Chapter 18 - Compliance Verification System
18.4 Organization and Frequency of Verification Tasks

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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.

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