18.7.6 Step 6 - Follow-Up

Inspectors follow up on:

  • items requiring correction listed on the Verification Report; and
  • non-compliance identified on the CAR.

18.7.6.1 Follow-Up on Items Requiring Correction Listed on the Verification Report

The inspector who issued the Verification Report is responsible to follow up on the resolution of the items requiring correction that are identified on the Verification Report. If the inspector who issued the report is unable to complete the follow-up, the inspector makes arrangements with the supervisor to assign this work to another inspector.

When the verification report is issued, the operator has 30 calendar days to correct the item. The inspector may follow up at any time during that period, if the operator has corrected an item. After the 30 day period for correction is over, the inspector must ensure they complete follow up for every item within the next 30 calendar days. During the follow-up the inspector determines if the items were resolved by the operator.

To conduct the follow-up on items requiring correction listed on the Verification Report the inspector:

  • asks the operator what actions they took to resolve the items;
  • verifies that these actions were taken by the operator by observing, inspecting, interviewing or reviewing records; and
  • verifies that these actions were effective to correct the items.

The inspector will document what activities were conducted to follow up on the Verification Report. If it is determined that the item(s) requiring correction were resolved by the operator, the inspector conducting the follow up will choose the appropriate entry from the results field on the report and enter their name and the date of the follow up.

If the inspector determines that the item(s) requiring correction were not adequately resolved by the operator, the inspector conducting the follow up will choose the appropriate entry from the results field on the report and enter their name and the date of the follow up. The related task will be completed at a subsequent visit to the establishment. If at that time a similar non-compliance is identified, then a CAR may be issued.

Follow-Up for the HACCP System Design Verification Report

The FSEP Specialist inspector is responsible to follow up. If it is determined that the item(s) requiring correction were resolved, the FSEP specialist inspector will enter the date of the follow up on the HACCP system design verification report and initial to indicate that the corresponding item has been corrected.

If the FSEP specialist inspector determines that the item(s) requiring correction were not adequately resolved, he/she will record the following information in the description field on the appropriate page of the HACCP system design verification report: A follow-up verification was conducted on (specify date). The following items were not adequately corrected by the operator (list the items).

The FSEP specialist inspector will meet with the operator to discuss any remaining items requiring correction listed on the report.

Depending on the reason that the operator was unable to correct the identified items, the FSEP specialist inspector will determine if an extension can be granted or if a CAR should be issued due to senior management lack of commitment to their HACCP system. The maximum time for an extension is 30 calendar days.

18.7.6.2 Follow-Up on non-compliance identified on the CAR

The inspector who issued the CAR is responsible to follow up on the resolution of the non-compliance identified on the CAR within 30 calendar days of the specified date of the completion of the action plan. The FSEP specialist inspector issues and follows-up on CARs related to the HACCP system design tasks within 30 calendar days of the specified date of the completion of the action plan. If the inspector is unable to complete the follow-up inspection within the 30 days, the inspector makes arrangements with the supervisor to assign this work to another inspector. The inspector may follow up at any time before the date specified for completion of corrective measures, to determine if the operator is implementing the action plan as written.

If non-compliance is observed during the course of conducting follow up activities, please follow the guidance provided in 18.7.2.3. Only situations that directly relate to the original CAR and the related action plan should be documented as follow up information. In some cases, it may be necessary to issue a new CAR in order to ensure the operator fully addresses the problem with a new action plan.

In order to conduct a follow-up inspection on the non-compliance identified on the CAR and determine if the CAR can be closed, the inspector evaluates the following items:

  • The acceptability of the product disposition:
    • by reviewing and evaluating any records generated by the food safety assessment and product disposition.
  • The corrective actions taken to eliminate the cause:
    • by observing conditions at the establishment;
    • by reviewing any records generated by the corrective actions;
    • by reviewing any written programs amended as a result of the corrective actions;
    • by interviewing any affected personnel;
    • by ensuring that the actions and timelines defined in the action plan were respected; and
    • by reviewing any records generated by the verification of effectiveness of the corrective actions.

The inspector records the information gathered during the follow-up inspection in the "follow-up" section of the CAR. The information must include:

  • the date the follow-up inspection was conducted;
  • any disposition of product, if applicable;
  • the name and date of any records reviewed;
  • the name and date of any amended written programs reviewed;
  • the name or title of anyone interviewed; and
  • any conditions observed at the establishment.

If the inspector determines that the action plan was implemented as written and that the corrective and preventative measures were effective to prevent the recurrence of the deviation, the inspector completes the appropriate fields of the CAR and the CAR is closed. A copy of the closed CAR is provided to the operator.

If the inspector determines that the situation of non-compliance has not been corrected, the inspector records the information gathered which supports the decision for refusing to close the CAR in the follow-up section of the CAR and the CAR remains open. A copy of the follow-up section of the CAR is provided to the operator. The inspector initiates enforcement actions as per Chapter 14 of the MOP.

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