sale across provincial border. Please refer to the domestic A Draft Step-by-Step Guide for Domestic Food Businesses and Exporters – Preparing a Preventive Control Plan for additional information and for domestic draft PCP templates. This guide can also provide insight in to the level of detail a domestic manufacturer considers for their PCP and therefore serve to understand the type of details you would require from your foreign supplier.

Q7. What about investigation, complaints and recall?

As a holder of a licence to import, whether or not you are required to have a written PCP, you would be responsible for having procedures and, where applicable, documentation in place to comply with the SFCR sections 80-82, such that:

  • Matters are immediately investigated by you when it is reasonably suspected that the food presents a risk of injury to human health or does not comply with the Act and Regulations. If the results indicate a risk, immediate action to mitigate the risk must be taken and the appropriate food regulatory authority must be immediately notified of the results of the investigation.
  • You have a written plan of procedures in place to receive, investigate and respond to complaints related to the food. Any complaint received must be actioned in accordance with the procedure and documented to record the details in writing of the complaint, the results of the investigation and actions taken based on those results. This document must be kept for two years after the day on which the actions are completed.
  • You have written food recall procedures in place that enable the effective recall of a food, including contact names responsible for the procedure and the implementation of the recall. Recall simulations must be conducted at least once per year. If a food is recalled, you must immediately notify the appropriate food regulatory authority, implement the recall procedure and prepare and keep for two years from the day the recall is initiated, a written document setting out the details of the recall, including any information that substantiates its effectiveness.

In addition, you would be required to ensure that the foreign supplier who manufactures, prepares, stores, packages or labels the food you import has at least the same level of protection for the food as that provided by the preventive control provision by having similar procedures relating to investigation, complaints and recalls. Such assurance would need to be addressed in your PCP.

Q8. I have more than one foreign supplier; do I complete a written PCP template for each foreign supplier?

The proposed SFCR do not specify how your written PCP needs to look. You may choose to select and adapt templates to meet your needs. If you have several foreign suppliers, it is recommended that you complete a written PCP for each foreign supplier as this may keep records more organized and easier to maintain.

6.2 Annex II – Draft Example Completed Templates

–Examples–

Below is an example of a completed Preventive Control Measures – Template for Importers and a completed Content of Preventive Control Plan for importers – Description of hazards, control measures, critical control points and critical limits for the import of whole black pepper from India.

Note that this is simply an example and that the evidence that the control measure is being implemented effectively below, may not be sufficient to meet the regulatory requirement based upon the type of food, country of origin, risk factors, etc., associated with your specific products. Other options of evidence to ensure that preventive control measures are being effectively implemented by the foreign supplier and/or frequency of verifying the evidence may apply to you. Always ensure that the information in your preventive control plan is tailored for your particular business, product(s), and regulatory requirements.

6.2.1 Preventive Control Measures – Template for Importers

Name of foreign supplier: Company ABC

Address of foreign supplier: XYZ St., New Delhi, India

Additional foreign supplier information: QA Contact: Mr. abc

Product information (e.g. product name, etc.): black pepper (whole)

