Operational guideline: Evaluating a supplier food safety assurance program (SFSAP)
Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply 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 Purpose
- 2.0 Authorities
- 3.0 Reference documents
- 4.0 Definitions
- 5.0 Acronyms
- 6.0 Operational guideline
- 6.1 Documented procedures / Record review
- 6.2 Food product, input, or service specifications
- 6.3 Supplier selection
- 6.4 Supplier agreement (SA)
- 6.5 List of suppliers
- 6.6 Regulated party's verification of the SFSAP
- 6.7 Maintenance of the SFSAP
- 6.8 Records
- 6.9 Food product, input or service documentation
- 6.10 Food product, input or service documentation
- 6.11 On-site inspection or observation
- 6.12 Determining compliance
- 7.0 Appendix
The purpose of this document is to provide guidance to Canadian Food Inspection Agency (CFIA) staff on the assessment of a regulated party's Supplier Food Safety Assurance Program (SFSAP) for the control of incoming food products (domestic or imported), inputs or the delivery of services provided through a Supplier Agreement (SA).
This document is intended to be used in conjunction with other guidance documents such as the industry guidance on Supplier Food Safety Assurance Program.
An SFSAP and SA's are not mandatory requirements under the Safe Food for Canadians Regulations (SFCR). However, if a regulated party's Preventive Control Plan (PCP) indicates that SA's are used as a control measure, then the SFSAP governing the SA's is to be assessed as part of the PCP.
The procedures outlined below should be used when an assessment of the SFSAP is required. This could be during an inspection under the Standard Inspection Procedure (SIP), review of a PCP related sub-element, as part of a food safety investigation or follow-up to a complaint.
- Safe Food for Canadians Act (SFCA)
- Safe Food for Canadians Regulations (SFCR)
- Food and Drugs Act (FDA)
- Food and Drug Regulations (FDR)
3.0 Reference documents
- Industry guidance - Incoming ingredients, materials and non-food chemicals
- Industry guidance - Supplier Food Safety Assurance Program
- Standard inspection procedure
Unless specified below, definitions are located in either the:
- Integrated Agency Inspection Model (iAIM) - Glossary of terms (Annex F)
- My CFIA Glossary of Terms
- Safe Food for Canadians Regulations - Glossary of key terms
- include activities such as contracted testing or calibration of equipment, pest control, laundry services, transportation or distribution of goods, or any other service that has a direct impact on a food commodity, a prescribed activity, or a food processing environment.
- means a person who supplies food products, inputs or services to a regulated party.
- Supplier Agreement (SA)
- means a documented agreement between a regulated party and a supplier for incoming food products, inputs or the delivery of services to the regulated party. An SA may also be referred to, by industry, as Supplier Quality Assurance (SQA) agreements.
Acronyms are spelled out the first time they are used in this document and are consolidated in the Food business line acronyms list.
6.0 Operational guideline
An assessment of a regulated party's SFSAP consists of two main components: a review of the regulated party's written procedures for SA's and an on-site inspection (record review, observation, interviews and sampling as required) of incoming food products, inputs or services. Refer to sub-sections 4.4.1 to 4.4.4 of the SIP for further details on how to conduct an inspection.
6.1 Documented procedures / Record review
6.1.1 Written procedures - Supplier Food Safety Assurance Program (SFSAP)
126.96.36.199 Verify that the regulated party has written procedures for establishing and entering into SA's with suppliers of incoming food products, inputs or the delivery of services that are used in, or have a direct impact on, a food commodity, a prescribed activity, or a food processing environment.
The SFSAP may be included in, or be a part of, the regulated party's PCP or be part of another written food quality program.
188.8.131.52 Review the written procedures and verify that they contain the following elements:
- specifications for food products, inputs or services received through SA's
- a supplier approval process for determining the suitability or acceptability of a specific supplier
- a documented and signed SA between the supplier and the regulated party
- a master list of all suppliers that provide food products, inputs or services to the regulated party under an SA
- verification procedures to assess the effectiveness of SA's
- procedures for the regular maintenance of the SA's including deviation procedures and corrective actions when issues are identified, and
Each of these elements will be evaluated individually in subsequent steps (See 6.2 – 6.8 below).
