Feed Regulatory Renewal Consolidated Modernized Framework Proposal – November 2015
Guidance Documents and Model Systems
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The CFIA recognizes that good guidance documents will assist in the successful implementation of the proposed regulations. Guidance documents should facilitate compliance with regulations. The most important benefit of effective guidance and compliance promotion is improved feed safety through the effective implementation of preventive control measures.
Currently the CFIA has a range of guidance with respect to the existing Feeds Act and Regulations. While filled with important and useful information for industry, the existing guidance documents can be difficult to navigate to find the necessary information.
The CFIA is developing a new suite of regulatory guidance documents that will significantly improve the format, content and accessibility of its guidance material. This new suite of documents will replace existing manuals to help industry to comply with the Feeds Act and Regulations including:
- Guidance to clearly explain the intent of regulatory requirements.
- Model systems to provide examples that when properly applied have been demonstrated to achieve compliance with the regulatory requirements. These would initially include generic models.
- Additional "plain language" resources for small and medium size businesses.
The CFIA is intending to consult with regulated parties to determine the most appropriate format, language and methods of communicating guidance material.
The CFIA has also drafted a comprehensive Compliance Promotion Strategy which will apply to all regulated commodities (food, plant, feed, seed, etc.), the details of which are contained in a discussion document which is available on the CFIA website.
Model systems provide examples that when properly applied have been demonstrated to achieve compliance with regulatory requirements. These would initially be drawn from existing guidance and systems recognized by the CFIA, but in time could include other validated generic models or programs.
Role of 3rd Party Certification Programs
A number of external feed preventive control programs already exist. This includes the feed component of Canadian On Farm Food Safety Programs, ANAC's FeedAssure program, private industry programs, and a number of international programs such as GMP+, FAMI-QS, GLOBALG.A.P., and AFIA's Safe Feed/Safe Food program. The commitment to improving feed safety, shown by the number of parties that are choosing to participate voluntarily in one of these programs, is commendable and demonstrates the progressive role many in the feed industry are already playing. In addition to these existing programs, third parties – namely, industry-related non-government organizations, academia, or other service providers – have expertise and knowledge in their fields and may offer guidance, programs, training, self-assessments, and peer support to equip their members or sectors with the necessary tools to achieve compliance with the proposed changes to the Feeds Regulations. There are significant opportunities to leverage their leadership capacity and expertise through partnerships (e.g. private sector or public-private). Likewise, other government departments at the federal and provincial, and territorial levels may play an advisory role by providing expertise and tools.
Sector-specific domestic and international programs that include compliance with feed regulatory requirements as a specification may be considered as Model Systems and be taken into consideration by CFIA in the design and delivery of risk-based inspection oversight programs.
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