Element 6: Verification and Maintenance of the QMP Plan
Minimum Requirements
Processors are required to perform the following verification activities to ensure that their QMP Plan is functioning correctly:
1. Before implementation the processor will be required to:
- validate the critical limits of CCPs, where appropriate; and
- verify the QMP Plan to ensure that all the necessary controls are in place and that it meets the requirements of the QMP Standard.
2. Once the QMP Plan is implemented, the processor is required to:
- perform routine verification of the HACCP Plan to ensure it is functioning effectively (e.g. Record reviews, Corrective Action reviews, review of calibration of equipment);
- verify or validate any changes to QMP controls or CCP critical limits that may occur in the ongoing development of the QMP Plan; and
- verify the QMP Plan at least once per year.
To ensure that the QMP Plan is accurately documented, processors are required to maintain records of any changes to their QMP Plan. There are five main activities involved in verifying a QMP Plan. The first two must take place before the implementation of and operation under the QMP Plan. These activities are the validation of the critical limits at the CCPs (covered in Element 5) and the initial verification. These activities happen once only.
The next three verification activities are performed once the QMP Plan is implemented and include: the routine verification of the CCPs (covered in Element 5), the verification or validation of changes to the QMP Plan to ensure that it is still adequate, and verify the QMP Plan at least once per year.
Changes to a QMP Plan must be documented in the form of an amendment log to ensure that the written QMP Plan reflects the controls that are being applied in the processing operation.
6.1 Initial QMP Plan Verification
Once the QMP Plan is completed, it must be verified. That is, reviewed to ensure that it complies with the QMP Reference Standard. Once it has been verified that the plan meets all the requirements of the standard, it and the other information required will be submitted to the CFIA for review.
Verifying Your Initial QMP Plan
Step 1 - Perform verification using a checklist.
Step 2 - Prepare the submission.
Prepare a QMP submission package with the completed QMP Plan including:
- background information on the plant;
- the date the company wishes to begin processing;
- the operations the company is requesting registration for; and
- the products the company intends to process.
Step 3 - Submit the QMP submission package to the local CFIA inspector.
Step 4 (Performed by CFIA staff)
Once the QMP submission package has been received, CFIA inspection staff will:
- review the QMP submission;
- ask the processor to explain anything in the QMP submission that is unclear;
- tell the processor whether the QMP Plan must be amended or expanded; and
- inform the processor when the QMP Plan has been accepted.
6.2 Annual QMP Plan Verification
The processor must verify their QMP Plan once each year. The processor must ensure that the QMP Plan is still effective and that it is still being correctly applied by the staff. This annual verification must be documented, and the records must be available for the inspector to review.
For the annual verification, check that:
- all CCPs are still being controlled;
- the controls implemented for each CCP are adequate;
- any amendments made to the processing line have been documented; and
- the QMP Plan, including the Prerequisite and RAP Plans are complete and functioning effectively.
6.3 Maintaining the Record of Amendments to a QMP Plan
When amending a QMP Plan, or any QMP documentation, record the changes and when they were made. The most efficient way to do this is to include an amendment record in all permanent QMP documentation (see Figure 10)
This documentation must also be made available to the inspector.
Figure 10: Sample Amendment Record
| Date | Page | Amendment made | Signature |
|---|---|---|---|
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