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Archived - Export Certification Control Program Reference Standard

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This page was archived due to the coming into force of the Safe Food for Canadians Regulations. Archived information is provided for reference, research or record-keeping purposes only. It is not subject to the Government of Canada Web Standards and has not been altered or updated since it was archived. For current information visit Food.

Table of Contents

1.0 Purpose

This standard outlines the requirements for the documentation and application of a system-based export certification control program (ECCP) plan to ensure fish products for export comply with the Fish Inspection Regulations (FIR) and with additional foreign requirements which may apply. It also outlines the ECCP plan requirements to ensure the integrity of certification requested.

2.0 Scope

This document applies:

  1. In full, to persons or companies applying for, or which already have, a fish export licence.
  2. To registered establishments participating in a systems based certification approach. Only elements 5.2, 5.3, 5.4, 5.8, 5.9, and 5.10 of this reference standard are required to be incorporated into the establishment's existing Quality Management Program (QMP). (Note: elements 5.1, 5.5, 5.6 and 5.7 are already covered through existing QMP)

3.0 Definitions

Broker:
an individual or party that purchases fish or seafood for resale without transformation.
Certification:
the procedure by which official certification bodies or officially recognized certification bodies provide written or equivalent assurance that food or food control systems conform to requirements. Certification of food may be, as appropriate, based on a range of inspection activities which may include continuous on-line inspection, auditing of quality assurance systems, and product inspection.
Consignment:
a specific quantity of fish or seafood imported or exported on a single transport carrier or vessel by one person.
Control Measures:
an action performed to maintain adherence to a standard or to eliminate a hazard or reduce it to an acceptable level.
Corrective Actions:
the procedure that is to be followed whenever the results of monitoring activities show that there is a lack of compliance with the Fish Inspection Regulations.
Export Certification Control Program (ECCP) plan:
the exporter's written description of the control measures and procedures implemented to ensure that exported fish products comply with the FIR and with additional foreign country requirements, if applicable.
Fish Export Certificate:
an inspection certificate that is recognized by the CFIA and is issued as a condition of entry set by the competent authority of the importing country. The fish export certificate is a paper or electronic document that describes and attests to attributes of consignments of fish destined for international trade.
Foreign country certification requirements:
the conditions as outlined on a CFIA recognized certificate that must be met to satisfy a foreign country's import requirements.
Inspection Certificate:
a certificate of inspection issued under the Fish Inspection Act (FIA).
Licensed Establishment:
an establishment licensed by the CFIA under the FIR that only washes, ices or boxes live or fresh unfrozen fish or seafood; or stores finished fish products for export.
Lot by Lot Certification:
certification that is based on the inspection of a defined lot of product.
Monitoring:
a planned observation or measurement of a parameter, at a specified point or time, which is compared to a standard or requirement.
Quality Management Program (QMP):
a fish inspection and control management system implemented by a registered establishment that includes procedures, inspections and records for the purpose of verifying and documenting the processing of fish and the safety and quality of fish processed in, exported from or imported into Canada (Section 2, FIR).
Registered Establishment:
a freezer-factory vessel, barge, onshore plant, building or premise where fish are processed or stored for export that is registered by the CFIA under the FIR.
Systems Based Certification:
certification based on the exporter's compliance with its export certification control program plan.

4.0 Reference Tools

Fish Inspection Regulations

Export Information By Jurisdiction

Certification of Fish and Fish Products, Chapter 10 Fish Products Inspection Manual

5.0 Elements of the Export Certificate Control Program (ECCP) Plan

Registered establishments may refer to their Quality Management Program (QMP) for elements addressed by their QMP.

5.1 Management Roles and Responsibilities

Element covered through QMP plans for registered establishments.

Intent

Management must identify and support the person responsible for the design, implementation and maintenance of the ECCP.

Management must be committed to and supportive of the development, implementation and maintenance of the ECCP.

Requirements

5.1.1 Person responsible

The ECCP plan must identify the name(s) and/or position(s) of the person(s) or service provider who developed the program and their qualifications.

The ECCP plan must identify the name or title of the person responsible for the implementation and maintenance of the program, the business address and telephone number where they can be reached in Canada, and their qualifications.

5.1.2 Management Commitment

Management must ensure that the ECCP plan is designed, implemented and maintained by capable personnel.

The ECCP plan must include an attestation from management acknowledging their responsibility for ensuring that the ECCP is designed and implemented in accordance to the reference standard and acknowledging their commitment to and support for the ECCP.

