Regulatory requirements: Preventive control plan (PCP)

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, other requirements will be introduced in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

On this page

1.0 Introduction

A preventive control plan (PCP) is a written document that demonstrates how written hazards to your food are identified and prevented, eliminated or reduced to an acceptable level.

The PCP is based on the internationally accepted principles of Codex Alimentarius General Principles of Food Hygiene and includes elements relating to packaging, labelling, grading, standards of identity and food safety. There are also preventive controls relating to humane treatment of food animals from which meat products are derived that are aligned with the recommendations outlined in the World Organisation for Animal Health's Terrestrial Animal Health Code – Slaughter of Animals.

The following provides an overview of the regulatory requirements in Part 4, Division 6 – Preventive Control Plan of the SFCR.

For information on the preventive control requirements in Part 4, Divisions 1 to 5 of the SFCR, refer to the guidance material Regulatory requirements: Preventive controls.

2.0 Application of the PCP requirements

Safe Food for Canadians Regulations: Sections 86 to 88

Generally, you are required to prepare, keep, maintain and implement a PCP if you:

Keep in mind

It is important to refer to the Preventive control plan interactive tool to help you determine if you are required to have a written PCP and when you are required to have your plan implemented.

Note that certain food businesses may not be required to have a PCP, for example, if their annual gross food sales are $100,000 or less.

The content of your PCP depends on the activities you conduct. Refer to Table 1: PCP content based on activities that you conduct, to determine the sections of this document that apply to you.

If you conduct more than one activity, make sure you refer to all of the sections that apply to you.

Table 1: PCP content based on activities that you conduct

1. Make food for interprovincial trade
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You have a licence to manufacture, process, treat, preserve, grade, package or label of food for interprovincial trade
  • You grow or harvest fresh fruits or vegetables for interprovincial trade
  • 89(1)(a),(b) and (e)
  • 89(1)(c) and (e); 89(2)
2. Make food for export
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You have a licence to manufacture, process, treat, preserve, grade, package or label meat products or fish for export
  • You have a licence to manufacture, process, treat, preserve, grade, package or label food for export and would like to obtain an export certificate or other export permission from the CFIA
  • You grow or harvest fresh fruits or vegetables for export and would like to obtain an export certificate or other export permission from the CFIA.
  • 89(1)(a),(b) and (e)
  • 89(1)(c) and (e); 89(2)
3. Store and handle imported edible meat products
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You have a licence to store and handle an imported edible meat products for inspection by the CFIA
  • 89(1)(a)(b) and (e)
  • 89(1)(c) and (e); 89(2)
4. Slaughter
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You have a licence to slaughter food animals, other than game animals
  • 89(1)(c) and (e); 89(2)
  • 89(1)(d) and (e); 89(2)
  • You have a licence to slaughter game animals
  • 89(1)(c)(i); 89(2)
  • 89(1)(d)(i); 89(2)
5. Post-mortem programs
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You are licence holder and are authorized to conduct a post-mortem program
  • 89(1)(c) and (e); 89(2)
  • 89(6); 89(2)
6. Import
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You import food
  • 89(1)(a)(b) and (e)
  • 89(1)(c)(i), (vi) to (vii), (e), 89(2)
  • 89(4); 89(2)
7. Export (sole activity)
Activities Sections of this document that apply to you Corresponding provisions from the SFCR
  • You have a licence to export food and you would like to obtain an export certificate or other export permission from the CFIA
  • 89(1)(a),(b) and (e)
  • 89(1)(c)(i), (vi) to (vii), (e) and 89(2)
  • 89(1)(c)(ii) to (v) – with respect to the supplier's activities
  • 89(5); 89(2)

3.0 PCP content for consumer protection

Safe Food for Canadians Regulations: Paragraphs 89(1)(a), (b) and (e)

Rationale

Outlining the measures that you take to make sure that you comply with requirements such as grade, standard of identity and labelling, if applicable to your food business, allows you to demonstrate to the CFIA how you meet those specified requirements.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer ideas on what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Paragraphs 89(1)(a) and (e): PCP content for specified requirements

