Chapter 18 - Compliance Verification System

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Table of Contents

List of Acronyms

CAR:
Inspection Report – Corrective Action Request
CCP:
Critical Control Point
CFIA:
Canadian Food Inspection Agency
CPLA:
Consumer Packaging and Labelling Act
CPLR:
Consumer Packaging and Labelling Regulations
CVS:
Compliance Verification System
FAD:
Foreign animal disease
FDA:
Food and Drugs Act
FDR:
Food and Drug Regulations
FSEP:
Food Safety Enhancement Program
HAA:
Health of Animals Act
HACCP:
Hazard Analysis Critical Control Point
HAR:
Health of Animals Regulations
IMS:
Issues Management System
MIA:
Meat Inspection Act
MIR:
Meat Inspection Regulations, 1990
MOP:
Meat Hygiene Manual of Procedures
MPIP:
Modernized Poultry Inspection Program
PC:
Process Control
RVO:
Regional Veterinary Officer
QMS:
Quality Management System
SRM:
Specified Risk Material
TB:
Tuberculosis
USA:
United States of America

18.1 Introduction

Compliance Verification System

This chapter outlines the procedures governing the Compliance Verification System (CVS) to be conducted in all federally registered meat and poultry establishments.

The CVS provides an efficient and uniform approach to verifying registered establishments compliance with regulations. The CVS includes verification tasks that are used by the Canadian Food Inspection Agency (CFIA) inspection staff to assess compliance to regulatory requirements. Each verification task includes detailed procedures for the inspection staff to follow when conducting verifications.

This chapter provides guidance on the verification task process as well as the reporting tools to be used in the implementation of the CVS. These tools allow data to be captured and analysed for:

  • patterns of compliance;
  • indications of systemic problems;
  • compliance with Canadian trading partner's regulations; and
  • uniformity of program delivery.

Verification of industry's compliance to regulations includes more than the verification tasks outlined in this chapter. Other verification activities conducted by CFIA staff are import inspection (Meat Hygiene Manual of Procedures [MOP] Chapter 10), export verification (MOP Chapter 11), complaint investigation and recall (CFIA Food Emergency Response).

Follow-up after a food safety recall and non-compliant situations identified through export verification, and complaint investigations by the CFIA will result in the completion of the corresponding verification task.

Compliance is normally achieved through a co-operative approach between the operator and the inspection staff. This approach generally involves the operator correcting instances of non-compliance through the development and implementation of action plans. When this co-operative approach is not successful, or when the operator is unwilling or unable to correct non-compliances, the CFIA pursues the enforcement options outlined in Chapter 14 of the MOP.

18.2 Roles and Responsibilities

18.2.1 Operator

The responsibilities of the operator are to:

  • Produce safe, wholesome, properly labelled product in compliance with the CFIA regulatory requirements i.e. applicable acts and regulations, Manual of Procedure, Meat Hygiene Directives, Food Safety Enhancement Program (FSEP) Manual and guidelines.
  • Establish and maintain the Hazard Analysis Critical Control Point (HACCP) system and HACCP records.
  • Identify and correct deviations in a timely and appropriate manner.
  • Develop and implement acceptable and effective action plans in response to non-compliances identified by the CFIA.
  • Correct items requiring correction as identified by the CFIA.
  • Provide written programs and records as requested by the CFIA.

18.2.2 Inspector

The responsibilities of the CFIA inspector are to:

  • Ensure all applicable verification tasks are assigned to the establishment as per section 18.6.
  • Conduct verification tasks according to the national frequency.
  • Take and document enforcement action(s) when necessary to protect public health, to protect consumers from fraud and to protect animal welfare or health as outlined in the MOP, Chapter 14.
  • Seek guidance and program clarification as required.
  • Communicate verification task results to the operator by issuing Verification Reports and Inspection Report - Corrective Action Requests (CAR) as defined in section 18.7.4.
  • Assess the operator's action plans submitted in response to CARs as per section 18.7.5.
  • Follow-up on items requiring correction that were identified on the Verification Report as per section 18.7.6.
  • Follow-up on operator's action plan implementation in response to CARs as per section 18.7.6.
  • Follow the regulatory enforcement actions and procedures as detailed in the MOP, Chapter 14.
  • Maintain documentation as defined in section 18.7.7.
  • Submit electronic information as defined in section 18.7.7.
  • Complete a Verification Task Comments Submission Form whenever the need for a change to a verification task is identified (see section 18.5).
  • Ensure their copy of Chapter 18 of the MOP (including task procedures) is current by incorporating the latest directives.
  • Review and update the on-line CVS Establishment Profile as per 18.6.
  • Notify the Supervisor via email that a profile is pending approval.

18.2.3 Supervisor

The responsibilities of the supervisor are to:

  • Schedule inspectors to ensure that all establishments are visited at the prescribed frequency and tasks are assessed at the prescribed frequency.
  • Review and approve or reject the on-line CVS Establishment Profile as per 18.6.
  • Notify the Responsible Inspector that the profile has been reviewed and approved or rejected.
  • Review CVS data reports to ensure awareness of trends and to identify potential areas of concern. For example: non-compliance that has not been corrected by the date specified by the inspector; repetitive situations of non-compliance; no identified non-compliance for long periods of time; task delivery ratesetc.
  • When concerns are identified as a result of reviewing the CVS data reports, follow up with the inspector to gather information.
  • Communicate follow up findings, including justification and rationale up through the management chain of command to the Area Executive Director.
  • Provide support to inspection staff in relation to program or policy clarifications.
    • Questions related to CVS and the verification tasks are forwarded to the Area CVS Coordinator.
    • Questions related to program or policy issues are forwarded to the Operations Specialists.
  • Select and conduct verification tasks CVS according to the verification process, as an inspector, when necessary.
    • Provide support to inspection staff in relation to situations of non compliance or enforcement.
    • Complete a Verification Task Comments Submission Form whenever the need for a change to a verification task is identified (see section 18.5).

18.2.4 Regional Veterinary Officer (RVO)

The responsibilities of the RVO are to:

  • Provide supervisory and/or technical oversight at federally registered slaughter establishments.
  • Provide support to inspection staff in relation to program or policy clarifications.
  • Provide support to inspection staff in relation to situations of non compliance or enforcement.
  • Within the CVS, anywhere there exists a "supervisory" responsibility, the RVO may fulfill that role as related to slaughter or veterinary specific activities.
    • This includes selecting and conducting verification tasks according to the CVS verification process, as an inspector, when necessary.
    • This also includes reviewing and approving or rejecting the on-line Establishment profile as per 18.6.

18.2.5 Area CVS Coordinator

The responsibilities of the Area CVS Coordinator are to:

  • Support the delivery of CVS in their area.
  • Respond to issues/questions about CVS and the verification tasks from area operations staff and management. If clarification is required, seek advice from the Operations Specialists, the Area Food Safety Enhancement Program (FSEP) Coordinator and the National CVS Coordinator.
  • Review with Operations Specialists proposed revisions, additions or deletions to the verification tasks received from Inspectors and Supervisors. Forward proposed revisions, additions or deletions to the National CVS Coordinator for review and acceptance.

18.2.6 Area FSEP Coordinator

The responsibilities of the Area FSEP Coordinator are to:

  • Respond to FSEP issues/questions about verification tasks from the Area CVS Coordinator and Operations staff.
  • Complete a Verification Task Comments Submission Form whenever the need for a change to a verification task is identified (see section 18.5). This form is forwarded to the Area CVS Coordinator for review and consideration.
  • Participate, as required in the completion of the Section 4 verification tasks.

18.2.7 Operations Specialists

The responsibilities of the Operations Specialists are to:

  • Respond to meat program issues/questions related to verification tasks from the Area CVS Coordinator and operations staff.
  • Provide support to the Area CVS Coordinator and operations staff as required.
  • Complete a Verification Task Comments Submission Form whenever the need for change to a verification task is identified (see section 18.5).
  • Participate, as required, in the completion of the Section 4 verification tasks.

18.2.8 National Program Specialists

The responsibilities of the National Program Specialists are to:

  • Respond to issues/questions about verification tasks from the National CVS Coordinator and Operations Specialists.
  • Propose revisions, additions or deletions to the verification tasks as required when amendments are made to the Meat Inspection Act (MIA), Meat Inspection Regulations, 1990 (MIR), MOP, FSEP Manual and other applicable acts and regulations. Forward proposed revisions to the National CVS Coordinator for review and acceptance.
  • Ensure that directives amending the MIA, MIR, MOP or FSEP Manual include the required changes to the verification tasks.

18.2.9 National CVS Coordinator

The responsibilities of the National CVS Coordinator are to:

  • Respond to issues/questions about CVS and verification tasks from the Area CVS Coordinators or Program and Operations staff or managers.
  • Accept or suggest revisions to the verification tasks received from the Program and Operations Specialists or Area CVS Coordinators.
  • Review, in consultation with the National Program Specialist, the national frequency for verification tasks at least annually and adjust as required.