6.2 Food product, input, or service specifications
6.2.1 Verify that, for each food product, input or service received through an SA, the written program:
- identifies and establishes food safety specifications or requirements, and acceptance or rejection criteria, and
- in addition to food safety specifications, identifies regulatory, functional, technical or operational requirements or criteria, for example:
- requirements of service provider (for example, behaviour, hygienic practices in food handling areas; materials used)
6.2.2 Verify that the specifications established under step 6.2.1 include:
- name / identification of the food product, input, or service received
- description of the food product, input or service received
- specifications, criteria or requirements for the food product, input or expectations for service delivery, for example:
- supplier or service provider uses approved or acceptable agricultural chemicals, therapeutants, non-food chemicals, pest-control products and other materials
- supplier or service provider uses approved or acceptable procedures (for example, lab methodologies, calibration methods, animal transportation)
- date and signature of person responsible for maintaining the specifications document
See "Product specifications" section of the industry guidance document: "Supplier Food Safety Assurance Program".
6.3 Supplier selection
6.3.1 Verify that the written program:
- establishes minimum criteria that suppliers must meet for consideration under an SA
- includes a description of how potential suppliers are assessed and selected for an SA
6.3.2 Verify that only suppliers that meet the minimum assessment criteria and requirements of section 6.3.1 are selected as suppliers under an SA.
See "Supplier selection" section of the industry guidance document: "Supplier Food Safety Assurance Program".
6.4 Supplier agreement (SA)
6.4.1 Verify that the written program includes procedures for documenting the agreements made between the supplier and the regulated party, such as, what needs to be included in an SA.
6.4.2 Verify, from a representative sample of records, that the SA on file include the following information:
- the full names and addresses of both parties to the agreement
- names and positions of the persons of all parties responsible for maintenance of the Agreement
- scope of the Agreement (which inputs or services are covered)
- food product, input or service specifications that must be met (refer to section 6.2)
- terms and conditions that the supplier is expected to meet, including ongoing assurance that food products, inputs and services meet specifications or requirements through Certificates of Analysis (COA's), Letters of Continuing Guarantee (LOCG's), or other similar documents
6.4.3 Verify that each SA is signed and dated by the regulated party and the supplier to acknowledge that both parties agree to the contents of the Agreement.
6.5 List of suppliers
6.5.1 Verify that the regulated party maintains a list of all suppliers operating under an SA which should include:
- information on the supplier and on the food product(s), input(s) or service(s) provided as required
- date and signature of person responsible for maintaining the list
6.5.2 Verify that the list is up-to-date and amendments are made as required (such as, new suppliers added when selected, suppliers removed when agreements expire, etc.)
6.6 Regulated party's verification of the SFSAP
6.6.1 Verify that the written program includes procedures for the assessment of the effectiveness of Supplier Agreements (such as, verification that suppliers and the food products, inputs or services they provide conform to specifications / requirements of the SA and comply with Canadian food legislation).
6.6.2 Verify that the verification procedures referred to in section 6.6.1 include:
- the name or position of the person responsible for carrying out the verification
- the frequency that verification activities will be carried out
- the activities that will be carried out to perform the verification
- the procedures that will be used to complete the verification activities
- Identification of the records and documents that will be maintained
See "Verification of the SFSAP" section of the industry guidance document: "Supplier Food Safety Assurance Program".
6.6.3 Verify, through a representative sample of records, that:
- les procédures de vérification sont mises en œuvre tel que décrites et sont efficaces
- les mesures appropriées sont appliquées lorsque le fournisseur, les produits alimentaires, les intrants ou les services ne respectent pas les spécifications aux termes de l'EF ou ne sont pas conformes à la législation canadienne (voir la section 6.7, ci-dessous).
6.7 Maintenance of the SFSAP
6.7.1 Verify that the written program includes procedures for regular maintenance and updating.
See "Maintenance of the SFSAP and supplier agreements" section of the industry guidance document: "Supplier Food Safety Assurance Program".
6.7.2 Verify that the written program includes deviation procedures for the development and implementation of corrective action when issues are identified.
The procedures for deviation and corrective action may be set out in the SFSAP or in the regulated party's PCP.
6.8.1 Verify that the written program identifies the records which will be kept in relation to SA's, where they will be located, and how long they will be retained.
For example, these records could include:
- supplier approval lists
- food product, input and service specifications
- SA between supplier and the regulated party
- Certificates of Analysis (COA's) and Letters of Continuing Guarantee (LOCG's) or other equivalent documents
- verification records
- deviations and corrective action records
6.9 On-site food product, input or service inspection
6.9.1 Selection of food product, input or service for inspection
184.108.40.206 Select at least one incoming food product, input (for example, ingredient, additive, label, etc.) or service (for example, equipment calibration, laundry, pest control, transportation, etc.) for assessment against requirements of the SA and Canadian food legislation.