The ECCP must also be signed by a senior level manager or the owner of the business and, if different, the person responsible for the implementation and maintenance of the plan to acknowledge the commitment to and support for the plan.

5.2 Foreign Country Requirements

Intent

Foreign import requirements must be determined in order to ensure the compliance of exports with these requirements.

Requirements

Exporters must determine the foreign import and fish and seafood requirements which apply to the fish and seafood they export.

5.2.1 Fish and Seafood for Export

The ECCP must describe the fish and/or seafood for export, and for which export certificates are required. This must include:

5.2.2 Certification Requirements

The ECCP must indicate, for each type of product for export:

5.2.3 Establishment Eligibility Requirements

The ECCP plan must indicate, for each country of export, the country’s fish and seafood establishment eligibility requirements, as applicable. For example:

Control measures

The ECCP plan must describe:

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the foreign country requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.3 Product Compliance

Element covered through QMP plans for registered establishments. Registered establishments only need to address the foreign product standards which exceed Canadian standards or for which there are no Canadian standards since the Canadian standards are already addressed in the QMP.

Intent

Fish and seafood exported comply with Canadian and foreign standards.

Compliance with Canadian requirements is assured through the implementation, maintenance and verification of control measures for the processing, storage, handling and transportation of fish and seafood in accordance with the Fish Inspection Regulations.

Compliance with foreign certification requirements pertaining to fish or seafood standards that exceed Canadian standards or for which there is no Canadian standard must be assured through product testing.

Requirements

The exporter must ensure that all fish and seafood exported comply with Canadian and foreign standards.

5.3.1 Product standardsFootnote 2

The ECCP plan must indicate the standards the fish or seafood must comply with:

  1. Chemical and Microbiological standards, as applicable.
  2. Labelling requirements.
    • The applicable Canadian labelling requirements as outlined in chapter 15 of the Guide to Food Labelling and Advertising.
    • The foreign labelling requirements outlined in the attestations of the certificate e.g. registration number).
  3. Sensory and Net Content standards.

5.3.2 Product Inspections to verify ECCP control measures

Fish and seafood is subject to inspection by the exporter in order to verify the implementation and effectiveness of the control measures in place to assure the compliance of fish and seafood with Canadian and foreign country requirements.

The inspection may be conducted in house when using procedures and methods accepted by the CFIA.

5.3.3 Product Inspections to verify the compliance of fish or seafood for export

Fish and seafood must be inspected when:

Fish and seafood must be sampled for inspection in accordance to the procedures outlined in the Fish Inspection Program Sampling Procedures or equivalent procedures.

Physical tests such as sensory evaluation and net content determination must be conducted in accordance to the CFIA Fish Products Standards and Methods manual and Fish Products Inspection Manual or equivalent procedures.

Microbiological and chemical analyses must be conducted by a laboratory accredited by the Standards Council of Canada (SCC) or by the Canadian Association for Laboratory Accreditation (CALA) for those analyses. Test results from the Standards Council of Canada (SCC) or CALA accredited laboratories are recognized by the CFIA as official results. As per the FIR, fish or seafood found to have in or upon it a poisonous or harmful substance cannot be re-inspected (the fish or seafood sample cannot be tested again nor can new samples from the lot be tested).

5.3.4 Supplier Quality Assurance Agreement

Brokers may develop and implement a Supplier Quality Assurance Program (SQA) agreement with each supplier (registered or licensed establishment) requiring them to conduct any required product testing to assure compliance of the fish or seafood with foreign standards.

The SQA must comply with the CFIA Criteria for an Acceptable Supplier Quality Assurance Agreement.

Control measures

The ECCP plan must describe:

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.4 Certification

Intent

Exporters must ensure the integrity of certificates requested.

Requirements

Certificates must be requested prior to shipping a consignment.

Certificates requested must be required by the country of export and recognized by the CFIA.

Certificates can only be requested when the fish or seafood are in compliance with all applicable requirements of the importing country and the FIR.

The certification information provided or completed must be complete and describe accurately the consignment.

The consignment for certification must be available for inspection by the CFIA.

5.4.1 Certificate Requests

The following information must be completed or provided to the CFIA when requesting a certificate to be signed by the CFIA:

5.4.2 Replacement Certificates

A replacement certificate can be requested when:

A replacement certificate can only be requested when the integrity of the consignment has been maintained and the consignment has not yet been imported in a foreign country.