18.2.10 Inspection Managers and Regional Directors

The responsibilities of Inspection Managers and Regional Directors are to:

  • Review CVS data reports to ensure awareness of trends and to identify potential areas of concern. For example: non-compliance that has not been corrected by the date specified by the inspector; repetitive situations of non-compliance; no identified non-compliance for long periods of time; task delivery rates etc.
  • When concerns are identified as a result of reviewing the CVS data reports, follow up with inspection staff to gather information.
  • Communicate follow up findings, including justification and rationale up through the management chain of command to Area Executive Director

18.3 This section is reserved for future use

18.4 Organization and Frequency of Verification Tasks

Task Numbering

Each verification task is assigned a number. This number represents the section, sub-section, and sequential task number. The first part of the task number indicates the section, the second part indicates the sub-section, and the last part of the task number represents the sequential task number.

For example:

Task # 2.2.02 is in Section 2: Labelling and Other Domestic Requirements; sub-section 2: CFIA Stations and Facilities; and is the second task in this sub-section.

Task #3.1.02 is in Section 3: Export; sub-section 1: Export USA; and is the second task in this sub-section.

Each verification task is assigned a minimum frequency. These frequencies are determined considering the:

  • impact on food safety;
  • FSEP manual guidelines;
  • type of control measures identified at the establishment;
  • regulatory requirements;
  • export requirements; and
  • state of compliance of the industry as a whole.

The "Verification Task Procedures" provide the procedures for each verification task. Each verification task procedure includes the following information:

  • section and sub-section;
  • task number;
  • task title that summarizes the task;
  • minimum frequency;
  • the date the task was last revised;
  • references to the MIA, MIR and other applicable regulations;
  • provisions of the MIA & MIR subject to Administrative Monetary Penalties;
  • the procedure to follow when completing each task to ensure the uniformity of application across the country; each verification task procedure includes:
    • the requirements being assessed by each task;
    • how the inspector must assess the operator's compliance to requirements; and
    • references to the MOP.

18.4.1 Section 1: HACCP System Implementation and Specific Control Programs

The following sub-sections include verification tasks related to HACCP system implementation and specific control programs required in the Meat Hygiene Manual of Procedures.

  • Sub-section 1: Specific Control Measures for Product Safety

    The control measure verification tasks are designed to assess the implementation and effectiveness of the operator's HACCP system to meet regulatory requirements. The tasks include: reviewing the written procedure and the records, interviewing, and observing the written procedures being implemented.

    The tasks in this sub-section may include operator identified Critical Control Points (CCPs) or other specific control measures recognized by the CFIA. In the case where operator identified CCPs or other control measures are covered by another verification task in section 1 – sub-sections 2, 3 or 5, that CCP or control measure must be verified under that specific task instead of a sub-section 1 task.

  • Sub-section 2: Prerequisite Programs

    The prerequisite verification tasks are designed to assess the implementation and effectiveness of the operator's prerequisite programs to meet regulatory requirements. The tasks include: reviewing the selected written prerequisite control program and records, interviewing, and observing the procedures being implemented.

  • Sub-section 3: Slaughter/Processing Requirements & Control Programs

    These verification tasks are designed to assess the implementation and effectiveness of the operator's control programs, as well as compliance with other regulatory requirements related to slaughter and processing operations. The tasks include: reviewing any written control programs, reviewing records, directly observing and interviewing to determine if the regulatory requirements are met and the control programs are implemented effectively as described.

  • Sub-section 4: Current Issues

    The current issues verification tasks will be developed as required. Tasks may be developed in the following situations:

    • extraordinary requests from the President of the CFIA;
    • need for data collection on a specific subject of interest; and
    • survey to Industry.
  • Sub-section 5: Process Controls

    These verification tasks are designed to assess the implementation and effectiveness of the operator's process controls. The tasks include: reviewing any written programs, reviewing records, conducting independent and correlation tests, directly observing and interviewing to determine if the regulatory requirements are met and the process controls are implemented effectively as described.

18.4.2 Section 2: Labelling and Other Domestic Requirements

The verification tasks included in this section are designed to assess compliance with labelling and other domestic regulatory requirement not covered under section 1.

Each of the following sub-sections includes verification tasks related to labelling and other domestic regulatory requirements.

  • Sub-section 1: Labelling
  • Sub-section 2: CFIA Stations and Facilities
  • Sub-section 3: Grading Program
  • Sub-section 4: Current Issues

18.4.3 Section 3: Export

The export verification tasks are designed to assess compliance with export requirements. The tasks include: directly observing if requirements are respected, reviewing any required written control programs, and reviewing records.

Each of the following sub-sections includes verification tasks related to export requirements.

  • Sub-section 1: Export USA
  • Sub-section 2: Export other than USA
  • Sub-section 3: Export All Countries
  • Sub-section 4: Current Issues

18.4.4 Section 4: HACCP System Design and In-Depth Review

The tasks included in section 4 are organized in 3 sub-sections:

  • Sub-section 1: HACCP System Design
  • Sub-section 2: In-depth Review
  • Sub-section 4: Current Issues

The goal of the HACCP system design tasks is to verify that the operator's HACCP system:

  • is designed to effectively control food safety hazards;
  • meets the FSEP and program requirements; and
  • is reassessed to ensure food safety hazards remain under control.

The HACCP system design tasks are conducted by a CFIA team that is led by an FSEP specialist inspector. The team includes the responsible veterinarian/inspector and if appropriate, a meat program specialist.

The HACCP system design tasks are performed once every two years and whenever the following situations occur:

  • submission of new HACCP plans;
  • follow-up after a food safety recall.

The HACCP system design tasks might also be performed on special occasions when the integrity of the HACCP system is compromised and support from an FSEP specialist inspector is requested. The supervisor will notify the Area CVS Coordinator of the need for immediate support. The Area CVS Coordinator will contact the Area FSEP Coordinator to evaluate the situation and, when deemed appropriate, provide the necessary support to the inspector.

The goal of the in-depth review tasks is to verify that the operator's HACCP system is designed and implemented so as to effectively control the risk associated with contamination by pathogens or other specific hazards. The in-depth review tasks are designed to focus on the hazard of concern. Out-of-scope inspection findings should be noted and verified at a subsequent visit.

The in-depth review team may include but is not limited to:

  • Area/Regional FSEP specialist (team leader)
  • Responsible veterinarian/inspector of the establishment
  • Supervisor inspector
  • Regional veterinarian officer
  • Area meat program specialist

The in-depth review tasks are conducted in these situations:

  • Repetitive unsatisfactory test results indicating there may be a health risk associated with a product, either distributed in the marketplace or not.
  • Where there is confirmed illness/death cases related to food.
  • During food safety investigations.
  • At the request of senior management.

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.

18.4.4.1 Submission of New HACCP Plans

When an establishment adds a new HACCP plan to its system, this must be communicated to the responsible inspector prior to the commencement of the new process. The CFIA may request a review of the new HACCP plan prior the commencement of the new process. The supervisor or responsible inspector must notify the Area FSEP coordinator of the submission of a new HACCP plan, as well as the Area CVS Coordinator. Task 4.1.03 must be carried out within 30 calendar days from the receipt of the new HACCP Plan. The new HACCP plan title must be recorded in the "Activities conducted to assess compliance" field of the verification worksheet CFIA/ACIA 5470 for tracking purpose.

18.4.4.2 Follow-up After a Food Safety Recall

The Office of Food Safety and Recall (OFSR) will send an e-mail notification to the Operations Strategy and Delivery - Domestic Inspection Division (OSD-DID) when a decision to request a food recall is made, including the associated Issues Management System (IMS) number. The date of the decision to request a recall will be captured in the IMS.

The OSD-DID will immediately send notification to the Area Operations Coordinators (AOC) in the applicable areas requesting that the process described below begins if the recalling establishment is a meat registered establishment. The related IMS number will be included in the notification to the AOC. The OSD-DID will track each process and verify that the timelines are met. Reminders will be sent to the AOCs as required.

The task 4.1.04 must be completed in conjunction with task 1.2.34 within 60 days of the date when the decision to request a recall (initial) was made. In situations where the food investigation continues after the initial recall and this results in additional (secondary) recalls being requested, the tasks must still be completed within 60 days of the date when the decision to request the initial recall was made. The 60 day timeline should be sufficient for the establishment to address the causes of the recall and update their HACCP system accordingly.

The purpose of the food safety investigation is to ensure that all aspects of the potential health and safety issue are addressed by the establishment, as per the guidance in the Food Investigation Response Manual.

The purpose of the HACCP system design verification is to ensure that the recalling establishment has reassessed the HACCP System and made the appropriate changes to prevent the recurrence of the deviation.