SFCR section number Preventive Control Measure
(as may be applicable to the imported food and your foreign supplier's operations)
Evidence that this preventive control measure is being implemented effectively Frequency that evidence is verified Date last verified
Determination and Control of Hazards of the Imported Food
44 Biological, chemical and physical hazards that may present a risk of contamination of a food are identified and you are assured that these hazards have been prevented or eliminated control measures shown by evidence obtained from your foreign supplier to be effective, (see template 1B for further information). 1) Product specification sheet: foreign supplier guarantee that hazards are properly controlled.
2) In-house random sampling for Salmonella
1) Documents received with each shipment
2) Random (approximately every 3rd shipment)
1) Documents reviewed with each shipment
2) 2016/06/29
45, 46 The food is subjected to a process or treatment necessary to eliminate any biological, chemical or physical hazard that might be present and that presents a risk of contamination to the food (as set out in sections 45 and 46). 1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
3) Foreign supplier fumigation, sifting/screening, and metal detection records
4) In-house random sampling for Salmonella
1-3) Annually
4) Random (approximately every 3rd shipment)
1-3) 2016/07/19
4) 2016/06/29
Sanitation and Pest Control at the Foreign Supplier's Establishment
48 The establishment, equipment and conveyances are clean and in a sanitary condition, and the cleaning and sanitation is conducted in a manner that does not present a risk of contamination of the food. 1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
3) Foreign supplier written sanitation procedures
1-3) Annually 2016/07/19
49 The establishment is protected against the entry of animals that could contaminate the food (e.g. insects and rodents), non-essential animals are barred entry into the facility or conveyance and measures taken in this regard do not present a risk of contamination of the food. 1) Foreign supplier written pest control procedures
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
50 Non-food chemicals (sanitizers, etc.) are properly and clearly identified, are suitable for its intended use, do not present a risk of contamination of a food, and are handled and used in a way that does not pose a risk of contamination of the food. Foreign supplier written sanitation procedures Annually 2016/07/19
Conveyances and Equipment at the Foreign Supplier's Establishment
51 Conveyances and equipment must be appropriate for the food and activity being conducted and meet the requirements of paragraphs 51(b) to (i). 1) Third party certification document
2) Foreign supplier letter of guarantee
1&2) Annually 2016/07/19
52 Separate conveyances or equipment are used for handling contaminated material, waste or any other inedible substances, be identified as reserved for that purpose and meet the applicable requirements of section 52. Foreign supplier written procedures Annually 2016/07/19
53 There is restraining equipment for food animals being examined and inspected for slaughter. N/A
Supplier's Establishment
54 Unless measures are taken to eliminate the risk, the land forming part of the establishment must not present a risk of contamination of a food and the establishment must not be located near any place or thing (e.g., pollution, garbage, rodents, insects) that presents a risk of contamination of a food. 1) Third party certification document
2) Foreign supplier letter of guarantee
1&2) Annually 2016/07/19
55 The interior of the facility or conveyance is of sanitary design to prevent the accumulation of contaminants (e.g., dust, dirt, micro-organisms, food products) and to permit effective maintenance, cleaning and sanitizing. They must also be designed and constructed in accordance with paragraphs 55(b) to (d). 1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
56 An establishment where food animals are slaughtered must have:
  • separate areas for activities set out in section 56(1)(a) to (d);
  • an enclosed area where inedible meat products are handled;
  • secure footing for food animals during movement; and
  • stations for conducting post-mortem examinations.
N/A
57 The facility or conveyance must be designed, controlled and maintained in a manner so that the movement of people and things are controlled and the movement does not present a risk of contamination of the food. 1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
58, 59 Incompatible activities and anything that presents a risk of contamination of a food, as well as any food that does not meet the requirements of the Safe Food for Canadians Act or its Regulations and any non-food item that is manufactured, prepared, stored, packaged or labelled in the establishment, must be separated by physical or other effective means. 1) Third party certification document
2) Foreign supplier written procedures
1&2) Annually 2016/07/19
60 Upon arrival at an establishment, food that presents a risk of injury to human health, or has been returned after export ,or does not meet the requirements of the Safe Food for Canadians Act or its Regulations, is identified as such and kept in a designated area within the establishment. Any other measures necessary to prevent contamination of any other food in the establishment must be taken. 1) Third party certification document
2) Foreign supplier written procedures
1&2) Annually 2016/07/19
61 Lighting is appropriate for the food (or food animals) and activity being conducted, can be repeatedly cleaned (and, if applicable, sanitized) and not present a risk of contamination of the food in the event of breakage. 1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
62 The facility or conveyance is equipped with a ventilation system that:
  • functions as intended;
  • provides sufficient air exchange to provide clean air and to remove unclean air and odours that might affect the food;
  • is accessible;
  • can be maintained and is capable of withstanding repeated cleaning; and
  • if necessary, is able to be disassembled for cleaning, maintenance and inspection.
1) Third party certification document
2) Foreign supplier letter of guarantee
1&2) Annually 2016/07/19
63 Temperature and humidity in a facility or conveyance are maintained at levels appropriate for the food (or food animals to be slaughtered) and the activity being conducted. Any heating, cooling or humidity-control system must:
  • function as intended;
  • be equipped with necessary instruments that control, indicate and, if required, record the temperature and humidity levels;
  • be accessible
  • be capable of withstanding repeated cleaning; and
  • if necessary, be able to be disassembled for cleaning, maintenance and inspection.
1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
64 The establishment is equipped with means to remove and dispose of contaminated materials and waste, including a drainage, sewage and plumbing system capable of withstanding repeated cleaning and that functions as intended. Contaminated materials and waste must be removed and disposed of at sufficient frequency to prevent contamination of a food and in a way that does not present a risk of contamination of the food. 1) Third party certificationb document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
65 There are hand cleaning and sanitizing stations, drinking water stations, break rooms, change rooms and washrooms (including lavatories and showers) in the establishment as necessary to meet the needs of the establishment. They must:
  • be appropriately equipped and appropriate in number and size for the number of persons using them;
  • be located in the establishment and reasonably accessible to the persons using them;
  • be capable of withstanding repeated cleaning and, if applicable, sanitizing;
  • for the hand cleaning and sanitizing stations, supply water at a temperature and pressure for effective cleaning of hands; and
  • for the lavatories, not provide direct access to any area where a food is manufactured, prepared, stored, packaged or labelled or where food animals are slaughtered.
1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
66 An appropriately sized area that is readily accessible and properly equipped is provided for CFIA inspectors conducting oversight/verification activities related to the food upon their request. Inspection records from Food Safety and Standards Authority of India Annually 2016/07/19
67 Appropriate accommodation and equipment as described in section 67 is provided in the establishment to inspectors of imported meat products, processed egg products and food animals. N/A
68 Water, ice or steam that comes in contact with a food, any system that supplies water and any water given to food animals to be slaughtered, must meet the requirements of section 68. N/A
69 As appropriate for the food, the activity conducted and for food animals slaughtered, the establishment must be supplied with:
  • water adequate in quantity, temperature, pH and pressure to meet the needs of the establishment;
  • steam and ice that is adequate in quantity and steam that is adequate in pressure to meet those needs.