Keep in mind

  • If you intend to export food and the requirements of the destination country differ from the Canadian requirements listed in Table 2,
    • you can still export the food provided it meets the requirements of subsection 16(1), Part 2 – Trade, of the SFCR relating to the export of non-compliant food
    • you keep a document that describes the measures you take to meet their requirements
Example 1
  • Your written PCP describes the measures you take to make sure that the food meets the appropriate standard described in the Canadian Standards of Identity. These measures may include:
    • written procedures for the production or processing of your food that result in a product that complies with the applicable standard, such as
      • a current written formula that:
        • identifies all ingredients and components
        • specifies the quantity of each ingredient, including food additives and added nutrients (vitamins, mineral nutrients and amino acids)
        • includes only food additives that are permitted for use in your food and within the prescribed maximum level of use
        • is only fortified in accordance with the Food and Drug Regulations (nutrients are permitted in your food and added at the appropriate level)
    • protocols and frequencies for verifying that the written procedures are followed
  • Your written PCP also includes the documents you use as evidence of the measures you take to meet the standard, which may include:
    • records of analyses that verify your food meets parameters set out in the standard (for example, moisture level, protein content)
    • a sample label showing that your food is represented appropriately with the common name set out for that standard
Example 2

The food, in respect of which a grade is prescribed, is required to meet the requirements set out in the Canadian Grade Compendium or the Beef, Bison and Veal Carcass Grade Requirements, as applicable.

  • Your written PCP describes the measures you take to make sure that the food meets the grade, and any applicable size designation and class requirements. These measures may include:
    • a description of the grading process for the food, including identification of point(s) in the process where specific criteria or quality factors are controlled
    • identification of the criteria or quality factors against which the food is examined and the tolerances or limits that are set for these and for each grade
    • identification of point(s) in the grading process where samples of your food are taken and examined against the criteria or quality factors
    • a description of the measures taken to ensure that the correct grade, including any applicable size designation and class, is applied on the food's label or on the food after it has been graded
  • Your written PCP also includes the documents you use as evidence of the measures you take to meet the grade, which may include:
    • records of the grading process
    • results of examination at sampling site(s)
    • label verification worksheets
    • samples of all labels showing the different grades
Paragraphs 89(1)(b) and (e): PCP content for truthful and not misleading packaging and labelling of food
  • As applicable to your food business, your PCP includes:
    • a description of the measures that you take to make sure that the food is packaged and labelled in manner that is not
      • false
      • misleading
      • deceptive
      • likely to create an erroneous impression with respect to the food's character, quality, value, quantity, composition, merit, safety or origin or the method of its manufacture or preparation
  • the documents you use as evidence of the measures you take to make sure that your food is labelled in a manner that is not false, misleading, deceptive or likely to create an erroneous impression.
Examples
  • Your PCP includes:
    • written procedures that document the means by which the mandatory information (for example, nutrient values, net quantity, ingredient list) required on the label of your food is determined to ensure accuracy of the information declared
    • written procedures that document the means by which voluntary information (for example, claims) provided on the label of your food is developed to ensure it is truthful and not misleading such as:
      • identification of claims with prescribed criteria in regulation and measures taken to adhere to the criteria
      • measures taken to substantiate that claims are not false, such as laboratory testing, third party certification, supply chain controls
      • measures taken to substantiate that consumers are not misled, such as consumer research, adherence to publicly available guidance, proactive communications clarifying the meaning of claims to consumers
  • Your written PCP also includes the documents you use as evidence of the measures you take to make sure that your food is packaged and labelled in manner that is not false or misleading, which may include:
    • records of net quantity determination
    • records of analyses (for example, nutrient levels, product authenticity)
    • research demonstrating consumers' understanding of specific claims
    • records of complaints by consumers with respect to packaging and labelling of your food, as well as actions taken to address complaints

4.0 PCP content for food safety

Safe Food for Canadians Regulations: paragraphs 89(1)(c) and (e) and subsection 89(2)

Rationale

Hazards may be inherent to food, or they may be introduced during its preparation, movement, or storage. The presence of hazards in food can cause a risk of injury to human health.

A PCP allows you to identify and describe the biological, chemical and physical hazards associated with the food, document how you intend to control those hazards, provide the information you used to develop your plan, and demonstrate through records that you have implemented your plan.