18.4.5 Section 5: Animal Welfare and Animal Health

The Animal Welfare and Animal Health verification tasks are designed to assess compliance with regulatory requirements. The tasks include: reviewing any written control programs, reviewing records, directly observing and interviewing to determine if the regulatory requirements are met and the control programs are implemented effectively as described.

Each of the following sub-sections includes verification tasks related to Animal Welfare and Animal Health.

  • Sub-section 1: Animal Welfare and Animal Health
  • Sub-section 4: Current Issues

18.4.6 Section 6: Miscellaneous

This section includes tasks that will be used by CFIA for other purposes than verifying operator's compliance to Acts and Regulations and assigning a compliance level. NO level of compliance "A" Acceptable or "U" Unacceptable is assigned as a result of the implementation of these tasks. The task is coded as per the task instructions. Sub-section 1 includes the forecasting task which is a tool for inspectors to get a global picture of the current processes in operation and the conditions of the building in order to make sure that the verification tasks are prioritized when situations that may impact food safety are observed or when situations indicate the operator's HACCP system may not be effective.

18.4.7 Section 7: Sampling

This section incorporates both Operator sampling activities and CFIA sampling activities. Operator sampling activities are based on policy requirements. Tasks that verify export sampling requirements are located under Section 3: Export.

18.4.7.1 Operator Sampling

Operator sampling tasks focus on elements of prescribed sampling programs. This includes verifying written plans, sampling activities, frequencies and results. Operators are required to notify the CFIA of non-compliant product and environmental results.

Based on the task guidance, if a CAR is issued there may be follow up sampling required. Follow up samples and results received must be documented on the follow up section of the CAR. Follow up sampling results do not require additional CARs to be issued.

The only exception is in the case where an operator notifies the CFIA of a positive Listeria environmental sample result. The inspector will issue a CAR under Task 7.1.02. According to the MOP Chapter 5, the operator must then conduct product sampling. Should that product sample test positive, the CFIA will issue the operator another CAR under Task 7.1.04.

This ensures the positive product sample is differentiated from the environmental sample in CVS. The action plan submitted by the operator can be the same action plan for both CARs provided it meets the requirements of an acceptable action plan and addresses both non-compliances.

18.4.7.2 Domestic & Import CFIA Sampling

These tasks encompass the scheduled domestic and import sampling plans conducted by CFIA inspectors in the field. It should be noted that these sampling tasks differ from other CVS tasks. The task rating is determined by the analysis result and not information gathered. In addition, there are no criteria to verify other than the sample collection. Each task will contain a certain amount of follow up guidance; however, in each case the MOP and current guidelines must always be consulted.

Domestic - Microbiological Sampling

In the case of domestic meat products sampled in accordance with the CFIA Microbiological Sampling Program, non-compliant or unsatisfactory product analysis results indicate that the operator does not meet the regulatory requirements related to the manufacturing of edible meat products.

Follow up samples that are related to an initial non-compliant or unsatisfactory result must be documented on the follow up section of the CAR. Non-compliant or unsatisfactory follow up sampling results do not require additional CARs to be issued.

The only exception is in the case where product samples are collected as a result of non-compliant environmental sampling results (Task 7.2.11). The product sample must be collected and documented on the verification worksheet under Task 7.2.01. If the product analysis result is non-compliant, another CAR is issued under Task 7.2.01.

This ensures the positive product sample is differentiated from the environmental sample in CVS. The action plan submitted by the operator can be the same action plan for both CARs provided it meets the requirements of an acceptable action plan and addresses both non-compliances.

Domestic - Chemical Sampling

These tasks are typically conducted at slaughter establishments. The tasks require that the task be coded "C" when completed, regardless of the analysis result. Unsatisfactory results are generally not a result of non-compliance by the operator and therefore do not result in the issuance of a CAR.

Import - Microbiological & Chemical Sampling

These tasks assess the compliance of imported products with Canadian standards. These tasks are coded "C" when completed, regardless of the analysis result. Unsatisfactory results are not a result of non-compliance by an operator and therefore do not result in the issuance of a CAR.

18.5 Amendments to Verification Tasks

A Verification Task Comment Submission Form must be completed and submitted to the Area CVS Coordinator when verification task procedures need to be revised or when a new verification task is requested. Reasons for amendments may include: a change in regulatory requirements, a change in importing countries requirements, clarification of policy, or suggestions from inspectors or program specialists to amend or reword a task.

The Verification Task Comment Submission Form is available through Desktop E-Forms (See section 18.8 - List of Forms). Instructions on how to complete the request are included with the form. The request on the Verification Task Comment Submission Form must:

  • reflect the approach and style established for the tasks;
  • support the common assessment for similar issues between groups/species; and
  • include accurate references to the MOP and appropriate act and regulations.

Only requests submitted on the Verification Task Comment Submission Form will be considered. The form must follow the identified distribution path. At each step the form is reviewed and adjusted as required. The distribution path for the form is as follows:

  • Forms initiated by Field staff are distributed from Field staff > Area CVS Coordinator > National CVS Coordinator
  • Forms initiated by Programs Network staff are distributed from Program Network Staff > National Program Specialist > National CVS Coordinator

At each step the form is reviewed and adjusted as required.

The Area CVS coordinator reviews the proposed revisions, additions or deletions to the verification tasks received from inspectors and supervisors with Area program specialists. The proposed revisions, additions or deletions are then forwarded to the National CVS Coordinator for review and acceptance.

Changes to the verification tasks will be made by the National CVS Coordinator in consultation with the National Program Specialist. Changes that coincide with amendments to the MOP and/or Acts and Regulations will be communicated via MOP directives. Inspectors must update their Chapter 18 accordingly.

18.6 Assignment of Verification Tasks to the Establishment

The inspector completes the Establishment Task Profile by selecting verification tasks that are applicable to the establishment. This information is entered into the CVS database by the Responsible Inspector.

The Establishment Task Profile template is available in the CVS application and will include all verification tasks that may be applicable to the Establishment.

The Establishment Task Profile is completed/reviewed by the inspector annually at the same time as the operator's licence is renewed. The Establishment Task Profile is also completed by the inspector when:

  • a new establishment begins operation;
  • operations change in an establishment;
  • the workshift agreement changes;
  • program requirements change which impact the establishment; and
  • verification tasks are amended which impact the establishment.

The Establishment Task Profile must be approved by the Supervisor prior to inclusion into the CVS data base. Note: The supervisor must review and approve or reject the changes within 30 days of the changes being submitted. It is important to note that after 30 days the profile will revert back to the original state and the pending changes will be lost.

The Task Tracking Table is used by inspection staff to track the delivery of the verification tasks at each establishment. The Task Tracking table includes:

  • the establishment number;
  • the task name;
  • the task number;
  • the task frequency; and
  • the field to enter the applicable rating or code when each task is completed.

Note: Inspectors must ensure that in the case where the operator identified CCPs or other control measures are covered by specific verification tasks, the related verification task is used to verify the process and not task 1.1.08 CCP (Generic) task.

18.6.1 Scheduling and Completion of Verification Tasks

See MOP Chapter 1, section 1.4.2 for specific information regarding the CFIA inspection frequency for slaughter activities, processing activities and storage activities.

Inspectors, Supervisors and Managers must ensure that verifications occur at varied times and proportionately cover all periods of production at the establishment. Certain verification activities will require the inspector to be present at the establishment during periods of non-production i.e. sanitation shifts, pre-operational inspections etc.

18.7 Verification Task Process

18.7.1 Step 1 - Preparation for the Verification

This section is divided in three components:

  • Preparation for conducting sections 1, 2, 3, 5 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 Verification Tasks

Prior to conducting a verification task, the inspector:

  • Determines which verification task to perform by:
    • Identifying tasks from the Task Tracking Table that are due to be completed according to the frequency.
    • Considering tasks to be prioritized as a result of the forecasting task (6.1.01).
    • Considering tasks to be prioritized as a result of unscheduled verification findings (stumble on) identified during other CFIA verification activities (code 9010).
    • 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 cleaned in place 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 1Group 2Group 3

Premises:

  • A 4.1 Water/Ice/Steam Quality, Protection and Supply

Transportation, Purchasing, Receiving, Shipping and Storage:

  • B 2.1 Purchasing/Receiving/Shipping
  • B 2.2 Storage

Equipment:

  • C 1.2 Equipment Maintenance and Calibration

Personnel:

  • D 2.1 General Food Hygiene Program

Sanitation and Pest Control:

  • E 1.1 Sanitation Program

Operational Prerequisite Programs:

  • G.1.1 Allergen Control Program
  • G.1.2 Food Additives and Nutrients
  • G.1.3 Food Processing Aids
  • G.2.1 Foreign Material Control Program

Recall:

  • F.1.2 Product Coding and Labelling

Premises:

  • A 2.1 Building design, Construction and Maintenance
  • A 2.2 Lighting
  • A 2.3 Ventilation
  • A 2.4 Waste and Inedible/Food Waste Disposal
  • A.3.2 Hand washing Stations & Sanitizing Installations

Transportation, Purchasing, Receiving, Shipping, and Storage:

  • B 1.1 Food Carriers

Equipment:

  • C 1.1 Design and Installation

Personnel:

  • D 1.1 General Food Hygiene Training Program
  • D.1.2 Technical Training

Sanitation and Pest Control:

  • E 2.1 Pest Control Program

Premises:

  • A 1.1 Outside Property
  • A 3.1 Employees' Facilities

Recall:

  • F 1.1 Recall Plan
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

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 reviewFootnote 1;
  • obtains the operator's written prerequisite programs, HACCP plans and other related documentation; and
  • confirms the expected duration of the in-depth review.