Requests for consignments no longer available in Canada for inspection, but which have not yet been imported in a foreign country, must include a written explanation of the event (what,when and where) which resulted in the need for a new certificate.

The original certificate is considered void and must be returned to the CFIA. A written explanation must be provided to the CFIA when a certificate cannot be returned to the CFIA.

A copy of the original certificate, the replacement certificate issued and written explanation of the event must be kept on file.

Control measures

The ECCP plan must describe:

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.5 Traceability

Element covered through QMP plans for registered establishments.

Intent

The CFIA must be notified when fish or seafood exported is determined to constitute a hazard to the public.

Information on the distribution of fish and seafood must be readily available to allow for the rapid recall of fish or seafood determined to constitute a hazard to the public.

5.5.1 Lot Accountability

Requirements

Exporters must be able to identify all the certificates issued to them by the CFIA, the fish or seafood certified by each certificate, and the status of the lots certified (in inventory or exported). The distribution of the exported fish and seafood must be traceable to the first shipping destination to allow for the rapid recall of fish or seafood determined to constitute a hazard to the public.

For this purpose the following information must be maintained for each consignment certified by the CFIA.

Replacement certificates received from the CFIA must be linked to the original certificate which was cancelled.

5.5.2 Health and Safety Verification and Notification

Requirement

When information or a complaint is received that questions the safety of fish or seafood exported, the validity of the information must be verified to determine whether the fish or seafood constitutes a hazard to the public. When the verification indicates that the fish or seafood constitutes a hazard to the public, the CFIA must be notified within 24 hours.

The following information must be kept on file and provided to the CFIA when the fish or seafood is determined to constitute a hazard to the public:

Control measures

The ECCP plan must describe:

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.6 Licensed Establishments of Live and/or Fresh fish and SeafoodFootnote 3

Element covered through QMP plans for registered establishments.

Intent

Establishments must protect from contamination and preserve the quality and safety of the fish and seafood they export.

Requirements

The fish or seafood must be protected from contamination and cross-contamination from the equipment, water, air, personnel and any other sources of contamination, including insect and animal pests. The quality and safety of the fish or seafood must also be preserved.

5.6.1 Conveyances and Equipment

Conveyances and equipment used to unload and handle live or fresh fish must be constructed and maintained in such a way that it will not become a potential source of contaminations. Equipment must be made of materials that are non-corrosive and non-porous to allow it to be cleaned and disinfected and meet the following requirements:

5.6.2 Establishment Requirements

The establishment must be constructed in a manner that:

The construction and packaging materials and non-food chemical products used in the construction and operation of establishments and their equipment must be suitable for their intended use. Materials and non-food chemicals listed on the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products have been found by the CFIA to be acceptable for use in food establishments. All non-food chemicals must be clearly labelled as to its use, stored in an appropriate location and only used by a person trained to use or apply it in a manner that prevents contamination of fish or contact surfaces.

The enclosed establishment must meet the following construction and equipment requirements:

5.6.3 Sanitation and Personnel Hygiene

Establishments must develp and implement a sanitation and hygiene program to ensure that the employees of the establishment or the users of the conveyance or equipment use proper sanitation and hygiene practices, and that the establishment, grounds, equipment or conveyances are maintained in a clean and sanitary condition and free from serious contamination and insect and animal pests.

Cleaning/disinfecting equipment and supplies must be available to ensure that the sanitation program can be carried out as written. Chemical products for use in cleaning and disinfecting must not be allowed to contaminate food products.

No person who is a known carrier of a disease that is likely to be transmitted through food or who is afflicted with an infected wound, skin infection, sore, diarrhoea or any communicable disease, can work in the handling areas if there is a possibility of contaminating fish with pathogenic organisms.

The sanitation and hygiene program must describe:

5.6.4 Pest Control

The establishment must be free of pests.

5.6.5 Hazard Analysis

A hazard analysis of each process step, from the time the fish or seafood is caught or received to the time it is transported for export must be conducted. A Hazard Analysis Worksheet, or equivalent, must be used to organise and document the hazard analysis.

All potential hazards (biological, chemical, physical) which may be present or introduced must be identified for each step and the significance of the hazard determined i.e. consideration of its severity, the likelihood of its occurrence or increase to an unacceptable level. Justification must be provided when a hazard is identified but determined to not be significant.