Since each food business is unique, it is important that you tailor your PCP to your specific food business.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer ideas on what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subparagraph 89(1)(c)(i) and paragraph 89(1)(e): PCP content for hazard control
  • As a result of the hazard identification and analysis conducted under section 47 of the SFCR, subparagraph 89(1)(c)(i) requires that for each food, including the food that you import or export, and food animals that you slaughter, your PCP includes a description of the:
    • biological, chemical and physical hazards you identified as presenting a risk of contamination to the food;
    • control measures you use to prevent, eliminate or reduce the hazards to an acceptable level; and
    • evidence that the control measures are effective
  • Paragraph 89(1)(e) requires that your PCP also includes the documents you used to
    • identify the hazards; and
    • determine the appropriate control measures
Examples
  • For each hazard you identified, your PCP includes:
    • a description of the hazard
    • a description of the control measure(s), including details such as:
      • the task(s) required to carry out the control measure (for example, standard operating procedures)
      • how frequently the tasks are carried out (for example, hourly, weekly, monthly)
      • the job title of the person responsible for the control measure
  • Your PCP also includes evidence that the control measures you use are effective, for example
    • references to guidelines from internationally recognized organizations, such as the Codex Alimentarius (for example, Codes of practice for specific foods)
    • test results
    • verification activities
  • Your PCP also includes the documents you used:
    • to identify the hazards associated with the food; and
    • to determine the appropriate control measures to control those hazards
  • These documents may include:
    • the information used to conduct the hazard analysis, such as process flow diagrams and product descriptions
    • consumer complaints
    • food illness outbreak data
    • scientific research
    • a record of test results
    • certificates of analysis provided by your foreign supplier or a competent third-party
  • Your PCP also includes the documents you used:
    • to identify the hazards associated with the food you import; and
    • to help you determine the select appropriate foreign supplier
  • The documents used to conduct the hazard analysis may include:
    • consumer complaints
    • food illness outbreak data
    • scientific research

For a list of guidance material on hazard identification and control, refer to section 9.0 of this document.

Example for licence holders who import
  • For each hazard you or your foreign supplier identified, your PCP includes:
    • a description of the hazard
    • a description of the control measure(s) you use to prevent, eliminate or reduce the hazards to an acceptable level. This may include the procedure and criteria you use for selecting foreign suppliers that have control measures in place to address the identified hazards
  • Your PCP also includes evidence that the control measures you use are effective, for example, a description of your procedure for testing the food you import

For a list of guidance material on hazard identification and control, refer to section 9.0 of this document.

Example for licence holders who export (sole activity)
  • For the food you export, your PCP includes:
    • a description of the hazards associated with the food
    • a description of the control measure(s) you or your supplier uses to prevent, eliminate or reduce the hazards to an acceptable level
  • Your PCP also includes evidence that the control measures you or your supplier uses are effective.

For a list of guidance material on hazard identification and control, refer to section 9.0 of this document.

Subparagraphs 89(1)(c)(ii) to 89(1)(c)(v) and paragraph 89(1)(e): PCP content for hazards controlled at one or more critical control points

Note: The requirement to identify critical control points is not applicable to licence holders who import.

  • If you determine that one or more critical control points (CCP) are essential to prevent or eliminate the hazards that present a risk of contamination of the food or to reduce them to an acceptable level, your PCP includes
    • a description of the CCP, the control measure that is applied at that CCP and the evidence that the control measure is effective
    • a description of the critical limit for each CCP
    • the procedures you use for monitoring each CCP in relation to its critical limit
    • the procedures for the corrective actions you would use for each CCP if the critical limit is not met
    • the information you used to determine
      • the CCPs, their related control measures and their critical limits
      • your monitoring procedures
      • your corrective action procedures
Examples
  • For the hazards that are controlled at one or more CCPs, your PCP includes:
    • the step in your process at which you determined that a CCPs is needed and for which hazard
    • a description of the control measure, including details such as:
      • the tasks required to carry out the control measure, such as standard operating procedures
      • the frequency at which the tasks are carried out, such as, hourly, weekly, monthly
      • the job title of the person responsible for the control measure
    • evidence that the control measures you use at the CCP are effective, such as
      • published information from regulatory authorities or scientific journals/ literature demonstrating that the control measures have been validated to be effective
      • results of a validation study, including challenge studies, conducted by you, equipment manufacturers or other industry parties.
    • a description of the critical limits for the CCP
    • monitoring procedures for each CCP, which include details such as
      • what: a description of the procedure to monitor the critical limits (essentially "what" you are doing)
      • how: a description of how the monitoring procedure is carried out (for example, your standard operating procedure)
      • when: the frequency at which you carry out the monitoring procedure
      • who: the name of the person responsible for monitoring the critical limits
    • the records you use to capture the monitoring data at each CCP
    • corrective action procedures that include details such as
      • how you would control the affected food
      • how you would correct the process that led to the deviation
      • how you would evaluate if other food were impacted
    • records of all corrective actions
  • Your PCP also includes the documents you used to determine the CCPs, their related control measures and their critical limits, the monitoring procedures and the corrective action procedures. These documents may include:
    • a description of how you determined the CCPs
    • regulatory standards and guidelines
    • guidelines from internationally recognized organizations, such as the Codex Alimentarius
    • expert opinions
    • description of industry practice
    • standard operating procedures