Important points to note:

  • The results of the in-depth review are presented to the operator on an Inspection Report - CAR.
  • 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.

18.7.2 Step 2 - Gather Information to Determine Compliance

18.7.2.1 Gathering Information to Determine Compliance

The "Verification Task Procedures" detail how to gather information to determine compliance for each task.

The tasks permit a thorough, in-depth evaluation of the operator's compliance to regulations including implementation of their HACCP system within a limited time frame.

Inspectors are to seek guidance and program clarifications as required.

Using the task procedure, inspectors will collect information by:

  • observing procedures being implemented using the written program as a reference (e.g. watching employees at work, watching employees taking measurements etc.);
  • inspecting (e.g. evaluating equipment cleaning or building maintenance);
  • interviewing/questioning designated employees using the written program as a reference; and
  • reviewing documentation (e.g. HACCP system written programs and records).

When using the operator's written program as a reference, the inspector should be concerned with the following:

Note: The operator's written program can be any document that the operator uses to record an instruction, process or procedure. For example, it could be Standard Operating Procedures (SOPs), Facility Manuals, Training Material, Prerequisite Programs, HACCP Plans etc.

  1. written program(s) that do not meet regulatory requirements;
  2. incomplete finding(s) that affect the integrity and effectiveness of the operator's written program; and
  3. incomplete finding(s) which results in situations in which potential hazards are not controlled.

The situations listed above are considered deviations that affect the integrity of the HACCP System; therefore the inspector must rate the associated task "U" and issue a CAR. The inspector can always ask for support from the FSEP Specialist before rating the task "U" or prior to the follow-up of the action plan. The inspector must not wait for the Section 4 Verification Tasks to identify these types of deviations.

If the integrity of the entire HACCP system is compromised, the inspector must contact the Area CVS coordinator who will evaluate the situation and provide the necessary support to the inspector.

Inspectors are to review the operator's written program and records at the establishment. Inspectors may obtain photocopies of these documents when the inspector believes, on reasonable grounds, that the documents are directly related to non-compliance with the MIA, MIR or other applicable legislation.

Records will be examined for completeness and accuracy. It is not necessary to examine all the documentation that is available; a sample of the records produced since the last verification shall be taken for review. If any significant deviations or problems are encountered, the inspector must expand the record review to determine the extent of the problem.

If the inspector encounters a situation where the operator is unwilling or unable to take action to protect public health, protect consumers from fraud or protect animal welfare or health, the inspector must initiate actions to control the situation (See MOP Chapter 14).

18.7.2.2 Unscheduled Verification Findings (Stumble On)

When conducting a task or other inspection activity, if the inspector identifies a deficiency that is not related to the current verification activity (a stumble on), the following actions must be initiated:

  • The inspector verbally notifies the operator of the deficiency.
  • The inspector is responsible for taking enforcement action(s) when necessary to protect public health, to protect consumers from fraud and to protect animal welfare or health. Any time an inspector is required to take control of such a situation, a CAR must be issued.
  • If the deficiency requires immediate enforcement action(s) to be taken by the CFIA, the inspector adds the verification task related to the deficiency to the scope of the current verification activity and completes only the applicable sections of the task related to the deficiency including record review.

Note: The entire task must be conducted at the required frequency at a subsequent visit to the establishment.

  • If the deficiency does not require immediate enforcement action(s) to be taken by the CFIA, the inspector considers selecting the task related to the deficiency at a subsequent visit to the establishment. If so, the responsible inspector must use the code 9010 and note on the verification worksheet CFIA/ACIA 5470 in the "Activities conducted to assess compliance" that this task must be completed at a subsequent visit.

When a stumble on finding is identified during the section 4 tasks, the following actions should be initiated:

  • The FSEP specialist inspector verbally notifies the operator of the deficiency.
  • If the deficiency does not require immediate enforcement action(s) to be taken by the CFIA, the FSEP specialist inspector considers whether the task related to the deficiency should be conducted by the responsible inspector at a subsequent visit to the establishment. If so, the responsible inspector or the FSEP Specialist inspector must use the code 9010 and note on the verification worksheet CFIA/ACIA 5470 in the "Activities conducted to assess compliance" field that this task must be completed at a subsequent visit.
  • If the deficiency requires immediate enforcement action(s) to be taken by the CFIA, the team adds the operator's written program related to the deficiency to the scope of the verification. The team must assess if the written program is designed to effectively control the hazard.
    • If the written program is not designed to control the hazard, a Corrective Action Request is issued under the HACCP System Design task.
    • If the written program is designed to control the hazard but was not implemented correctly, a CAR must be issued by the inspector under the verification task related to the deficiency.

18.7.2.3 Identifying Non-Compliance that is Related to an Open CAR

Important: The guidance below is to be applied when the observed non-compliance directly relates to a non-compliance identified in an open CAR. If the observed non-compliance only relates to the same task associated with the CAR, but is not the same situation/type of non-compliance, the inspector must issue a separate CAR.

When a non-compliance is observed during completion of a regularly scheduled task or as a stumble-on and it is directly related to a non-compliance already identified in an open CAR, the inspector must consider:

  • Is there an immediate food safety risk?
  • Has the operator attempted to correct the problem and is in control of the situation?

Ultimately, the inspector must judge whether this situation demonstrates a loss of control by the operator.

If the operator is not in control, the inspector:

  • Takes immediate enforcement action as necessary, i.e. holds product or stops the process until control is restored by the operator.
  • Documents these actions/activities on the follow up section of the CAR. This will serve as information gathered to support the decision as to whether or not to close the CAR when the date for completion of corrective measures arrives.
  • Informs the operator immediately that this information will be documented on the CAR and will be considered to determine whether the CAR can be closed or not.
  • Enters a "U" on the worksheet and notes the original CAR number in the "items requiring correction" field on the Verification Worksheet. A new CAR is not generated, however, it may be necessary for the operator to amend their action plan. This will be discussed during the meeting with the operator. This information gathered will support the decision as to whether or not to close the CAR when the date for completion of corrective measures arrives.

If the operator is in control, the inspector:

  • Enters an "A" on the worksheet, where the task was being conducted as per the prescribed frequency.

For example:

  1. A CAR is issued as a result of non-compliance identified with the CCP cooking of bologna. The monitoring procedures and record keeping are not implemented as per the written CCP. One week later, the inspector notices, while talking with employees and checking records in the cooking room, the exact same non-compliance for the CCP cooking of wieners. The inspector must take immediate enforcement actions as necessary and document the non-compliance observed and, if applicable, the enforcement actions taken on the follow-up section of the open CAR. The inspector must enter a "U" on the worksheet for the related task and note the original CAR number in the "Items requiring correction" field on the verification worksheet.
  2. A CAR is issued as a result of non-compliance identified for detection of fecal contamination on offals. The following week, non-compliance is noted for the detection of fecal contamination on carcasses. Although it may be the same task related to the non-compliance (CCP task), it is necessary to issue a new CAR because these are not the same control points. The cause and corrective actions will be different.
  3. A CAR is issued as a result of a breakdown of the ventilation system which resulted in condensation above the product without appropriate action by the operator. The following week condensation is also present elsewhere in the plant but there is no immediate food safety risk. The operator has been able to demonstrate to the inspector that adequate measures to control and correct the issue have been taken. It is not necessary to document this information on the open CAR since the inspector considers that the operator is in control of the situation and there is no immediate risk to product safety.

Note: In slaughter establishments, the Veterinarian in Charge is responsible to review and sign the CAR.

18.7.2.4 Recording Information Gathered to Determine Compliance

The information gathered is recorded by the inspector/FSEP specialist inspector on two worksheets:

Notes made on the worksheets must be clear, concise and accurately reflect the conditions observed or an answer to a question. As the completed worksheets are part of the CVS file, subjective comments, personal opinions, etc. are inappropriate.

The worksheets are available through Desktop eForms (See section 18.8 - List of forms). Detailed instructions are included with each worksheet and are available in two formats: as pop-up help (where help appears when you place the cursor over a field) and as a printable instruction page.

