18.7.1 Step 1 - Preparation for the Verification
This section is divided in three components:
- Preparation for conducting sections 1, 2, 3, 5 and 6 verification tasks by the inspector.
- Preparation for conducting section 4 verification tasks by a CFIA team.
- Preparation for conducting section 7 verification tasks by the inspector.
18.7.1.1 Preparation for Conducting Sections 1, 2, 3, 5 and 6 Verification Tasks
An integral part of CVS Task preparation is for the inspector to be aware of current conditions, processes and areas of concern in the establishment. An inspector must conduct a tour of the entire establishment once a month to identify items of concern in order to forecast or prioritize verification tasks that will be performed during the upcoming month(s).
Note: In storages, the establishment tour is conducted once per quarter.
As part of the tour, the inspectors will review the operator's HACCP Log Book for updates or changes to the HACCP System that have a significant impact on food safety (e.g. new CCP, new allergen ingredient, new equipment etc.). Log book updates or changes may influence the prioritization of verification tasks. If significant changes are made to the HACCP system, the inspector must contact the Area CVS Coordinator to consult. The Area CVS Coordinator may determine that the HACCP System Design task must be conducted in the case of the operator's proposed amendments.
Inspectors will document the tour by entering the applicable code on the verification worksheet and must record their observations as well as the conclusion (tasks to be considered when planning upcoming inspection activities) in the "Activities conducted to assess compliance" box.
Prior to conducting a verification task, the inspector:
- Determines which verification task to perform by:
- Considering items of concern identified during their tour through the establishment or during other CFIA verification activities.
- Identifying tasks from the Task Tracking Table that are due to be completed according to the frequency.
- Identifying products that are not produced frequently but are being produced and selecting the task which addresses these products or the processes associated with this product.
- Reviews the Verification Worksheet for the last time this task was completed to determine what was assessed during the preceding verification.
- Ensures that the selection of processes, rooms, areas and equipment is varied throughout the establishment.
- Identifies written programs and records to be requested from the operator.
- Obtains written programs and records required to perform the verification task. This information may be requested from the operator in advance.
18.7.1.2 Preparation for Conducting Section 4 Verification Tasks
Development of a scope for the verification to be performed at least once every two years (Task 4.1.04)
The verification scope should at least include a review of the following documentation:
- The senior management letter of commitment;
- The HACCP system performance reporting;
- The maintenance and reassessment procedures;
- One (1) HACCP plan; and
- Six (6) prerequisite programs sub-elements.
Selection of HACCP plan(s) and prerequisite programs to be verified
The selection will be based on CFIA compliance documentation and situations that have occurred at the establishment that should have resulted in an update and/or a reassessment of parts of the HACCP system.
The CFIA team must review 6 - 12 months of CFIA compliance documentation. The types of data that should be reviewed are:
- plant compliance history (CAR) including operator's corrective action plans;
- consumer complaints investigated by the CFIA;
- The CFIA sample results including operator's corrective action plans when unsatisfactory results were obtained;
- detention and other enforcement issues or actions; and
- new regulatory requirements related to food safety.
The CFIA team must then interview the appropriate establishment representative(s) and review the establishment's log book to determine whether any of the following situations have occurred:
- new product;
- new product line that can potentially cause cross-contamination;
- new ingredient or incoming material that come in contact with the product or are used for preparing the product;
- new ingredient or product that contains allergen;
- new process step;
- new technology or piece of equipment that impacts on the level of a hazard (i.e. eliminate, reduce or increases the level of biological, chemical or physical hazards);
- potential of cross-contamination due to new/on-going construction or change in the product flow and or employee traffic patterns;
- new control measure for an identified hazard;
- change made in product description (shelf life, labelling instruction, finished product distribution, etc.);
- change made in product formulation;
- change made in processing methods that required new training and new control measures;
- change made in production volume that impact on the product flow, sanitation schedule, employee training, etc.;
- change made in sanitation/cleaning procedures (i.e. decrease or increase of time, temperature, chemical strength during CIP operations);
- change made in the application of current control measure at a CCP (e.g. change in critical limit);
- change made in the application of a current control measure at a prerequisite program bullet;
- emergence of a previously unidentified hazard;
- company's unsatisfactory lab results;
- consumer or client complaints related to food safety; and
- food safety recall.
HACCP plan selection
If there is CFIA compliance documentation or changes as outlined in the list of triggers above which affect a HACCP plan, add the HACCP plan to the scope of the verification and perform the task. The review of one (1) HACCP plan should allow the determination of effectiveness of the operator's HACCP system design and reassessment procedures as well as effectiveness of implementation.
If there is CFIA compliance documentation or there are changes which trigger the review of CCP(s) and/or PC(s) included in other HACCP plan(s), add the CCP(s) and/or PC(s) to the scope of the verification.
If there is no CFIA compliance documentation or there are no changes which affect a HACCP plan, select one (1) HACCP plan. Priority must be given to selection of a HACCP Plan that presents a higher risk to human health if control is not maintained.
