Imported and Manufactured Food Program Inspection Manual
Chapter 1: Introduction
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Chapter 1 of the Inspection Manual describes the scope and activities of the Imported and Manufactured Food Program (IMFP) and outlines the roles and responsibilities of the CFIA and other government departments involved in the regulation of food. The responsibilities of the food industry with respect to food safety are also outlined here.
1.1 The Imported and Manufactured Food Program
The focus of the Imported and Manufactured Food Program (IMFP) is the non-federally registered sector (NFRS) which represents approximately 70 per cent of food products available for sale in Canada. The regulatory authority for the IMFP is derived from the Food and Drugs Act, the Food and Drug Regulations, the Consumer Packaging and Labelling Act and Regulations and the Organic Regulations under the Canada Agricultural Products Act.
There are several large general categories of food that fall under the exclusive jurisdiction of the IMFP. These for the most part include, but are not limited to:
- Grains and grain-based products such as breads, biscuits, pastas and cereals, rice
- Bakery products such as cookies, crackers, muffins and cakes
- Most beverages including tea, coffee, most carbonated drinks, pre-packaged water and alcoholic beverages, juice blends/cocktails
- Snack foods that do not contain fish and/or contain less than 2 per cent meat
- Food chemicals, such as additives and colours, vitamins and minerals
- Biological additives, such as bakers' and brewers' yeasts
- Spices, seasonings, salt and dried herbs
- Vegetable fats and oils
- Infant formula, meal replacements and formulated liquid diets
- All retail-prepared food, such as meat that is cut and packaged at retail, or items that are manufactured and sold at retail (e.g. baked goods produced by in-store bakeries)
- Intra-provincially traded foodFootnote 1
To facilitate decision-making regarding the jurisdiction of a food product, the Imported and Manufactured Food Division (IMFD) developed and published Products Regulated under the Imported and Manufactured Food Program (This document is intended for internal use. CFIA staff can access this document using RDIMS number 2580416). This document is intended as a guide for use by all CFIA personnel, including inspectors and program officers, to determine which products are within the jurisdiction of the Imported and Manufactured Food Program.
1.1.1 Activities of the IMFP
The IMFP contributes to food safety and consumer protection through the administration of a national food program for non-federally registered foods at all levels of trade. This includes domestic manufacturers, importers, and distributors as well as retailers who manufacture/package foods on-site. The program is based upon the safety, nutrition, composition and labelling provisions of the federal FDA/R and the CPLA/R and the organic requirements in the CAPA/R. Some of the Program's activities include:
- Designing and developing a food safety control program which encompasses assessment standards, verification procedures and training.
- Compliance verification and enforcement actions related to food safety, labelling and fraud.
- Developing and implementing policies and procedures for the non-federally registered sector.
- Liaising with the provinces, territories and foreign governments to facilitate the formation of MOUs and other agreements
- Providing input into legislative changes aimed at strengthening Canada's food safety system.
The Risk Pathway Decision Model (as seen above) outlines some of the activities carried out by the IMFP. While the Food Safety Division (FSD) is primarily responsible for phases 1, 2 and 3 of this model (risk identification, risk mitigation and gap analysis), the IMFP may collaborate with the FSD to conduct activities under these phases. Based on the results of these first three phases, the IMFP will develop risk management options which may include inspection and sampling strategies and development of policies, procedures, and standards. The effectiveness of the risk management options will be assessed and the activities will be redesigned or retired as required.
As a means to facilitate and standardize establishment inspections, the IMFP developed two voluntary Codes of Practice – General Principles of Food Hygiene, Composition and Labelling (GPFHCL) and Good Importing Practices for Food (GIP). These Codes of Practice provide guidance to inspectors in assessing an establishment's compliance with the regulatory provisions. In addition, they serve as voluntary guidelines to the food industry in Canada for good manufacturing and importing practices.
As an on-going risk management strategy, the IMFP develops work specifications to target commodities and hazards that pose the highest potential risk to public health and safety. Work specifications are designed to provide commodity-specific inspection and sampling guidelines for inspectors.
1.2 Roles and Responsibilities
- 1.2.1 The Canadian Food Inspection Agency
- 1.2.2 Health Canada
- 1.2.3 The Public Health Agency of Canada
- 1.2.4 The Canada Border Services Agency
- 1.2.5 Provincial/Territorial/Municipal Governments
- 1.2.6 Industry
The CFIA delivers its mandate in many areas of shared jurisdiction and responsibility. Strong partnerships with other federal government departments, as well as provincial, territorial and municipal authorities are imperative to the Program's success. Specifically, in the area of food safety, Health Canada and the CFIA share unique and complementary roles and responsibilities. Health Canada is responsible for food safety policies, standards and regulations, while the CFIA is responsible for all food inspection activities, as well as the development of regulations and policies related to food labelling and compositional standards.