For a list of guidance material on critical control points, critical limits, monitoring procedures and corrective action procedures, refer to section 9.0 of this document.

Examples for licence holders who export (sole activity)
  • For each food you export, if your supplier has identified hazards that need to be controlled at one or more CCPs, your PCP includes:
    • a description of the following information or evidence that your supplier has described them:
      • the CCPs, their related control measures and the evidence that the measure is effective
      • the critical limits for each CCP
      • monitoring procedures to each CCP
      • corrective action procedures for each CCP

For a list of guidance material on critical control points, critical limits, monitoring procedures and corrective action procedures, refer to section 9.0 of this document.

Subparagraph 89(1)(c)(vi) and paragraph 89(1)(e): Verifying PCP implementation
  • Your PCP also includes:
    • the procedures you use to verify that the implementation of your PCP results in compliance with the Safe Food for Canadians Act and the Safe Food for Canadians Regulations
    • the documents you used to develop your verification procedures
Examples
  • Your verification procedures describe what you are doing to verify that all control measures, including those that are applied at a CCP, are consistently implemented and are effective at ensuring safe and compliant food. The procedure includes details such as:
    • what: are the control measures
    • how: the control measures are verified and what to do when the control measure is not consistently implemented or is not effective
    • when: the frequency at which the control measures are verified
    • who: the job title of the person responsible for the verification procedure. Ideally this would be a different person than the person that carried out the control measure.
    • where: you record the verification activities
  • Your PCP also includes the supporting documents you used to determine your verification procedures, which may include
    • scientific literature
    • regulatory standards and guidelines
    • guidelines from internationally recognized organizations, such as the Codex Alimentarius
    • expert opinions
    • description of industry practice

For guidance material on verification procedures, refer to section 9.0 of this document.

Example for licence holders who import
  • Your verification procedures describe what you are doing to verify that your import process is consistently implemented and is effective at ensuring the import of safe and compliant food. The procedure includes details such as:
    • what: a description of the steps you take to make sure that the food you import meet Canadian requirements. This may include
      • sampling and testing the imported food,
      • reviewing certificates of analysis and
      • reviewing product specification.
    • when: the frequency at which you conduct your verification steps. For example, you identify in your verification procedure that you sample and test the first 5 shipments from a new supplier and request yearly audit results from your suppliers that are certified to an internationally recognized food safety system.
    • who: the job title of the person responsible for the conducting the verification steps
  • Your PCP also includes the supporting documents you used to develop your verification procedures. Supporting documents may include; scientific literature; regulatory standards and guidelines; guidelines from internationally recognized organizations, such as the Codex Alimentarius; expert opinions; description of industry practice

For guidance material on verification procedures, refer to section 9.0 of this document.

Example for licence holders who export (sole activity)
  • Your verification procedures detail what you do to verify that your export process is consistently implemented and is effective at ensuring that the food you export is safe and compliant. The procedure includes details such as:
    • what: a description of the steps you take to make sure that the food you export is safe and compliant. This may include
      • sampling and testing the food you export;
      • reviewing certificates of analysis;
      • reviewing product specification.
    • when: the frequency at which you conduct your verification steps.
    • who: the job title of the person responsible for the conducting the verification steps
  • Your PCP also includes the supporting documents you used to develop your verification procedures. Supporting documents may include, scientific literature; regulatory standards and guidelines; Codex Alimentarius guidelines; description of industry practice

For guidance material on verification procedures, refer to section 9.0 of this document.