The above must be applied in a manner that does not present a risk of contamination.

N/A
Unloading, Loading and Storing at the Foreign Supplier's Establishment
70 Conveyances used to convey food to or from the establishment and that are unloaded or loaded at the establishment must be:
  • designed, constructed, and maintained to prevent contamination of the food;
  • constructed of, and maintained using materials that are suitable, for their intended use and, if the materials present a risk of contamination, that are durable, capable of withstanding repeated cleaning and, if applicable sanitizing, and free of any noxious constituent;
  • capable of maintaining the temperature and humidity at levels that are appropriate for that food and, if necessary, be equipped with instruments that control, indicate and record those levels;
  • of sound construction and in good repair; and
  • clean and in sanitary condition at the time of unloading or loading.

In addition, the conveyance must not contain or have contained animals, pest control products or any other material or substance that represents of a risk of contamination of the food.

1) Third party certification document
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
71 Unloading and loading of a food and food animals for slaughter from or onto a conveyance must be conducted in a manner that does not present a risk of contamination of a food. Foreign supplier written procedures Annually 2016/07/19
72 Storage of a food, and of non-food items used in the manufacture, preparation, storage, packaging or labelling of a food (e.g., cleaning agents, packaging materials, sanitizers, equipment, starter products [as defined in s. 72(3)]), are conducted in a way that does not present a risk of contamination of a food. 1) Foreign supplier written procedures
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
Competency of Employees at the Foreign Supplier's Establishment
73 Employees and others involved in the manufacturing, preparing, storing, packaging or labelling of a food, or in the slaughter of food animals, are competent and qualified to carry out their duties. Foreign supplier letter of guarantee and employee and training policy Annually 2016/07/19
Hygiene at the Foreign Supplier's Establishment
74-78 Everyone in an area where food is manufactured, prepared, stored, packaged, or labelled, or where food animals are slaughtered, follows hygienic practices as set out in sections 74-78. 1) Foreign supplier written procedures
2) Inspection records from Food Safety and Standards Authority of India
1&2) Annually 2016/07/19
Communicable Diseases Control at the Foreign Supplier's Establishment
79 Anyone suffering from a communicable disease or open infected lesion is prevented from being in an area of the establishment where a food is manufactured, prepared, stored, packaged, or labelled, or where food animals are slaughtered, if the condition presents a risk of contamination of the food. Foreign supplier letter of guarantee and written procedures Annually 2016/07/19
Investigation and Notification, Complaints and Recall
80 There are procedures in place for investigation and they are implemented. Foreign supplier written procedures Annually 2016/07/19
81 There are procedures in place for complaints and they are implemented. Foreign supplier written procedures Annually 2016/07/19
82 There are procedures in place for recall and a recall simulation and they are implemented. Foreign supplier written procedures and recall simulation records Annually 2016/07/19