18.7.2.5 Verification Worksheet

The Verification Worksheet is completed by the inspector and is used to record:

  • establishment information and proof of daily presence;
  • verification task performed or applicable code;
  • activities conducted to assess compliance;
  • level of compliance (rating) or code assigned to each task; and
  • items requiring correction.

The Worksheet is completed each time the inspector or the CFIA team visits the establishment to do a verification task. The code 9012 must be recorded on the verification worksheet once every 12 hour period of production regardless of whether a compliance verification task was completed or not. The time in and time out (24 hour format) must be entered on the same line as the 9012 code.

Note: For Section 4 tasks, the inspector will not be required to describe the activities conducted to assess compliance on the verification worksheet as this information will be recorded on the HACCP System Design Verification Worksheet. If a section 4 task is assigned an Unacceptable level of compliance, the appropriate field of the Verification Worksheet will be completed to make reference to the CAR number.

The Worksheet is for use by the inspector only and not for presentation to the operator. Information related to items requiring correction will automatically populate the Verification Report which is then presented to the operator.

The following is a list of codes that are used when completing the Verification Worksheet.

Verification Task Codes
CodeVerification Task
E The inspector is unable to complete a task according to the prescribed frequency because the establishment/process was not operating. The inspector only assigns this code to the task when the frequency for the task has expired.
I The inspector is unable to complete a task according to the prescribed frequency for a reason other than the establishment/process was not operating. The inspector only assigns this code to the task when the frequency for the task has expired.
P Task started but not completed (rating is pending). This code is used when an Inspector begins a task and is unable to complete it during that visit. It is also used when a sample is submitted to a Lab and results are pending. When the results of the sample are received the inspector would make a new entry and apply the appropriate rating.
C Task was completed and rating is not required. This code is used when a task does not require a rating and applies to some current issue tasks that are in the form of a survey and certain sampling tasks such as import samples where a rating does not apply.
Activity Codes
Activity
code
Activity
9006 Establishment closed for the week
9008 Establishment is operating (meat operations) during the 12 hour period but NOT visited
9010 Unscheduled Verification Findings (Stumble On)
9011 Establishment is NOT operating (meat operations) during the 12 hour period and was NOT visited.
9012 Establishment is visited - proof of daily presence and administrative functions.

18.7.2.6 HACCP System Design Verification Worksheet

The HACCP System Design Verification Worksheet is used by the FSEP specialist inspector to record:

  • the activities conducted to assess compliance;
  • the HACCP system design verification scope;
  • the items requiring correction identified during the completion of the HACCP System Design Verification Tasks (see 18.7.4.2);
  • the level of compliance (rating) of the HACCP System Design Verification Tasks conducted; and
  • in-depth Review findings.

Note: When the HACCP System Design Verification Tasks are completed at an establishment, both the HACCP System Design Verification Worksheet and the Verification Worksheet must be completed.

18.7.3 Step 3 - Assign Compliance Level

Each task is assigned a level of compliance and rated accordingly. Based on the information gathered during the completion of a verification task, inspectors assign one of the following levels of compliance:

Acceptable level of compliance (task rated "A")
Unacceptable level of compliance (task rated "U")

18.7.3.1 Acceptable Level of Compliance (A)

The level of compliance is acceptable when the information gathered demonstrates:

  • There are no deviations that:
    • could cause or have caused product contamination or adulteration;
    • affect the integrity of the HACCP system or other control programs;
    • represent fraud;
    • affect animal welfare or health; and
    • contravene requirements related to CFIA Inspector facilities and/or stations.
  • There are no deviations to the applicable export requirements.

The inspector may identify minor items that have no impact on food safety and/or do not compromise the intent of applicable legislation. In this case, the level of compliance is still considered Acceptable and the task is rated "A".

Documentation of these items is required if there is an added value (i.e. the inspector determines that a follow-up is required and that keeping track of these items will demonstrate trends of non-compliance). These items are documented on the Verification Worksheet and presented to the operator in the Verification Report.

18.7.3.2 Unacceptable Level of Compliance (U)

The level of compliance is unacceptable when the information gathered demonstrates:

  • There are deviations to the applicable regulatory requirements or HACCP system that:
    • could cause or have caused product contamination or adulteration;
    • affect the integrity of the HACCP system or other control programs;
    • represent fraud;
    • affect animal welfare or health; and
    • contravene requirements related to CFIA Inspector facilities and/or stations.
  • Deviations to applicable export requirements.

Whenever a verification task is rated as "U"Footnote 2 a CAR must be issued as per section 18.7.4.3.

18.7.3.3 Guidance for Assigning a Level of Compliance

Inspectors must assess all of the information gathered prior to assigning a compliance level to a task. Every situation has to be assessed based on the context and using professional judgment to make compliance determinations.

Inspectors may want to ask themselves the following questions during the analysis of information gathered:

  • Is the situation a violation to a standard prescribed in the regulations? (E.g., microbiological standards, labelling standards, general standards related to control programs or HACCP system design.)
  • When the situation is linked to the HACCP system or other mandatory control programs:
    • Has the information gathered demonstrated that the HACCP system or the mandatory control program is not designed or maintained to control the hazards inherent in the establishment operations?
    • Will the situation result in the manufacture, storage or sale of a food product that may pose a risk to the consumer?
    • Have the operator's controls in place failed to identify the unsatisfactory situations observed during the verification? (Inspectors must use judgment with regards to isolated events)
    • If the operator's controls in place have identified the unsatisfactory situations, has the operator failed to implement effective corrective actions?
    • Is the situation generalized/recurrent?
  • Will the situation result in the marketing of a food product that leads the consumer to believe something about the product that is not true?
  • Is the situation a violation of an export requirement?
  • Does the situation result in cruel treatment of animals?
  • Will the situation directly affect control of animal health?

If the inspector answers yes to any or all of the questions above, the task should be rated unacceptable.

If the answer to all questions is no, the task should be rated acceptable. Documentation of the items observed is required if there is an added value (this means that the inspector determines that a follow-up is required and that keeping track of these items will demonstrate trends of non-compliance). These items are documented on the Verification Worksheet and presented to the operator in the Verification Report.

What is meant by "deviations that could cause product contamination or adulteration"?

The operator's HACCP system failed to identify and/or control a biological, chemical or physical hazard in a product or in an environment which may compromise the safety of the product being produced. For example:

  • employees in contact with product are not adhering to hygienic practices;
  • not doing a full clean up after processing products that contain allergens;
  • not controlling condensation on overhead structures in a processing area;
  • cross-contamination of raw and cooked products;
  • allowing inedible material to come in direct or indirect contact with edible product;
  • not controlling evisceration accidents resulting in contamination of equipment, employees and/or area;
  • floors and walls that cannot be adequately cleaned due to overcrowded conditions;
  • lighting that is not adequate to enable establishment employees to determine whether a substance on product is fecal material;
  • temperature abuse of product which could allow an increased bacterial load;
  • thermal process critical limit not met and no action taken by the operator; and
  • improperly labelling allergens.
What is meant by "product adulteration"?

As per the definition of "adulterated" in section 2(1) of the MIR:

"adulterated" means, in respect of a meat product intended for sale, use or consumption as an edible meat product in Canada,

  • (a) containing or having been treated with
    • (i) a pesticide, heavy metal, industrial pollutant, drug, medicament or any other substance in an amount that exceeds the maximum level of use prescribed by the Food and Drug Regulations,
    • (ii) an ingredient, a food additive or any source of ionizing radiation not permitted by or in an amount in excess of limits prescribed by these Regulations or by the Food and Drug Regulations,
    • (iii) any poison, decomposed substance or visible contamination, or
    • (iv) any pathogenic microorganism in excess of levels published in the Manual of Procedures.
What is meant by "compromises the integrity of the HACCP system"?

Deviations from the design or the implementation of the HACCP system which results in situations in which identified hazards are not controlled. For example:

  • The operator is not performing the monitoring and/or verification procedures at the frequencies specified in the CCP or prerequisite program which results in a loss of control of the identified hazard.
  • The operator is not conducting the monitoring and/or deviation procedures as specified in the CCP which results in a loss of control of the identified hazards.
  • The operator is following its written HACCP system but it is not effective to meet the regulatory requirements.
  • The operator is producing new products and the HACCP system has not been reassessed which results in situations in which hazards are not controlled.
What is meant by "compromises the integrity of other control programs"?

Deviations from the design or the implementation of a control program required as per the Meat Hygiene Manual of Procedures which results in situations in which potential hazards are not controlled or in deceiving consumers on the quality of a food product. For example:

  • The operator is not following its Boneless Meat written program which results in a loss of control of the quality of the food product.
  • The operator is not following the Modernized Poultry Inspection Program (MPIP) presentation control program which results in situations in which potential hazards are not controlled.
What is meant by "fraud"?