Selection of prerequisite program sub-elements
If there is CFIA compliance documentation or there are changes as outlined in the list of triggers above which affect one or more prerequisite program sub-elements, include the corresponding prerequisite program sub-elements in the verification scope.
If there are less than six prerequisite program sub-elements included in the scope, select additional sub elements to reach a total of six sub elements.
Note: Prerequisite program sub-elements have been grouped according to their impact on food safety (see Table 1), with Group 1 having the most impact and Group 3 having the least. Priority must be given to selection of sub elements in group 1. Different sub elements than those selected during previous verification should be selected.
Table 1. Grouping of prerequisite program sub-elements
| Group 1 | Group 2 | Group 3 |
|---|---|---|
|
Premises:
Transportation, Purchasing, Receiving, Shipping and Storage:
Equipment:
Personnel:
Sanitation and Pest Control:
Allergen Control Program:
Recall:
|
Premises:
Transportation, Purchasing, Receiving, Shipping, and Storage:
Equipment:
Personnel:
Sanitation and Pest Control:
|
Premises:
Recall:
|
Development of a scope when new HACCP Plans are submitted
In case of submission of new HACCP plans, the scope will be limited to the HACCP plan(s) submitted.
The CFIA team will perform task 4.1.03 - New HACCP Plan.
Development of a scope when follow-up is required after a food safety recall
In case of a follow-up after a food safety recall, the FSEP Specialist Inspector will determine which section(s) of the HACCP system must have resulted in a reassessment by the operator by:
- Considering the findings of the CFIA Lead Investigator on the IMS.
- Discussing the recall with Program Specialists, the responsible inspector and any other CFIA personnel who may have been involved in, or have knowledge of the recall.
- By reviewing any action plans submitted to the CFIA by the establishment.
Task 4.1.04 must be completed. The scope must include those HACCP plan(s)/CCP(s)/PC and prerequisite program(s) that the company was required to reassess and update as a result of the recall. The Recall program must be included in the scope of the verification to determine its effectiveness. CVS task 1.2.34 associated with the implementation of the recall program has to be completed by the CFIA team in conjunction with task 4.1.04.
Opening meeting with the operator representative(s)
During the opening meeting, the FSEP specialist inspector:
- introduces the members of the CFIA team to the operator representative(s);
- explains the purpose of the assessment of the HACCP system design and how it differs from the day-to-day verification that is done by the Inspector;
- finalizes the verification scope;
- obtains the applicable company's written prerequisite programs, HACCP plans and other related documentation; and
- confirms the expected duration of the verification according to the scope.
18.7.1.3 Preparation for Conducting Section 4 In-depth Review
Trigger for in-depth review
The Inspection Manager in consultation with the Regional Director and Area Program Specialists will determine if an in-depth review needs to be conducted at an establishment that is experiencing an extended period of non-compliance related to failure of microbiological performance standards and/or other CFIA pathogen control policy requirements.
In-depth review team
The in-depth review team may include but is not limited to:
- Responsible Veterinarian/Inspector of the establishment
- Supervisor Inspector
- Regional Veterinarian Officer
- Area/Regional FSEP Specialist (team leader)
- Area Program Specialist
Other experts from National or Area Programs/Operations/Science/Enforcement could be included in the in-depth review team, if deemed necessary for the situation.
Steps prior to conducting an in-depth review
Prior to conducting an in-depth review at the establishment, the CFIA team must:
- Review all relevant data and analyse the issues surrounding the trigger for the in-depth review. Relevant data may include:
- CVS documentation including worksheets, Inspection Report - CARs and operator root cause analysis and corrective action plans;
- Consumer complaints;
- Enforcement data; and
- CFIA and operator laboratory results.
- Provide the operator advance notice of the visit.
Opening meeting with the operator representative(s)
During the opening meeting, the FSEP specialist inspector:
- introduces the members of the CFIA team to the operator representative(s);
- explains the purpose of the in-depth review;
- discusses the scope of the in-depth review*;
- obtains the operator's written prerequisite programs, HACCP plans and other related documentation; and
- confirms the expected duration of the in-depth review.
* The scope of the in depth review is pre-determined by type of in-depth review task being conducted.
Important points to note:
- The results of the in-depth review are presented to the operator on an Inspection Report - CAR.
- The in-depth review Inspection Report - CAR is issued on the basis of the original non-compliance, For example, initial positive Listeria test result(s).
- The operator must re-evaluate existing action plans and then may revise and combine these in order to address all open Inspection Report - CARs related to the same non-compliance.
18.7.1.4 Preparation for Conducting Section 7 Verification Tasks
Inspectors must ensure that they have the necessary supplies, equipment and related training to collect the sample. Establishment processing schedules must also be considered to ensure samples are collected as close to scheduled dates as possible. In every case, the current sampling guidelines and applicable MOP sections are consulted.
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