A Draft Step-by-Step Guide for Domestic Food Businesses and Exporters: Preparing a Preventive Control Plan

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 on the SFCR advances through its various stages. In the interim, current laws applicable to your food and business continue to apply.

Table of contents

Introduction

A) Developing your preventive control plan

B) Implementing your preventive control plan

C) Maintaining your preventive control plan

Tell me more! – References and further reading

Introduction

This guide is intended for domestic food businesses, including exporters, that would be required to have a preventive control plan (PCP) when the Safe Food for Canadians Regulations (SFCR) comes into force. A PCP is a written plan outlining how you ensure that food is safe and fit for consumption and conforms to applicable regulatory requirements.

Preventive controls are an internationally accepted approach to prevent or eliminate hazards associated with food products. They are based on the CODEX Alimentarius General Principles of Food Hygiene CAC/RCP 1-1969 – PDF (179 kb).

Preventive control plans are not a new concept for many food businesses. For example, federally registered meat and fish processors already have implemented systems such as the 'Food Safety Enhancement Program' (FSEP) and the 'Quality Management Program' (QMP). These programs are considered comparable to a preventive control plan because they deal with similar food safety requirements.

More information for businesses who import foods can be found in A Draft Guide for Preparing a Preventive Control Plan – For Importers.

It's your choice

You may use other preventive control plan approaches that have been developed by other food safety authorities, industry associations, international partners, or academia. Always ensure that the information in your 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 it comes into force.

A) Developing your preventive control plan

Under section 87(1)(c) of the proposed Safe Food for Canadians Regulations, a written preventive control plan would include the following:

  • a hazard analysis that describes the biological, chemical, and physical hazards that are reasonably expected to contaminate your food
  • descriptions of the control measures used to control the hazards, and the evidence showing they are effective
  • descriptions of the critical control points (CCPs) in your process, including the related:
  • procedures to verify that the written preventive control plan has been implemented and is effective at preventing or eliminating hazards in the food
  • evidence that you have implemented your written preventive control plan (for example, service contracts, processing records, and other day to day records)

In addition, the written preventive control plan would include the following:

  • descriptions of the measures you have in place to meet the market fairness provisions (such as labelling, packaging, grading, standards of identity, net quantity and humane treatment of animals) referred to in section 87(1)(a) and (b) of the proposed Safe Food for Canadians Regulations
  • the supporting documents referred to in section 87(1)(d) used to develop your PCP, such as the information you used to determine your hazards, your rational for determining CCPs, and historical data

If applicable to your business, your written preventive control plan may also need to include additional content related to food for export and post-mortem examination programs referred to in sections 87(3) and (4) of the proposed Safe Food for Canadians Regulations.

Keep in mind

The Would you need a preventive control plan? tool will help you determine if you would need to prepare a written preventive control plan once the regulations come into force.

The CFIA has created a series of infographics on food hazards and preventive controls. The infographics will give you a basic overview of key elements that need to be included in your preventive control plan.

The CFIA has also created Draft Preventive Control Plan Templates – for Domestic Food Businesses and Exporters and A Draft Guide to Preparing a Preventive Control Plan – For Importers. These draft templates help further illustrate what a PCP would include.

The following steps will guide you through the process of developing a written preventive control plan for your food operation.

Step 1: Assemble your team

Developing, implementing and maintaining an effective preventive control plan depends on knowledgeable and experienced management and employees working together to identify food safety hazards and how to control them.

Include key people on your team to cover all aspects of your food operation for developing the PCP. Consider using people that:

  • understand the practical aspects of food operations, such as the process flow, and the technology and equipment used in your facility, and
  • are knowledgeable in the area of food safety, including the microbial, chemical and physical hazards related to the food being prepared.

Some ways of enabling your team to develop your preventive control plan are to:

  • provide the team with the necessary resources and time, and
  • train staff so they are qualified to carry out this work.

Step 2: Ensure you meet preventive control requirements

The first task would be to check that you would meet the applicable preventive control requirements in sections 48 to 78 of the proposed Safe Food for Canadians Regulations once they come into force.

The preventive controls covered in sections 48 to 78 are the basic practices a food business must follow to reduce the risk of introducing hazards to the food through the processing environment.

Step 3: Perform a hazard analysis and establish procedures

The next step would be to perform a hazard analysis on your food, determine control measures and document it all by applying the following process.

Step 3.1 – hazard analysis

For each food product, identify and describe any hazards (biological, chemical and physical) that are likely to contaminate the food through:

  • the inputs (ingredients and packaging materials),
  • processing steps, and
  • traffic flows.
Keep in mind

You may choose to use the expertise of a trade or professional association or a consultant to help you analyze relevant biological, chemical and physical hazards, and develop your PCP. The references listed at the end of this guide may also be useful.

The Reference Database for Hazard Identification (RDHI) is also available to help you identify potential hazards in food processing.