220.127.116.11 If possible, select incoming food products, inputs or services, or a supplier that has not been selected before. Any new suppliers or a change in incoming food products, inputs or services should also be considered for selection.
6.10 On-site inspection or observation
6.10.1 For the food product, input or service selected, verify that all the necessary SA documentation is in place for that specific food product, input or service:
- supplier is on the regulated party's List of suppliers operating under an SA
- regulated party has specifications, criteria or requirements for the food product, input or service
- regulated party has a current SA for the food product, input or service which is signed and dated by both parties
- if identified as terms and conditions of the SA, regulated party has a COA on file for the selected food product or input lot or shipment; has a LOCG on file for the food product, input or service; or other documentation related to analysis or assurance, as described in the SA
- regulated party has service reports for delivery of services
- regulated party has records for verification of the supplier, food product, input or service (supplier inspection/audit, food product or input sampling, etc.)
- regulated party has a record of any deviation issues, appropriate follow-up and corrective actions
6.10.2 Review records referred to in section 6.10.1; verify that records are complete and accurate, and specified frequencies are met.
6.11 On-site inspection or observation
Refer to sub-section 4.4.1 to 4.4.4 of the SIP.
6.11.1 If possible, conduct an on-site inspection of the food product, input or service which could include:
- visual inspection of food product, input at incoming / receiving
- observation of incoming / receiving practices of the regulated party
- interview employees responsible for incoming / receiving
- visual inspection of incoming food products or inputs in storage
- observation of supplier delivering services
- interview of employees that witnessed supplier delivery of services
- interview employees responsible for verifying the supplier, food products, inputs or services
- conduct sampling and analysis or appropriate testing (such as, temperature) of food products or inputs
- observe employees completing documentation
Verify that the regulated party, employees and/or service provider are following procedures set out in the written program and the SA.
6.12 Determining compliance
6.12.1 Compliance decision
18.104.22.168 Based on observations from the documentation review and on-site inspection (as per steps 6.10 and 6.11) determine if the food products, inputs and services meet SA specifications, PCP performance criteria and outcomes and, in turn, meet regulatory requirements (SFCA and SFCR, FDA and FDR). Refer to sections 4.5 and 4.6 of the SIP for further direction on determining compliance.
For general inquiries related to this Operational Guidance Document, please follow established communication channels, including submitting an electronic Request for Action Form (e-RAF).
Appendix 1 - Information that should be contained in Certificate of Analysis (COA), letter of Continuing Guarantee (LOCG) or equivalent document
A COA or equivalent document should include the following:
- name and address of the supplier
- name and address of the manufacturer / producer of the food product or input, if not the same as the supplier (for example, foreign ingredient provided by a broker / distributer)
- name of the food product, input or service provided
- food product or input identification - lot number(s) or lot code(s) for traceability purposes
- testing or analysis that was performed (including methodologies used) and results obtained
- name and address of person that performed the testing / analysis (for example, accredited lab)
- confirmation that test results meet acceptance criteria
- confirmation that the food product, input or service meets specification and requirements set out in the SA
- signed and dated by the person certifying the results
An LOCG or equivalent document should include the following information:
- name and address of the supplier
- name of the food product, input or service provided
- intended use or application of the food product, input or delivery of service and conditions under which the food product, input or service is to be used, applied, or delivered
- any precautions for the use, application or delivery of the food product, input or service
- a statement / commitment from the supplier that the food product, input or service is not adulterated or contaminated and meets specifications or requirements of the SA and Canadian food legislation (SFCA and SFCR; FDA and FDR)
- a commitment from the supplier that the LOCG or equivalent document will be reviewed and updated on at least an annual basis, or anytime there is a change to the food product, input or service provided
- signed and dated by the supplier
LOCG's are more generic / broader in nature than COA's. LOCG's are not intended for a specific lot or shipment of food product or inputs; nor based on specific testing or analysis of individual lots or shipments. Rather LOCG's are based on a more in-depth evaluation / assessment / or validation of an input or service over time (for example, chemical leaching or migration data; chemical and physical characteristics; approval by Health Canada or other jurisdictions – for example, United States of America, Australia or New Zealand, etc.).
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