Canadian Food Inspection Agency's On-site Assessment Report of Mexico's Food Safety Control System for Fresh Fruit and Vegetables – 2017
Appendix C. Summary of SENASICA's action plans/comments to the CFIA's recommendations from the Canadian Food Inspection Agency On-site Assessment Report of Mexico's Food Safety Control System for Fresh Fruit and Vegetables – 2017
| No | CFIA recommendation | SENASICA action plans / comments |
|---|---|---|
| 1. | Revise the 2 year recognition process in order to reduce the administrative burden on all parties and re-allocate funds to areas of higher risk. |
In June, started the review of the recognition process, according the Contamination Risk Reduction System (SRRC) guidelines:
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| 2. | Review the current processes for the authorization and monitoring of auxiliary parties (TPPs, TPSs, laboratories) to take into consideration the previous history of the individuals/ organizations and consider the potential value of third party certifications, for example, Primus, Global Food Safety Initiative, and the British Retail Consortium. The revised authorization process should focus on results of oversight activities, training received in the past 2 years, and any certifications granted. |
Update the procedure for the authorization of Professionals and Third Party Specialists in SRRC in the production of fresh fruits and vegetables. The updating of the procedure of authorization is considering specific processes for those TPPs and TPSs that are authorized for the first time and those that are renovating their validity. This process will operate by using an informatics system called: Authorization of Auxiliary Parties System, the main objective of this system is to attend the approval application in a very short time but also to have third party specialists and professionals register that allow us to have their documentary records, monitor their activities and historical performance. Activities to be developed Activities for authorization For the renewal of licenses, the manual of procedures will be updated in 2018, the documentary records previously delivered by the TPPs or TPSs, will be considered, in order to avoid having the same documentary information. Also it is expected that the database will also consider the results from the supervisions and performance assessments, activities and training obtained from the last 2 years (during their validity). Activities for monitoring Activities for supervision Include in the Manual of Procedures the supervision of TPPs and TPSs during the certification process in SRRC; consider into account the results of the supervision for the renewal of licenses. Activities of regulatory improvement Develop the "agreement under which are established the general guidelines for presenting the initial notice for operating, and the certification of SRRC in primary unit productions and establishments that made post-harvest activities; and also for the use of the SRRC National Emblem", this document is coordinated with the Directorate of Normalization of SENASICA and could be considered until it is being published in the Federal Official Gazette. |
| 3. | Consider developing a national CB network to identify best practices, share-training resources and other information/experience to ensure consistent national delivery of the program. |
Since 2017, was created at SENASICA the Coordination and Linkage Unit (UCE), which is integrated by officers, divided into regions in every state of Mexico and is in charge of monitoring the working plans of the CB. This unit can be considered as an official communication network under different levels and will be strengthen by using regular teleconferences or video calls. It is also operating a Risk Management Scheme, which is in charge of making annual meetings with people that belongs to CB's and which objective is identify and improve technical assistance, training and share experiences in the development and implementation of the Food Safety Program in each state of the country. It is important to mention that each year are organized work meetings with all the CBs for training, updating and standardizing criteria. Since 2012, SENASICA has celebrated the International Food Safety Forum in which participate more than 1500 people between producers, researchers, representatives or different organizations. Annually, within the framework of this event, we have meetings with CBs to exchange experiences and update the people that work with us by presenting scientific and technical advances that ensure the accomplishment of the Food Safety Program. With respect to the information to ensure the national delivery of the food safety program, since July, 2017 it started the implementation of a single format to monitor the activities of the CBs, this strategy is due to the observations made by our financial regulators. We will also standardize the technical supervision since October 2017. |
| 4. | Consider developing a standardized template for the training and assessment of TPPs and TPSs as well as for recording and tracking employee training to facilitate the identification of training requirements. |
The General Direction Agri-Food Safety, Aquaculture and Fisheries has created the document: "Guidelines for the Offer Agents of Training and Updating Courses for individuals and legal entities", which has the main objective to establish technical criteria and specific requirements for the assessment of academic institutions, organizations and professional colleges, research organizations interested in helping SENASICA for the training and updating purposes of TPPs and TPSs. On June 15, 2017 SENASICA presented the "Guidelines for the Offer Agents of Training and Updating Courses for individuals and legal entities" to universities and academic institutions interested in providing training courses to third party entities. On September 12, 2017, a second meeting with those institutions occurred and training to staff in the certification of SRRC and Good Agricultural Practices was delivered. The Guidelines for the Offer Agents establish the next topics:
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| 5. | Re-assess the need for the ongoing presence of a TPP in the implementation of the CRRS once an operation has been recognized. |
The presence of the technical staff during and after the company gets its certificate in food safety was analyzed , this activity is coordinated with the Certification and Recognition Office of DIAOOPA (CRO) in the new procedure, which establish:
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| 6. | Review SENASICA's CRRS oversight process that verifies the requirement for operators to develop and implement a "database on the indicator's behaviour of products, water sources and contact surfaces" to ensure that operators understand what is expected of them and, they have the capacity to conduct trend analysis, etc. |
Since August 2017 we started the process of developing a guideline for the companies on how to generate a database (records) and how to use. This database will be fed by the results of the analysis (physical-chemical, microbiological, pesticide residues, etc) from the units that implement SRRC. On November 2017 we will make a test for the guideline in the production and packinghouse units for detecting opportunity areas and make the necessary adjustments. On December 2017, we will notify to all SRRC stakeholders (farms, packinghouses, TPPs, TPSs and SENASICA's officers in the states) about this Guideline, which will entry into force on January 2018. At the same time, we will include in the Inspection and Verification procedure the specification to verify the database during the visits that will be made in 2018. This will permit to have historical trend of analysis that will be the basis for the improvement and that will allow to the production units and packinghouses to use this for its own performance. In addition, we will train TPPs in SRRC for the identification and elaboration of risk analysis based on the database historical trend. |
| 7. | Review the oversight process for evaluating operator's traceability procedures to ensure that they are well-prepared to respond to real-life issues. For example, mock recalls should include players such as SENSASICA, CBs, etc. and CAs. |
Since July 2017 we started the process of updating the "Guide of the Traceability System of the production of fresh fruits and vegetables in Mexico" in which are included those activities that companies must do to act in case of any sanitary emergency and develop the corresponding procedure as indicated in section 8.6 and 8.7 of the Technical Annex 1. Guidelines for implementing SRRC. In November 2017, we will make a practical exercise in a company to ensure that the elements involved in the procedure could solve properly a sanitary emergency in a real-life event. In December 2017, we will notify to all SRRC stakeholders (farms, packinghouses, TPPs, TPSs and SENASICA's officers in the states) about the update of this Guideline, which will entry into force on January 2018. In 2018, the Federal Inspection and Verification Office of DIAOOPA will make their activities with a special emphasis on this. |
| 8. | Re-consider SENASICA's role in assessing CAs that are generated by TPSs, that is, non-conformities that they have not directly observed. |
Update the methodology establish in "Technical Annex 5. Procedure for Auditing the SRRC in the primary production of fresh fruits and vegetables" and General Guidelines for the Operation and Certification of SRRC in the primary production of Fresh Fruits and Vegetables that use TPSs for the assessment of SRRC. We will establish that in Headquarters we will receive only those assessments reports that are in conditions of issue the certification of the companies. Generate a circular letter through which we will notify all SRRC stakeholders the critical points from the risk analysis, the lapse of time for delivering the assessment reports, but also the documentation that they need to send to SENASICA's Offices, according to the established procedure. Train TPSs so they could have the required tools for determining risks inside production units and harmonize criteria for the assessment of SRRC in the primary production in order to decrease the extraordinary information requirements and extend response timeframes for the companies. |
| 9. | Consider developing new outcome-based tools/checklists to assess/conduct internal audits, third party audits and SENASICA inspections. This will allow the different parties involved to observe the operation from different perspectives, leading to a more comprehensive assessment of their implementation of the CRRS. This should also better prepare operators to respond to food safety issues. |
On June 2017, the first checklist draft for the verification for the assessment of SRRC for TPSs was developed. On October 2017, we will develop the other 2 checklists (Internal Audits and inspections of officers) and on November 2017, we will make a proof with the 3 verification checklists in a farm and packinghouse to assure that the considered points accomplish with the main objective: implement, assess and verify the SRRC. On December 2017, we will notify to all SRRC stakeholders (farms, packinghouses, TPPs, TPSs and SENASICA's officers in the states) about the entry into force of these 3 checklists that we expect that could be during the first trimester or 2018. |
| 10. | Evaluate the needs for additional program resources in order to meet increasing demands as more companies join the program. |
Since April 2017 and due to the increase in the number of companies added to SRRC, DIAOOPA changed its operational structure, creating a single area that attends the proceedings related to SRRC. At present, we are working on the implementation of systematized mechanisms for a better, and greater, information management and analysis. Since August 2017, the electronic register system of the companies that implement SRRC was improved, we are also working on the information migration to an electronic system to know the real progress in the implementation and recognition of SRRC of the companies; we are expecting to issue electronic certificates in the medium and long term. In addition, we are jointly working with food safety private schemes in order to generate equivalence strategies with SRRC so we can consider production units of other schemes as being part of SENASICA. |
| 11. | Review the current prioritization process to allocate resources to activities that are truly critical to the success of the program. |
Financial resources through which Mexican Food Safety Program operates is subject to a set of specific provisions called "Rules for the Operation". Resources are committed to the Collaboration Bodies (CBs) through the Program for Promoting Inversion and Productivity by the program denominated: "Food Safety and Plant Health". Additionally, it exits a Fund for the attention of Sanitary Emergency Events. It is important to note, that for the resources commitment we have done previous analysis, according the surface and the importance level of crops/species, also the contaminants presence or incidence. This process starts with coordination mechanisms that includes the conformation of the information from the contaminants monitoring, noting the next Programs:
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