Subparagraph 89(1)(c)(vii) and subsection 89(2): Proof of PCP implementation
  • You keep documents that prove you have implemented your PCP, with respect to subparagraphs 89(1)(c)(i) to (vi), for 2 years after the day on which you prepared them.
    Refer to Section 4.0 of this document for an explanation of those subparagraphs.
Examples:
  • You have records of your operational activities that show you have implemented your PCP such as:

For a list of guidance material on monitoring, verification and corrective action procedures, refer to section 9.0 of this document.

Examples for licence holders who export (sole activity):
  • You have records of your operational activities that show you have implemented your PCP such as:
    • staff training records on your sourcing and exporting procedures
    • records of verification activities
    • copies of certificates of analysis from your supplier showing that the food being exported are safe

For a list of guidance material, refer to section 9.0 of this document.

Remember:

5.0 Additional PCP content for import

Safe Food for Canadians Regulations: Subsection 89(4)

Rationale:

Since you do not have direct control of the manufacturing, preparing, storing, packaging and labelling of the food you import, it is important that you have an effective strategy to source and verify that the food meets the requirements of the Safe Food for Canadians Act (SFCA) and the Safe Food for Canadians Regulations (SFCR).

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer ideas on what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subsection 89(4): Proof that imported food is safe
  • If you hold a licence to import food, in addition to the requirements outlined in Section 3.0 and Section 4.0 of this document, your PCP also includes information to demonstrate that the food you import has been manufactured, prepared , stored, packaged and labelled in a manner and under conditions that provide at least the same level of protection as that provided by sections 47 to 81, in Part 4 – Preventive controls of the SFCR.
  • Your PCP also includes information to demonstrate that your foreign supplier has a food safety system in place that is consistent with the requirements of 89(1)(c)(i) to (vii), as outlined in Section 4.0 of this document

    Refer to Regulatory requirements: Preventive controls for more information on the requirements in sections 47 to 81.

Subsection 89(4) and subparagraph 89(1)(c)(i): Additional PCP content for hazard identification and control measures
  • Your PCP includes:
    • A description of the biological, chemical and physical hazards that your foreign supplier has identified OR evidence that your foreign supplier has documented all the hazards related to the food you import.
    • a description of the control measures your foreign supplier uses to prevent or eliminate the identified hazards, or reduce them to an acceptable level OR evidence that your foreign supplier has documented control measures in place to prevent or eliminate the identified hazards, or reduce them to an acceptable level.
    • the evidence that the control measures are effective OR evidence that your foreign supplier has verified the control measures are effective
Examples:
  • Your PCP describes:
    • the hazards inherent in the food, and
    • the hazards associated with the manufacturing, preparation, storage, packaging and labelling of the food before it arrives in Canada
  • Your PCP includes documents that demonstrate one or more of the following:
    • The food you import came from a supplier in a foreign state that CFIA has entered into a foreign food safety systems recognition arrangement and the supplier is in good standing with the foreign competent authority
    • your supplier's exports are certified by a competent authority in a foreign state that has a food safety system for that food that provides at least the same level of protection to that of Canada
    • your supplier is subject to internationally recognized third-party evaluations; the elements of the third-party evaluation meet all applicable requirements of sections 47 to 81 of Part 4 the SFCR; and the supplier is in good standing with the certification scheme
    • the results of your own evaluation confirm that the suppliers have control measures in place for that food that provide the same level of protection as that of Canada.

For a list of guidance material, refer to section 9.0 of this document.

Subsection 89(4) and subparagraphs 89(1)(c)(ii) to (v): Additional PCP content for hazards controlled at critical control points