Violation of regulations which result in deceiving consumers on the nature, origin, quality or quantity of a food product. For example:

  • false labelling information;
  • AA meat packaged in boxes labelled AAA; and
  • pork and beef sausages labelled as all beef sausages.
What is meant by "affects animal welfare"?

Violation of regulations which result in:

  • inhumane treatment of animals in the yard/barn; and
  • inhumane stunning or bleeding of animals.
What is meant by "affects animal health"?

Related to ante-mortem inspection:

  • failure to segregate animals exhibiting signs of foreign animal disease (FAD) - for example in hogs, vesicular lesions on the snout; and
  • failure to train plant staff perform ante-mortem inspection or screening for possible FAD or zoonosis.

Related to livestock traceability:

  • failure to record and report any identification or tag numbers or animals coming through the premise (required under the National Identification Regulations of the Federal Health of Animals);
  • failure to keep records or respond to deviations in livestock identification and or Poultry Flock Sheets; and
  • failure to identify and keep records for vehicles used to transport animals.

Related to specified risk material (SRM):

  • failure to implement an effective program to exclude SRM from animal feeds, pet foods and fertilizers.

Related to biosecurity:

  • failure to ensure that poultry crates and transport vehicles are free of visible organic matter when leaving the establishment; and
  • failure to maintain a foreign animal disease contingency plan.

Related to special situation disease control or depopulation:

  • failure to comply with regulations when slaughtering animals under special order or licence (e.g. cervid slaughter, animals designated by animal health as "of concern", tuberculosis (TB) reactors); and
  • failure to identify those animals transported under permit or special Animal Health circumstance.
What is meant by "contravenes requirements related to CFIA Inspector facilities and/or stations"?

Deviations that result in:

  • occupational safety & health of inspectors being compromised;
  • ergonomic considerations being compromised;
  • impeded and unsafe access to travel from inspection stations to other areas of the establishment; and
  • failure to provide amenities as prescribed by the Meat Inspection Regulations, 1990 and detailed in the Meat Hygiene Manual of Procedures.

18.7.4 Step 4 - Communicate Results and Action Required

Results of the verification tasks are communicated to the operator through three documents:

Note: For the purpose of this chapter, the Inspection Report - Corrective Action Request will be referred to as a CAR.

These reports are available through Desktop eForms (See section 18.8 - List of forms). Detailed instructions are included with each form and are available in two formats: as pop-up help (where help appears when you place the cursor over a field) and as a printable instruction page.

These documents are presented to the operator in accordance with the following guidance:

18.7.4.1 Verification Report

The Verification Report is used to communicate any items requiring correction by the operator identified during the completion of the verification tasks (other than those deviations recorded on a CAR). All information that appears on the Verification Report is automatically populated from the data entered by the inspector on the Verification Worksheet.

The Verification Report must be issued to operators once per week even if no deficiencies have been identified.

The Verification Report is issued at least quarterly at storage establishments.

18.7.4.2 HACCP System Design Verification Report

The HACCP System Design Verification Report is used to communicate any deficiencies which were identified during the completion of the HACCP System Design Verification Tasks.

Note: When a task is rated U all items requiring correction must be entered on the Inspection Report - Corrective Action Request (CAR). The CAR is the only report issued to the operator.

18.7.4.3 Inspection Report - Corrective Action Request (CAR)

A CAR is issued to an operator by CFIA inspectors whenever a verification task is assigned an unacceptable level of compliance. The CAR identifies the non-compliance and requires the operator to implement corrective measures by:

  • providing an acceptable action plan by a specified date; and
  • effectively implementing the corrective and preventative measures as described in the action plan by a specified date.

The CAR also describes the information gathered during the follow-up inspection conducted after the date for completion of corrective measures specified on the CAR.

When non-compliance is identified, the inspector must prioritize their activities to ensure that immediate inspectional control is initiated and actions are taken as appropriate. It is the responsibility of the operator to implement temporary measures as necessary in order to meet the regulatory requirements prior to continuing the process/activity. The operator then must investigate the cause of the deviation and apply corrective actions to bring the control measure, CCP, prerequisite program or other regulatory requirement under control. These corrective actions must be implemented immediately (prior to action plan submission or request for a CAR review).

The inspector verbally informs the operator of his/her intention to issue a CAR as soon as the non-compliance is identified. The inspector must endeavour to issue the CAR as soon as possible, but no later than three (3) calendar days of completion of the task for which a non-compliance was identified. In the interim, if necessary, the immediate/short term measures still need to be implemented that will allow operations to resume. If the CAR is important enough to warrant immediate disposition of the product then the CAR should be presented to the operator on the same day that the non compliance is identified in order to track any follow-up inspections conducted by the CFIA on the acceptability of the product disposition.

The date specified by the inspector for completion of corrective measures must reflect the seriousness of the non-compliance. The maximum timelines for submission of an action plan and completion of corrective measures are only intended as a guide. In cases where food safety is compromised, a shorter timeline must be specified.

Note: In slaughter establishments, the Veterinarian in Charge or delegate is responsible to review and sign the CAR.

18.7.4.4 Guidance for the Description of the Non-compliance

The non-compliance must be described in clear, factual and concise terms. The description of the non-compliance includes two components:

Component 1:

The first shaded box in each task contains a statement. This statement describes what is being assessed when conducting the task. When non-compliance is identified, the statement is not being achieved; therefore the negative form of the statement is used as Component 1.

For example: In sub-section 1 control measure task 1.1.08, "The operator meets the regulatory requirements related to effectively implementing a HACCP Plan" is what is being assessed. If an Inspection Report - CAR must be issued under this task, Component 1 would state: "The operator does not meet the regulatory requirements related to effectively implementing a HACCP Plan".

Component 2:

Describe the deficiency in clear and factual terms that:

  • accurately reflect the deficiency identified;
  • do not offer solutions or opinions; and
  • are related to the task.

The description of deficiencies must:

  • Include what was observed, measured or obtained through interviews as they relate to the deficiency. Include where and when deficiencies were noted as well as the name or title of anyone interviewed.

    Such as, "May 10, 2007 10:45 am observed in the cutting room."

  • If deficiencies were noted during the record review, include a summary of the review related to the deficiency. Include the name and date of the records reviewed and the deficiency noted.

    Such as, "Reviewed the Cooking Reports for June 2007 and deviations were identified on June 5th, 6th, and 7th but the deviation procedures were not implemented ..."

  • If deficiencies were noted during written program review, include the name of the written program reviewed and the deficiencies noted.

    Such as, "HACCP plan X, CCP2B: Monitoring procedures do not meet FSEP Manual requirements. No frequency identified."

  • If the operator took control of product(s), animal(s) or thing(s), include a summary of the control and, if applicable, disposition of the affected product, animal or thing.
  • If the CFIA took action to control a product or thing, include a summary of the action. This action includes the application of a held tag, seizure and detention of a meat product or thing, refusal to certify a product for export or the initiation of a mandatory recall.
  • If there is a recently closed CAR related to this task with the same cause of the deviation, link this CAR to the closed CAR by referencing the number of the closed CAR on the new CAR and stating what corrective actions were implemented on the closed CAR, and that these actions were ineffective. The inspector should only link CARs when they were issued for the same task and the non-compliances are from the same cause.

Note: The purpose of linking CARs is to provide notification to the operator that the previous actions were ineffective in, or were not implemented in a way that is preventing the non-compliance from recurring, and that a similar action plan will not be accepted for this CAR.

18.7.4.5 Meeting with the Operator

The inspector will meet with the operator at least once a week to discuss findings and any CARs and/or the Verification Report. This meeting must occur at least quarterly in storage establishments. During meetings with the operator, the inspector must communicate in a clear professional manner. The operator may also want to share information or concerns at this time. In addition, the inspector and operator should discuss pertinent issues such as new policy changes, planned changes at the establishment, etc.

If a CAR was issued to the operator, the inspector:
  • discusses the non-compliance with the operator and clarifies any concerns or questions that the operator may have regarding the description of the non-compliance.
  • requests an acceptable action plan from the operator to respond to the non-compliance described in the CAR. The the action plan must include items described in section 18.7.5.1 of this chapter
  • specifies a date the operator is required to submit an acceptable action plan. The date specified by the inspector should reflect the seriousness of the non-compliance. The maximum time for an action plan to be submitted is 14 calendar days.