6.2.2 Content of Preventive Control Plan for Importers – Description of hazards, control measures, critical control points and critical limits

As per section 87(2) of the proposed SFCR, the preventive control plan of a holder of a licence to import must also include the elements set out in the template below in relation to the applicable requirements of section 45-82. As an importer, it is important that you are aware of the hazards associated with the food you are importing.

Name of foreign supplier: Company ABC

Address of foreign supplier: XYZ St., New Delhi, India

Additional foreign supplier information: QA Contact: Mr. abc

Product information (e.g. product name, etc.): black pepper (whole)

SFCR section number Principle
(in relation to the applicable requirements of sections 45-79)
Describe how this principle is being implemented effectively through actions taken by you, your foreign supplier or other means. Frequency that this is verified Date last verified
87(1)(c)(i) Describe all biological, chemical and physical (BCP) hazards that have been identified under section 44 as presenting a risk of contamination of the food to be imported Product specification sheets from the foreign supplier are detailed with all BCP hazards.
Specification sheets are reviewed regularly by our office.
On-going N/A
87(1)(c)(i) Describe the control measures used to prevent or eliminate the BCP hazards and that you have evidence that such measures are effective 1) Rely upon information from the foreign supplier as well as third party certification.
2) We arrange for random product samples to be submitted to an accredited laboratory
1) Annually
2) Approx. every third shipment
1) 2016/07/19
2) 2016/06/29
87(1)(c)(ii) Describe any applicable critical control points and related control measures 1) Rely upon information from the foreign supplier as well as third party certification.
2) inspection records from Food Safety and Standards Authority of India are reviewed
Annually 2016/07/19
87(1)(c)(ii) Ensure you have evidence showing that related control measures are effective at each critical control point 1) Rely upon third party certification as well as foreign supplier processing and product sampling records
2) inspection records from Food Safety and Standards Authority of India are reviewed
3) We arrange for random product samples to be submitted to an accredited laboratory
1&2) Annually
3) Approx. every third shipment
1&2) 2016/07/19
3) 2016/06/29
87(1)(c)(iii) Describe the critical limits for each critical control point 1) Rely upon third party certification
2) inspection records from Food Safety and Standards Authority of India are reviewed
3) foreign supplier documented critical limits for each CCP are reviewed
Annually 2016/07/19
87(1)(c)(iv) Ensure there are procedures for monitoring the critical control points in relation to their critical limits 1) Third party certification
2) inspection records from Food Safety and Standards Authority of India are reviewed
3) foreign supplier written CCP monitoring procedures are reviewed
Annually 2016/07/19
87(1)(c)(v) Ensure there are corrective action procedures for each critical control point 1) Third party certification
2) inspection records from Food Safety and Standards Authority of India are reviewed
3) foreign supplier written corrective action procedures are reviewed
Annually 2016/07/19
87(1)(c)(vi) Ensure there are procedures to verify the preventive control plan complies with the Act and applicable Regulations Rely upon third party certification as well as sampling results and shipment inspection. On-going N/A
87(1)(c)(vii) You have documents that substantiate that the preventive control plan has been implemented as per above steps Documents supporting the above steps (e.g., certification, test results, specification sheets, etc.) are stored on-site. On-going N/A
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