  • If you or your foreign supplier determine that the identified hazards need to be controlled at one or more critical control points (CCPs) during the manufacturing, preparation, storing, packaging and labelling by your foreign supplier, your PCP also includes:
    • a description of the CCPs, their related control measures and the evidence that the measures are effective; OR evidence that your foreign supplier has described the CCPs, their related control measures and has evidence that the control measures are effective
    • a description of the critical limits for each CCP; OR evidence that your foreign supplier has described the critical limits
    • the procedures you or your foreign supplier uses to monitor each CCP in relation to its critical limit; OR evidence that your foreign supplier has monitoring procedures in place for each CCP
    • the procedures for the corrective actions your foreign supplier would use if the critical limit is not met, for each CCP OR evidence that your foreign supplier has procedures in place for each CCP to be used when a critical limit is not met
Examples:
  • Your PCP includes a list of each type of food you import, the identified hazards and whether or not any CCPs have been identified for those hazards.
  • For each imported food and hazard that has a CCP, your PCP includes a description of one or more of the following (make sure that at least one is applicable):
    • Evidence that the foreign supplier is in a foreign state that CFIA has entered into a foreign food safety systems recognition arrangement with and the supplier is in good standing with the foreign competent authority in that foreign state.
    • Evidence that the foreign supplier is subject to internationally recognized third-party evaluations; the elements of the third-party scheme meet all applicable CCP-related elements and the supplier is in good standing with the certification scheme.
    • A description of the 4 CCP-related criteria described above using information provided by your foreign supplier. This could include copies of this information from the foreign supplier's food safety plan.
    • A description of the 4 CCP-related criteria described above using information obtained through direct observation and your own evaluation of the foreign supplier's processes.

For a list of guidance material on hazard identification, control measures, critical control points, critical limits, monitoring and corrective actions procedures, refer to section 9.0 of this document.

Subsection 89(4) and subparagraphs 89(1)(c)(vi): Additional content for verifying PCP implementation
  • Your PCP includes the procedures that you use to verify that the implementation of the PCP results in compliance with the Safe Food for Canadians Act and the Safe Food for Canadians Regulations.
Examples:
  • Your written PCP includes:
    • a description of the steps you take to verify your PCP is effective
    • the name, position title, qualifications and competencies of the person who carries out your PCP verification steps
    • the frequency for conducting your verification steps
    • protocols and frequencies for verifying that foreign suppliers remain in good standing with foreign competent authority and if applicable, a third-party certification body

For guidance material on verification procedures, refer to section 9.0 on of this document.

Subsection 89(4); subparagraphs 89(1)(c)(vii) and subsection 89(2): Additional content as proof of PCP implementation
  • Your PCP includes the documents that prove that you have implemented the PCP with respect to subparagraphs 89(1)(c)(i) to (vi) for 2 years after the day on which you prepared them.

Refer to Section 4.0 of this document for an explanation of those subparagraphs.

Examples:
  • You have records of your operational activities that show you have implemented your PCP such as:
    • staff training records on your sourcing and importing procedures
    • records of verification activities
    • the results of your sampling and testing showing that the food being imported meets Canadian requirements
    • copies of certificates of analysis from your foreign supplier showing that the food being exported to Canada meets Canadian requirements

For a list of guidance material, refer to section 9.0 of this document

Remember:

6.0 Additional PCP content for export

Safe Food for Canadians Regulations: Subsection 89(5)

Rationale

If you need to have a PCP prior to exporting food, for example if you export meat products or fish or if you need an export certificate or other document, the PCP will help you demonstrate that you meet the Canadian food safety requirements as well as other applicable regulatory requirements of the Safe Food for Canadians Regulations (SFCR).

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer ideas on what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subsection 89(5): Content of a PCP for licence holders who export
  • If you export food and your required to have a PCP, unless the activity is exempted under subsection 15(1) of the Safe Food for Canadians Regulations (SFCR), your PCP includes information to demonstrate that:
    • if the food was manufactured, processed, treated, preserved, graded, packaged or labelled in Canada, those activities were conducted by a licence holder in a manner that meets the requirements of the Safe Food for Canadians Act (SFCA) and the SFCR.
    • if the food was imported into Canada, it was imported by a licence holder in accordance with the requirements of the SFCA and the SFCR.
    • if the food is a meat product and if
      • any meat product that it contains was manufactured, processed, treated, preserved, packaged or labelled in Canada, those activities were conducted by a licence holder in a manner that meets the requirements of the SFCA and the SFCR.
      • any meat product that it contains has been derived from a livestock or poultry carcass that has been graded in Canada, the carcass was graded by a grader in accordance with the requirements of the SFCA and the SFCR.
      • any meat product that it contains has been imported, that meat product was imported by a licence holder in accordance with the requirements of the SFCA and the SFCR
      • any meat product that it contains is derived from food animals that were slaughtered in Canada, the food animals were slaughtered by a licence holder accordance with the requirements of the SFCA and the SFCR
  • Your PCP includes documents to prove that you are sourcing the food your export from a licence holder.
  • You keep those documents for 2 years after the day on which you prepared them.
Examples:
  • If your sole activity is to export food, your PCP:
    • provides information on the licence holder from whom you source the food. Information may include the name, address, licence number and status of the licence.
    • describes how the licence holder meets the requirements set out in subparagraphs 89(1)(c)(i) to (vii) of the SFCR. This may include:
      • conducting your own evaluation of your suppliers, or you receive an evaluation report from a third party, showing that your supplier continues to meet the requirements set out in subparagraphs 89(1)(c)(i) to (vii) of the SFCR.
      • receiving an assurance, such as a letter of guarantee or attestation, from the suppliers indicating the food meets the requirements set out in subparagraphs 89(1)(c)(i) to (vii) of the SFCR.