Where a hazard has been identified to be of significance, a Hazard Analysis Critical Control Plan (HACCP) must be developed and documented identifying each hazard determined to be of significance and the process step where it was identified as a Critical Control Point (CCP). For each CCP:

Corrective action procedures must be established to address deviations, from the critical limits, identified during the monitoring of a CCP. The corrective actions must identify and correct the deficiency that resulted in the deviation, identifiy and segregate any product affected and prevent or reduce the likelihood that the deficiency will reoccur.

Verification procedures such as the review of records or additional testing must be established to verify the implementation of the HACCP plan.

Records of the CCP monitoring activities, corrective actions and verifications completed must be maintained. These records must be initialled or signed and dated by the person responsible for them.

Control measures

The ECCP plan must describe the process and the person responsible for ensuring:

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.7 Consignment Storage and Transportation

Element covered through QMP plans for registered establishments.

Intent

Consignments must be protected from contamination and their quality and safety preserved during storage and transportation.

Consignments must be stored and transported under secure conditions to prevent product loss or substitution.

Requirements

Consignments must be stored and transported under conditions that comply with the Fish Inspection Regulations.

The walls, floors and ceilings of storage and transport facilities, where appropriate, must be of a suitable corrosion-resistant material with smooth non-absorbent surfaces that can be adequately drained.

Consignments must be protected from contamination, exposure to extreme temperatures, the sun and wind.

The quality and safety of fish and seafood must be preserved from the time they are caught, during loading, unloading, holding and transportation.

Live fish are to be stored and transported at temperatures appropriate for the species.

Fresh fish and seafood must be maintained chilled at a temperature close to 0°C. The mechanical refrigeration should allow for the free flow of chilled air around the fish or seafood.

Control measures

The ECCP plan must describe the process and the person responsible for ensuring the integrity, quality and safety of the fish or seafood is maintained during loading, storage and transportation.

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.8 Verification & Maintenance of the ECCP Plan

Registered establishments to update QMP plans incorporating this element.

Intent

The ECCP plan must be maintained up-to-date and be effective in ensuring the compliance of the fish or seafood exported and the export certificates issued.

Requirement

The ECCP plan must be verified to ensure the controls are up-to-date, comply with the requirements and are effective in ensuring the integrity of the certification of fish or seafood.

5.8.1 Ongoing Maintenance

The plan must be updated when:

5.8.2 Annual Review

All the elements of the ECCP plan must be reviewed annually to verify that the plan continues to comply with the requirements and is effective in ensuring the compliance of the fish or seafood exported and the export certificates issued.

Control measures

The ECCP plan must describe the process and the person responsible for the ongoing maintenance of the plan.

The ECCP plan must describe the process and person responsible for the annual review of the plan to ensure that it is up-to-date, complies with the requirements and is effective.

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

5.9 Monitoring

Registered establishments to update QMP plans incorporating this element.

The control measures for elements 5.1 to 5.8 must be monitored to ensure that they are consistently implemented as written and are effective.

The ECCP must describe the monitoring procedures used to ensure that the control measures are being correctly and consistently carried out. The monitoring procedures must clearly specify what is being monitored, how it is being monitored, at what frequency, and by whom. The frequency identified for each monitoring activity must be sufficient to ensure that the standard is being met.

5.10 Maintenance of Records and Documents

Registered establishments to update QMP plans incorporating this element.

Intent

Records must be maintained to demonstrate that the ECCP plan is effective, implemented as designed, can identify issues, and is up-to-date.

5.10.1 Records relevant to the ECCP plan

Requirements

Records relevant to the implementation, monitoring and verification of the ECCP plan must be maintained.

Records must be up-to-date, legible, comprehensible, easily acessible, and stored in one location in a manner which protects their integrity.

The records maintained should provide evidence that the ECCP plan is effective, implemented as designed, can identify issues and is up-to-date.

Examples of the blank documents referred to in the ECCP plan monitoring, verification, and corrective action activities must be kept with the records.

When electronic records are used, specific controls must be developed for the creation and maintenance of electronic records and electronic signatures.

Records must be retained for at least three years.

5.10.2 Amendments to the ECCP plan

Requirements

A log of all amendments to the ECCP Plan must be maintained to ensure that documents are up to date and accurate.

The amendment log must identify historical documents for the last three years.

Control measures

The ECCP plan must describe the process and person responsible for amending and recording amendments to the plan.

The ECCP plan must identify the address in Canada where all records and documents relevant to the ECCP plan are maintained.

Corrective Action requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occuring.

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