Quality Management Program Plans And Corrective Action Plans
March 21, 2012
To: Federally Registered Fish Processing Establishments
Subject: Quality Management Program Plans And Corrective Action Plans
This notice updates the Quality Management Program (QMP) notice to industry of March 17, 2010, and is intended to remind operators of federally registered fish processing establishments of the importance of maintaining their QMP Plan as required by the Fish Inspection Regulations (FIR).
The Canadian Food Inspection Agency (CFIA) has almost fully implemented the updated approach to evaluate an establishment's QMP Plan's Prerequisite controls for construction and sanitation and to verify that they meet the requirements set out by the FIR. This approach provides the CFIA with the means to track the implementation of the corrective actions that are necessary to maintain compliance with the regulations. The CFIA has noted that industry has cooperated in completing the corrective actions that can be addressed quickly, and continues to work on long term corrective actions. The CFIA has agreed that fish processors can continue to operate while these long term corrective actions are addressed, as long as there is no impact on food safety.
An important element in achieving compliance with the regulatory standards is the verification and maintenance of the QMP plan and HACCP plan. Processors must verify that their QMP plan and HACCP plan accurately describe their products and process flow to ensure that these plans are effective in maintaining sanitary conditions for the production of safe, wholesome, and properly identified products. The QMP plan must be up to date, and provide a clear description of the controls that are followed at the establishment, the steps taken to monitor those controls, and a description of the corrective actions that will be taken if there is a loss in control. The HACCP plan must be complete and accurate, and correctly identify all hazards and critical control points in the production process, and must be accepted by a CFIA Inspector.
QMP plans are unique to each fish processor, and it is the responsibility of the fish processor to ensure that the QMP Plan is current and accurate. Guidance on how to create a Quality Management Program plan can be found on the CFIA website at http://www.inspection.gc.ca/english/fssa/fispoi/qual/guide/introe.shtml.
In addition to an acceptable QMP plan, the Corrective Action Plan (CAP) created in response to non-conformities identified during Compliance Verification inspections is an important tool for achieving regulatory compliance. A properly prepared CAP will ensure that interim measures re-establish control and that a root cause analysis identifies the problems that contributed to the loss of control. Furthermore, the CAP sets out the timelines for the activities that are necessary to maintain compliance. Fish processors are responsible for adhering to the activities and timelines outlined in their documented CAP. An acceptable CAP serves as a commitment from the regulated party to comply with the regulatory requirements.
Please note that the CFIA will initiate compliance and enforcement measures that may include suspension or revocation of the certificate of registration when operators of registered establishments fail to implement or maintain an acceptable QMP Plan, and any CAP that was developed as part of a CFIA Compliance Verification inspection.
The CFIA will continue to work with all regulated parties and will continue to conduct Compliance Verification inspections of fish establishments to confirm compliance with the conditions of registration provided by the FIR. Continued compliance with the FIR is essential to maintain your certificate of registration and is required to process fish for export. Establishments with a valid certificate of registration are considered by the CFIA to be in good standing with the requirements of the FIR, allowing the CFIA to provide such assurances to foreign government inspection services where required.
If you have any questions, please contact your local CFIA Office.
Fish, Seafood and Production Division
Canadian Food Inspection Agency
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