Refer to Section 4.0 of this document for information on subparagraphs 89(1)(c)

Remember:

7.0 Additional PCP content for post-mortem programs

Safe Food for Canadians Regulations: Subsection 89(6)

Rationale

Subsection 89(6) applies to if you have a licence and are authorized to conduct a post-mortem examination program or a post-mortem defect management program under section 160(3) of the Safe Food for Canadians Regulations (SFCR).

An authorization to conduct a post-mortem examination program provides you with the responsibility to detect defects on carcasses and their parts and to identify carcasses and their parts as accepted or rejected.

An authorization to conduct a post-mortem defect management program provides you with the responsibility to screen the carcasses and their parts and take post-screening defect management.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer ideas on what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subsection 89(6): Additional PCP content for licence holders who are authorized to conduct post-mortem programs
Examples:
  • Your PCP includes the scientific literature you used to determine the control measures that would be effective against the identified hazards.

For a list of guidance material on hazard identification and control measures, refer to section 9.0 of this document.

Remember:

8.0 Additional PCP content for food animal welfare

Safe Food for Canadians Regulations: Paragraphs 89(1)(d) and 89(1)(e); subsection 89(2)

Rationale

There are inherent animal welfare risks to food animals during their handling and slaughter. The PCP allows you to describe the measures for preventing or eliminating avoidable suffering, injury or death other than by slaughter or humane killing of the food animal, document how you intend to control those risks, provide the information you used to develop your plan, and demonstrate through records that you have implemented your plan.

What this means for your food business

To help you understand these requirements, specific criteria and examples are outlined below. The examples are not exhaustive but help illustrate the intent of the requirement and offer ideas on what you can do to comply. Key terms throughout the text have been hyperlinked to the SFCR glossary.

Subparagraphs 89(1)(d)(i) to (ii): Additional PCP content to control risks to food animal welfare
  • Your PCP includes a description of the measures you put in place to control the identified risks to the welfare of the food animal.
Examples:
  • You evaluate any gaps between what is actually occurring onsite and what the expected animal welfare outcomes should actually be to help you identify the animal welfare risks in your establishment.
  • You determine that the stunning, cutting and bleeding slaughter activities will carry high animal welfare risks in your establishment when poorly done or inadequately monitored.
  • Your PCP has effective measures to control the potential risks from stunning, cutting and bleeding slaughter activities and these are reassessed as required.
  • Your PCP also includes the supporting documents you use to develop your PCP, which may include:
    • scientific literature, studies and research that provide evidence of good performance outcomes for animal welfare
    • regulatory standards and guidelines
    • results of a validation conducted by the food business or a validation previously conducted by industry and/or equipment manufacturers provides evidence as to its effectiveness. This may include:
      • the validation of operational parameters of all stunning equipment is initially assessed and also reassessed on a regular basis to prevent stunning equipment failure on the live food animals prior to use on the food animal
      • internationally recognized and accepted best practices and standards for animal welfare

For a list guidance material on animal welfare, refer to section 9.0 of this document

Subparagraph 89(1)(d)(iii): Performance criteria for food animal welfare
  • Your PCP includes a description of the performance criteria that you have chosen to evaluate the expected outcome of each of the measures you take to control the risks.
Examples:
  • You use performance criteria for stunning effectiveness based on recognized best practices and auditing programs that are easy to use, measurable and objective.

For a list of guidance material on animal welfare, refer to section 9.0 of this document.