1.2.1 The Canadian Food Inspection Agency
The Canadian Food Inspection Agency (CFIA) is mandated to safeguard Canada's food supply and the plants and animals upon which safe and high quality food depends. In carrying out its mandate, it provides all federal inspection services related to food safety, economic fraud, trade-related requirements, and animal and plant health programs. The consolidation of responsibilities into a single agency was designed to enhance food safety systems by integrating the delivery of inspection and quarantine services that had previously been provided by other departments such as Agriculture and Agri-Food Canada, Health Canada, and Fisheries and Oceans Canada.
The CFIA is responsible for the administration and/or enforcement of 13 federal acts and their respective regulations. In carrying out its food safety mandate, in particular, the CFIA enforces the FDA/R as it relates to food.
188.8.131.52 CFIA Inspectors
CFIA inspectors are tasked to deliver thorough, unbiased inspections in accordance with the established design of the program.
As a public servant, inspectors are responsible for respecting certain ethical guidelines designed to protect his or her reputation as an honest and impartial public service employee, and the image of the public service.
As an employee of the CFIA, inspectors are also expected to act in a reasonable manner that will not compromise his or her job or the Agency. They are expected to uphold the CFIA values.
1.2.2 Health Canada
Although Health Canada is no longer directly involved in the inspection of food, it has the responsibility of establishing national health, safety and nutritional standards for food, and for assessing the CFIA's food safety activities. Among other roles, the Health Products and Food Branch of Health Canada:
- Administers the food safety provisions of the FDA/R;
- Develops regulations and guidelines for food safety;
- Sets standards for food safety and nutritional content of food;
- Conducts health risk assessments and evaluations concerning physical, chemical and microbial contaminants, natural toxicants, food additives, allergens, etc.;
- Conducts safety assessments on novel and genetically modified food;
- Approves the use of food additives;
- Approves the use of veterinary drugs for food-producing animals and sets residue tolerances; and
- Serves as the national authority for food safety issues at the international level in the development of international standards, guidelines, recommendations, etc. (e.g. WHO, FAO, CODEX).
1.2.3 The Public Health Agency of Canada
The Public Health Agency of Canada (PHAC) mandate is focused on preventing chronic diseases, and responding to public health emergencies and infectious disease outbreaks in collaboration with the provinces and territories.
The PHAC maintains linkages with the CFIA during the course of a foodborne illness outbreak investigation, and advises the CFIA, upon confirmation, of the epidemiological link of an outbreak with a food product.
Information or intelligence shared by the PHAC with the CFIA may be used in developing risk management strategies, such as inspection and sampling programs, for targeting higher risk commodities.
1.2.4 The Canada Border Services Agency
The Canada Border Services Agency (CBSA) ensures the security and prosperity of Canada by managing the access of people and goods to and from Canada. CBSA officers are present at strategic border points and undertake activities to protect the safety of imported goods, including food.
The CFIA liaises with the CBSA during border blitzes and takes advantage of the CBSA border lookout process to identify high-risk goods as they enter the country. The two Agencies also share intelligence and information when developing risk management options to address specific situations.
1.2.5 Provincial/Territorial/Municipal Governments
Constitutionally, the Provinces and Territories have prime jurisdiction for foods manufactured and sold within their province/territory. However, given that the FDA/R and CPLA/R are federal in scope and that most of the provinces/territories do not have parallel legislative requirements, the CFIA and the provinces/territories share jurisdiction for the over-sight of the intra-provincial part of the non-federally registered sector. Hence, the IMFP often consults with its provincial and territorial counterparts as part of the design and development of risk management strategies.
Among the provinces and territories, different levels of food industry oversight exist due to differences in priorities, regulations and resource capacity. For example, some provinces and territories may require certain establishments (e.g., meat and dairy) to be registered provincially or territorially, while others carryout regular establishment inspections and sampling of specific, high risk commodities. Some territories or provinces may not have manufacturers or producers of particular commodities and consequently do not engage in oversight activities related to those commodities. In order to maximize resources, the CFIA focuses on areas where potential risk is high, and oversight is not available or limited at some or all levels of government.
The food industry plays an important role in safeguarding the Canadian food supply. In general, food establishments are responsible for:
- The safety and quality of food products offered for sale.
- Ensuring compliance of imported or manufactured food products with appropriate government regulations.
Industry is expected to develop and implement their own food safety control program or system (e.g., quality assurance system) to minimize the risk of exposure by consumers to products which may have health and safety implications. They are also encouraged to establish and implement their own internal audit program and self-monitor their food safety control system on an ongoing basis. Further, industry is expected to cooperate with the CFIA during inspections and other regulatory activities.
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