    Note: Some tasks have prescribed timelines for action plan submissions. e.g. 7.2.02 and 7.2.11

  • The action plan must be fully implemented by the date specified by the inspector. The date specified by the inspector should reflect the seriousness of the non-compliance. The maximum time for completion of corrective measures is 60 calendar days from the date the CAR is issued.
  • informs the operator that the action plan will be reviewed for acceptance by the CFIA. The CAR cannot be closed until the effectiveness of the corrective actions has been reviewed by the CFIA, which will occur on or after the date for completion of corrective measures specified on the CAR. (See section 18.7.6.2 Follow-Up on Non-compliance Identified on the CAR.)
  • informs the operator that a failure to implement corrective measures in relation to the non-compliance noted by the date specified in the CAR may result in the initiation of the process to suspend the operator's licence to operate pursuant to sub-section 29.2(1) of the Meat Inspection Regulations, 1990.
    • If the non-compliance is related to a MIA/MIR provision that is subject to Administrative Monetary Penalties (AMP), the inspector must inform the operator that a failure to implement corrective measures in relation to the non-compliance noted by the date specified in the CAR may result in the issuance of an AMP pursuant to s.7.(2) of the Agriculture and Agri-Food Administrative Monetary Penalties Act.
  • obtains the operator representative's signature on the CAR to indicate they were notified of the non-compliance(s) and they agree to provide an acceptable action plan and correct the deficiencies.

    If the operator refuses to sign the CAR, the inspector:

    • notes in the Description of Non-Compliance section of the CAR that the operator refused to sign the CAR, and that a copy was left with the operator representative's name and title;
    • informs the operator that they must follow Chapter 18, section 18.7.4.7 if they wish to request a review of the CAR; and
    • informs the operator that they are required to correct any deficiencies described on the CAR that have an immediate impact on food products, animal welfare, animal health or consumer protection while the CAR is subject to the review process.

    If the operator refuses to correct the deficiencies described on the CAR that have an immediate impact on food products, animal welfare, animal health or consumer protection, the inspector must take enforcement action as necessary and document the actions taken on the follow-up section of the CAR.

  • provides the operator representative with a copy of the CAR.
If a Verification Report is issued to the operator, the inspector:
  • discusses the items requiring correction listed on the Verification Report and the developing trends of non-compliance that those items indicate;
  • informs the operator that items requiring correction listed on the Verification Report require correction within 30 calendar days of the date the verification report was issued and that a failure to correct these deviations may result in the issuance of a CAR;
  • informs the operator that after 30 calendar days of the date the verification report was issued, the CFIA will follow up to verify the items requiring correction have been corrected;
  • obtains the operator representative's signature on the Verification Report to indicate they were notified of the items requiring correction and they agree to correct these items within 30 calendar days of the date the verification report was issued. If the operator fails to sign the report, the inspector notes on the report that the operator refused to sign the report and that a copy was left with operator representative's (name) and (title). The items still require correction and the inspector follows-up after 30 days; and
  • provides the operator representative with a copy of the Verification Report.

18.7.4.6 HACCP System Design Closing Meeting

The CFIA team responsible for verifying the design of the operator's HACCP system conducts a closing meeting with the operator's representative.

If a CAR was issued to the operator, the FSEP Specialist inspector:

  • discusses the non-compliance(s) with the operator and clarifies concerns or questions that the operator may have regarding the description of non-compliance;
  • requests an acceptable action plan from the operator to respond to the non-compliance described in the CAR. Informs the operator that the action plan:
    • must include items described in section 18.7.5.1 of this chapter; and
    • must be fully implemented by the date specified by the inspector. The timelines specified by the inspector should reflect the seriousness of the non-compliance and the time required to correct the non compliant section of the HACCP system. Due to the nature of HACCP System Design Tasks, CARs generated as a result may require a specified timeline for completion of corrective measures that is over 60 days;
  • specifies a date the operator is required to submit an acceptable action plan. The timelines specified by the inspector should reflect the seriousness of the non-compliance. The maximum time for an action plan to be submitted is 14 calendar days;
  • informs the operator that the action plan will be reviewed for acceptance by the CFIA. The CAR cannot be closed until the effectiveness of the corrective actions has been reviewed by the CFIA, which will occur on or after the date for completion of corrective measures specified on the CAR. (See section 18.7.6.2 Follow-Up on Non-compliance Identified on the CAR.)
  • informs the operator that a failure to implement corrective measures in relation to the non-compliance noted by the date specified in the CAR may result in the initiation of the process to suspend the operator's licence to operate pursuant to sub-section 29.2(1) of the Meat Inspection Regulations, 1990.
    • If the non-compliance is related to a MIA/MIR provision that is subject to Administrative Monetary Penalties (AMP), the inspector must inform the operator that a failure to implement corrective measures in relation to the non-compliance noted by the date specified in the CAR may result in the issuance of an AMP pursuant to s.7.(2) of the Agriculture and Agri-Food Administrative Monetary Penalties Act.

    If the operator refuses to sign the CAR, the inspector:

    • notes in the Description of Non-Compliance section of the CAR that the operator refused to sign the CAR, and that a copy was left with the operator representative's name and title;
    • informs the operator that they must follow Chapter 18, section 18.7.4.7 if they wish to request a review of the CAR; and
    • informs the operator that they are required to correct any immediate food safety deficiencies described on the CAR while the CAR is subject to the review process.

    Note: If the operator refuses to correct the immediate food safety deficiencies described on the CAR, the inspector must take enforcement action as necessary and document the actions taken on the follow-up section of the CAR.

  • provides the operator's representative with a copy of the CAR.
If a HACCP System Design Verification Report is issued to the operator, the FSEP specialist inspector:
  • discusses the items requiring correction listed on the report and the developing trends of non-compliance that those items indicate;
  • informs the operator that items requiring correction listed on the report require correction within 60 calendar days of the date the report was issued and that a failure to correct these items may result in the issuance of a CAR;
  • informs the operator that after 60 calendar days of the date the report was issued, the CFIA will follow-up to verify if the items requiring correction have been corrected;
  • obtains the operator representative's signature on the HACCP System Design Verification Report to indicate they were notified of the items requiring correction and they agree to correct these items within 60 calendar days of the date the report was issued. If the operator fails to sign the report, the inspector notes on the report that the operator refused to sign the report and that a copy was left with operator representative's name and title. The items still require correction and the inspector follows-up after 60 days; and
  • provides the operator's representative with a copy of the HACCP System Design Verification Report.

18.7.4.7 Request for Review of a CAR

An operator may request a review of a CAR before the date specified for the submission of an action plan. The operator must submit his / her reason for the request in writing, to the Area CVS Coordinator. The request for review must include a copy of the CAR as well as all relevant information that can be used by the Area CVS Coordinator to make a decision.

The operator is required to correct the deficiencies described on the CAR that have an immediate impact on food products, animal welfare, animal health or consumer protection, while a CAR is subjected to the review process. If the operator refuses to correct these deficiencies, the inspector must take enforcement actions.

When a request for review is submitted prior to the date for submission of an acceptable action plan, the operator will not be required to submit an action plan until the review results have been communicated to the operator and CFIA staff.

The Area CVS coordinator is responsible to:

  • review the request submitted by the operator;
  • contact the operator to confirm receipt of the request and, as required, to seek clarification or further information;
  • advise the responsible inspector and supervisor of the request;
  • seek expertise from programs or the National CVS Coordinator where necessary; and
  • make a final decision regarding the request.

A written decision is returned to the operator with a copy sent to the responsible inspector, supervisor and the Area Meat Programs Manager.

The inspector will describe in the follow-up section of the CAR any decision taken by the CFIA with regard to the review process. The CFIA written decision must be attached to the CAR.

If the decision is to uphold the CAR, the Area CVS Coordinator will assign a new due date for the submission of an acceptable action plan and/or completion of corrective measures if deemed appropriate. The operator must submit the action plan by the date specified.

If the decision is to overturn the CAR, the CAR will be cancelled (closed). The inspector must note in the follow up section of the CAR that the CAR was overturned as a result of a review by the CVS Area Coordinator.

18.7.5 Step 5 - Assessment of Operator's Action Plan

An acceptable action plan is to be submitted by the operator to the CFIA by the date specified when the CAR was issued.

The inspector who issued the CAR is responsible to review all written action plans submitted by the operator in response to the CAR within seven calendar days from the date the action plan was submitted by the operator. The date on which the inspector completes the review of the action plan must be entered in the follow up section of the CAR.

If the inspector is unable to review these action plans within the seven days, the inspector makes arrangements with the supervisor to assign this work to another inspector. The inspectors seek support from Supervisors, FSEP or Program Specialists if needed.

18.7.5.1 Acceptable Action Plan

During the course of reviewing an action plan, the responsible inspector must ensure that the criteria described below are met.

It is important to ensure that all immediate and short term actions taken in relation to affected or potentially affected product are described to the inspector's satisfaction.

It is normal for inspectors to question the root cause of a deviation or perhaps the validity of corrective and preventative measures. These concerns should be discussed with the establishment representative in a professional manner. Please note that "concerns" are not concrete facts and are not sufficient reason to consider the action plan as unacceptable.

Any concerns or doubt as to the action plan effectiveness will be confirmed by observable or measurable facts during the follow-up inspection. At this time, the inspector will have concrete information to support additional enforcement actions, if necessary.