Step 3.2 – control measures

Identify and describe the control measure(s) that would control each hazard identified in your hazard analysis. The description of your control measures would include the following details:

  • What – a description of the task
  • How – details of how the task is carried out
  • When – the frequency of the task
  • Who – the person responsible for carrying out the task
  • Records – it is a good practice to list any forms you use for the day-to-day collection of information used to record delivery of tasks and controls.

Document the evidence that shows that your control measures are capable of controlling the hazard. More information on how to demonstrate the effectiveness of your control measures can be found in the CODEX Alimentarius Guidelines for the Validation of Food Safety Control Measures CAC/GL 69-2008 – PDF (222 kb).

Step 3.3 – critical control points

Determine if there are any critical control points in your process. Critical control points (CCP) are the points in your process where a control measure is applied and is essential to prevent or eliminate the identified food safety hazard(s).

Keep in mind

If the identification of CCPs is new to you, the Draft Preventive Control Plan Templates – For Domestic Food Businesses and Exporters contains a series of questions that will guide you through the process.

If you have identified any CCPs, establish and describe the critical limits for each of them. Critical limits are the maximum or minimum set values that control a hazard at a critical control point.

  • For example, the time and temperature parameters used at a pasteurization or cooking step.

For every CCP, develop and document:

  • monitoring procedures that ensure the critical limits are met, and
  • corrective action procedures when critical limits are not met.

Step 3.4 – verification

Establish verification procedures to demonstrate that your preventive control plan, including the control measures, you have identified in steps 3.1-3.3 are implemented as written and are effective in preventing food safety hazards, resulting in compliance with the proposed Safe Food for Canadians Regulations.

Step 4: Establish measures for market fairness requirements

Describe the measures you have in place to meet the applicable market fairness provisions (such as labelling, packaging, grading, standards of identity, net quantity and humane treatment of animals) referred to in section 87(1)(a) and (b) of the proposed Safe Food for Canadians Regulations.

You may also have to include measures for the additional requirements related to food for export and post-mortem examination programs referred to in sections 87(3) and (4) of the proposed Safe Food for Canadians Regulations.

Step 5: Assemble your documents

Compile your:

  • hazard analysis
  • written control measures for your food safety hazards, and the evidence showing that they are effective
  • CCP documentation, including critical limits, and monitoring and corrective action procedures
  • verification procedures
  • supporting documents that you used to develop your PCP
  • written measures describing how you meet the other requirements (e.g., market fairness requirements, such as labelling, packaging, grading, standards of identity, net quantity and humane treatment of animals)

You have now developed your written preventive control plan.

B) Implementing your preventive control plan

Once you have developed your written preventive control plan (PCP), you would need to implement it into your day-to-day operations. This involves:

  • training your staff on the procedures
  • following the PCP as written
  • generating and maintaining records that show you have implemented your PCP
  • verifying that your PCP is implemented as written and is effective in preventing food safety hazards, resulting in compliance with the Safe Food for Canadians Regulations.

The CFIA would verify during inspections that your preventive control plan is complete, implemented and effective.

C) Maintaining your preventive control plan

Once you have developed and implemented your PCP, review it at a frequency appropriate to your food business and revise it as necessary.

The PCP needs to be reassessed and updated when:

  • something is new or has changed

    (for example, in terms of regulatory requirements, food produced, growing or harvesting procedures, agronomic inputs, ingredients or incoming materials, product formulation, equipment, production flow, processing step, production volumes, etc.)

  • a problem has been identified

    (for example, deficiency or deviation observed during in-house monitoring or verification procedures, non-compliance identified by CFIA or third party auditors, customer complaints that reveal a problem with the PCP, food recalls, unsatisfactory laboratory results, etc.)

Updating and reassessing your plan includes reviewing records and conducting on-site assessments of all preventive controls.

Tell me more! – References and further reading

The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. The Canadian Food Inspection Agency is not responsible for the content of documents that are created by other government agencies or international sources.

Alberta Agriculture and Rural Development: Food Safety Guidebook

Alberta Agriculture and Rural Development: HACCP – Making Food Products Safe

CODEX Alimentarius General Principles of Food Hygiene CAC/RCP 1-1969 – PDF (179 kb)

CODEX Alimentarius Guidelines for the Validation of Food Safety Control Measures CAC/GL 69-2008 – PDF (222 kb)

Manitoba Agriculture, Food and Rural Development: Basic GMP Program

Ontario Ministry of Agriculture, Food and Rural Affairs: Food Inspection Programs

Canadian Food Inspection Agency Food Safety Enhancement Program (FSEP)

Canadian Food Inspection Agency HACCP Generic Models and Commodity-Specific Food Safety Guidance Documents

Canadian Food Inspection Agency Quality Management Program (QMP)

Canadian Food Inspection Agency Reference Database for Hazard Identification (RDHI)

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