Subparagraphs 89(1)(d)(iv), (v) and (vi): Monitoring procedures for food animal welfare
  • Your PCP includes monitoring procedures for each slaughter activity associated with an animal welfare risk.
Examples:
  • You have monitoring procedures in your PCP to evaluate the unloading of food animals or animals in crates/modules/cages, driving of food animals, unconsciousness or return to consciousness after stunning and on the bleed rail of food animals.

For list of guidance material, refer to section 9.0 of this document

Subparagraph 89(1)(d)(v): Corrective action procedures for food animal welfare
  • Your PCP includes the corrective action procedures to be implemented for deviations from the expected outcomes of the measures in place.
Examples:
  • You have long-term corrective action procedures to effectively prevent recurrence of the deviation.
  • In the case of a failed stun outcome, you immediately use your back-up stunning system or equipment as your immediate corrective action procedure to mitigate the suffering of the individual food animal.
  • You implement a preventive corrective action procedure when your stunning performance criteria are no longer met in order to prevent recurrence of the higher than tolerated stunning failures or deviations.

For list of guidance material, refer to section 9.0 of this document

Subparagraph 89(1)(d)(vi): Verification procedures for food animal welfare
  • Your PCP includes the verification procedures you use to check that your monitoring procedures are effectively implemented in accordance with your PCP.
Examples:
  • The employee who verifies the monitoring task on a regular basis for the assessment of unconsciousness of animals after stunning or on the bleed rail ensures there are records and visual evidence that the monitor performs this task competently.

For list of guidance material, refer to section 9.0 of this document

Subparagraph 89(1)(d)(vii): Animal welfare audit procedures
  • Your PCP includes the procedures for conducting an animal welfare audit, on a regular basis, to evaluate the overall outcome of your measures.
Examples:
  • These procedures may include a self-audit or the use of a third-party animal welfare auditor or both.
  • The auditor conducts the audit in accordance with recognized animal welfare best practices and standards that are based on science.
  • Your frequency of audits is determined by any changes in equipment, employees, shifts, line speed or construction that may affect animal welfare in your establishment.

For list of guidance material, refer to section 9.0 of this document

Subparagraph 89(1)(d)(viii) and subsection 89(2): Proof of PCP implementation associated with animal welfare
  • You keep documents that prove you have implemented your PCP, with respect to subparagraphs 89(1)(d)(i) to (vii), for 2 years after the day on which you prepared them.
Examples:
  • The documents are readily accessible to CFIA inspectors to assess their compliance with these regulations.
  • Hard copy or electronic records are stored on the premises for at least two years and are easily accessible upon request.

For list of guidance material, refer to section 9.0 of this document

Paragraph 89(1)(e): Supporting documents
  • Your PCP includes the supporting documents you use to develop your animal welfare PCP.
Examples:
  • The supporting documents you use to develop your animal welfare PCP may include:
    • scientific literature, studies and research that provide evidence of good performance outcomes for animal welfare
    • regulatory standards and guidelines
    • results of a validation conducted by the food business or a validation previously conducted by industry and/or equipment manufacturers provides evidence as to its effectiveness

      For example, the validation of operational parameters of all stunning equipment is initially assessed and also reassessed on a regular basis to prevent stunning equipment failure on the live food animals prior to use on the food animal.

    • internationally recognized and accepted best practices and standards for animal welfare

For list of guidance material, refer to section 9.0 of this document

Remember:

9.0 Reference and further reading

For additional information refer to the following guidance material:

Food Safety

Animal Welfare

Export

Import

Table 2: Requirements for which written descriptions of measures taken to achieve compliance are needed

1. Labelling
Description Corresponding provisions from the SFCR
Standards prescribed for food – common names 201
Prepackaged food, other than consumer prepackaged food – language requirement 205
Consumer prepackaged food – language requirement 206(1)
Legibility 208
Prepackaged food – information (common name, name and principal place of business, requirements of the Food and Drug regulations) 218
Consumer prepackaged food – declaration of net quantity 221
Label of edible meat products – exception (label does not meet requirements) 296
2. Grades and grade names
Description Corresponding provisions from the SFCR
Mandatory grading 306
Optional grading 307
Eggs – Canada A – size designation 316
Prepackaged fish – class and size designation 317
Fresh fruits or vegetables – size designation 321
Processed fruit or vegetable products – size designation 322
Honey – colour class 324
Maple syrup – colour class 325
Prepackaged cut of beef 326
Livestock carcass – removal of marking 328
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