An acceptable action plan must include:

Component 1 - Description of the problem

The objective is to accurately describe the problem, which will assist to identify the:

  • action to be taken on affected or potentially affected product, other things or animals;
  • immediate measures necessary to restore control of the deviation; and
  • root cause(s).

Establishments must collect information to find out the exact problem. One situation of non-compliance is typically the result of multiple problems or causes.

  • What is the non-compliance?
  • Did the problem affect product?
  • Where is the problem located?
  • How widespread is this problem?
  • Does the deficiency affect other areas of the facility or HACCP system?
  • When did the problem occur?
  • Who is involved in this problem?
  • Is this the first time the problem occurred?

Written Action Plan:

  • Describe the problem as it relates to the non-compliance noted on the CAR.
Component 2 - Person(s) responsible for measures

The objective is to determine the people who have the knowledge, time, authority and competence to correct the non-compliance.

Written Action Plan:

  • Identify the name or title of person(s) responsible for the immediate/short term and preventative measures.
Component 3 - Description of immediate /short term measures

The objectives are to:

  • control affected product or other thing(s); and
  • take immediate measures to restore control over the deviation so that food products are produced and/or animals are handled according to legislative requirements.

Written Action Plan:

  • Describe the measures taken on affected or potentially affected product, animals or other thing(s).
  • Describe the results of the assessment completed to determine if other products, animals or other things were implicated.
  • Describe the food safety assessment performed or to be performed on the affected or potentially affected product including any disposition of product.
  • Describe the immediate / short term measures taken to restore control over the deviation until permanent/preventative measures are planned and implemented.
  • Describe the procedure to verify the effectiveness of immediate/short term measures taken.
  • List records used to document the actions taken.

Note: Depending on the non-compliance, immediate measures may not be required.

Component 4 - Identification of root cause(s)

The objective is to identify the root cause(s) so establishments can form appropriate and comprehensive corrective measures that will prevent the recurrence of the deviation.

Start with the problem description.

  • Why has the CFIA found the deviation and not the establishment?
  • Identify all potential causes (Environment, Equipment, Personnel, Training, Written Programs, etc.).
  • Some causes have already been corrected by immediate measures.
  • Identify the root cause(s).

Written Action Plan:

  • Describe root cause(s).
Component 5 - Description of preventative measures

The objective is to identify and implement corrective measures to eliminate the root cause(s) and prevent recurrence of the deviation.

Written Action Plan:

  • Describe the preventative measures.
  • Establish a date for completion of each planned preventative measures.
  • List records used to document the preventative measures taken.
Component 6 - Description of activities planned to verify the effectiveness of preventative measures

The objective is to provide feedback as to whether or not further adjustment is necessary.

The assessment is the application of temporary procedures, tests or other evaluations to determine the effectiveness of the measures taken to correct the problem.

Examples:

  • On-site assessment of corrective measures taken.
  • Ensuring that staff is adhering to new procedures/instructions by observing and interviewing them.
  • Temporarily increasing sampling.
  • Temporarily increasing monitoring procedures.

If the problem is not resolved:

  • Additional corrective measures are required.

Written Action Plan:

  • Describe the activities planned to verify the effectiveness of preventative measures.
  • Establish a date for completion.
  • List the records used to document the activity.

18.7.5.2 Notice of an Unacceptable Action Plan

When the action plan is first submitted, the inspector must discern if critical components of the plan are missing or if there are only minor details missing that need clarification. The inspector should work with the operator to clarify any minor details that are missing.

If this approach fails, or if critical components are missing, the inspector will issue the Notice of Unacceptable Action Plan to specify which part of the action plan is incomplete or unacceptable. The inspector must specify a date for submission of the amended action plan on the Notice. This date specified on the Notice of an Unacceptable Action Plan must respect the initial date for submission of an acceptable action plan specified on the CAR. In other words, the turn-around time for amending and re-submitting an action plan must be quick but reasonable and is at the discretion of the inspector.

If the amended action plan still does not contain all the components, or if the operator is unwilling to submit an acceptable action plan by the specified date, the inspector records the following information in the "follow-up inspection" part of the CAR:

  • A Notice of an Unacceptable Action Plan was issued on (date) and not all reasons identified on the notice have been addressed by the operator;

The inspector will then follow up on the specified date for completion of corrective measures. The information gathered during the follow up will determine whether the CAR can be closed or not.

The Notice of an unacceptable action plan is available through Desktop eForms (See section 18.8 - List of Forms). Detailed instructions are included with each form and are available in two formats: as pop-up help (where help appears when you place the cursor over a field) and as a printable instruction page.

18.7.5.3 Action Plan Extensions

The CFIA may grant an extension to the date for completion of corrective measures (the corrective actions and preventive measures outlined in the operator's action plan) under the following circumstances:

  • Food safety is not compromised.
  • The operator will not meet the specified date for completion of corrective actions due to reasons beyond its control.
  • The operator submits a written request for an extension before the specified date for completion of the action plan.
  • The written request includes the reason for the extension request and the proposed new completion date.

Note: All criteria must be met in order to qualify for an extension to the completion date.

If an action plan extension is requested by the operator, the inspector must attach the written request to the CAR and record the following information in the Follow-up page of the CAR:

  • If the extension was accepted or not by the CFIA.
  • The reasons for the refusal.
  • The new specified date the operator has committed to completion of the action plan.

The inspector must provide the operator's representative with a copy of the Follow-up page of the CAR.

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. The inspector will provide the operator with a copy of the updated Verification Report.

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 inspector will provide the operator with a copy of the updated Verification Report. 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 CFIA will follow up on the resolution of any non-compliance identified on the CAR as soon as possible after the non-compliance has been corrected by the Operator but no later than 30 calendar days after the specified date of completion of corrective measures.

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. Stumble upon non-compliances that are not related to the CAR cannot be documented in the follow-up section of the CAR under review. In this case a new CAR must be issued.

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 action plan was not implemented as written and that the corrective and preventative measures were not effective, 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. The information must include a list of the items that were not adequately corrected by the operator. 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.The operator must be informed of the next step that will be taken by the CFIA.

18.7.7 Step 7 - File Maintenance

Depending on the type of document, the following records are to be maintained either electronically or in hard copy at the establishment.

Note: A document is a record. Records may be stored electronically or in paper form (hard copy) with the exception of those that bear signatures. Hard copies must be kept of records that bear signatures. Electronic records must be accessible to all staff that may require access (stored in RDIMS or on a shared drive with appropriate access rights).

Document How long to retain a copy of each document
Establishment Task Profile 2 years
Task Tracking Table 2 years
Verification Worksheet 2 years
HACCP System Design Verification Worksheet 2 years
Verification Report (with original signatures) 10 years
HACCP System Design Verification Report (with original signatures) 10 years
CAR including all follow-ups, regulated party's action plan(s) and, if applicable, a Notice of Unacceptable Action Plan (with original signatures) 10 years

An electronic copy of the following documents is to be emailed to the CVS Collector. Data from these documents is entered into the CVS database.

DocumentWhen to email the document
Verification Worksheet Verification worksheets must be submitted no later than one (1) week after the date of completion. The only exception is storages, where the worksheet may be submitted quarterly.
CAR including any Notice of Unacceptable Action Plan When the CAR is first issued and once the CAR is closed

18.8 List of Forms

The table below lists all forms used during the completion and maintenance of verification tasks. Official documents described by this table can be accessed through your local CFIA inspector, veterinarian or CVS Coordinator.

Name of FormUsePlatformForm #
Verification Task Procedures Provides detailed procedures on how to perform each verification task. Microsoft Word Not applicable
Verification Task Comment Submission Form Used to submit proposals to create a new task or change the content or wording of an existing task. Desktop eForms CFIA/ACIA 5523
Establishment Task Profile Used by the inspector to assign verification tasks to an establishment. CVS Online Application Not applicable
Task Tracking Table Used by inspection staff in each establishment to track completion of the verification tasks. Excel Not applicable
Verification Worksheet Used by the inspection staff to track verification results and daily presence and populates the information that appears on the Verification Report Desktop eForms CFIA/ACIA 5470
HACCP System Design Verification worksheet Used by inspection staff to record any items requiring correction and any incomplete written program(s) identified during the completion of the HACCP System Design Tasks. Populates the information that appears on the HACCP System Design Report. Desktop eForms CFIA/ACIA 5522
Verification Report Presented to the operator to communicate non-compliances not noted on a CAR. Desktop eForms CFIA/ACIA 5470
HACCP System Design Verification Report Presented to the operator to communicate any items requiring correction related to a CAR. Desktop eForms CFIA/ACIA 5522
Inspection Report - Corrective Action Request (CAR) Issued to the operator each time a task assigned an Unacceptable level of compliance. Desktop eForms CFIA/ACIA 5472
Notice of an unacceptable action plan Issued as a notice to the operator when an Action Plan is not acceptable. Desktop eForms CFIA/ACIA 5472
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