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Importer guide: prepare your preventive control plan

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements are being phased in over the following 12 to 30 months. For more information, refer to the SFCR timelines.

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Introduction

As an importer, it's your responsibility to make sure the food you import is safe and that it meets Canadian requirements. This guide is intended for food importers that are required to have a preventive control plan (PCP) under the Safe Food for Canadians Regulations (SFCR). A PCP is a written plan outlining how you ensure that imported food is safe and fit for consumption in Canada and conforms to Canadian consumer protection requirements, as applicable. This document describes the preventive control plan contents for import licence holders only. If you are licenced to conduct other activities (for example packaging or labelling food that will be sent between provinces or exported) your preventive control plan will need to include additional elements that are described in other guidance documents. More information on preventive control plan requirements for domestic food businesses or businesses that export food can be found in A Guide for Preparing a Preventive Control Plan: Domestic Food Businesses and the Exporting food: A step by step guide.

Preventive controls are an internationally accepted approach to prevent, eliminate or reduce to an acceptable (safe) level hazards associated with food products. They are based on the Codex Alimentarius General Principles of Food Hygiene CAC/RCP 1-1969 – PDF (179 kb).

Preventive control plans are not a new concept for many food importers. For example, some fish importers already have a system in place called the Quality Management Program for Importers (QMPI) that is comparable to a preventive control plan because they are based on a Codex approach. In addition, many food importers have food safety plans in place that align with voluntary codes of practice that are also consistent with Codex principles.

It's your choice

You may use other preventive control plan approaches that have been developed by other food safety authorities, industry associations, international partners, or academia. Always ensure that the information in your preventive control plan is tailored for your particular business, foods, foreign suppliers and market requirements. You are responsible for ensuring that your written preventive control plan meets the requirements of the Safe Food for Canadians Regulations.

In addition to the preventive control plan requirements described here, importers have several other record keeping requirements under the SFCR. For example, importers are required to keep records related to receiving and responding to complaints, recall and traceability. While these records are not required to be part of the preventive control plan, you may still choose to include these records with your plan. More details regarding these additional record keeping requirements can be found in Importing Food: A step by step guide.

A) Developing your preventive control plan

The required components of a preventive control plan are described in specific parts of section 89 of the SFCR and described further in Regulatory requirements: Preventive control plan (PCP). The parts of section 89 that apply to import licence holders are:

Each of the above requirements is described in more detail below.

Keep in mind

We have created the following tools related to the PCP requirements that may apply to you:

  1. The Preventive control plan interactive tool tool will help you determine if you need to prepare a written preventive control plan.
  2. A series of infographics on food hazards and preventive controls will give you a basic overview of key elements that need to be included in your preventive control plan.
  3. Preventive Control Plan Templates have been developed for importers to help further illustrate what a PCP includes.

1. Hazard identification and associated control measures

The SFCR requires that imported food be subject to the same level of hazard analysis and preventive food safety controls as food prepared in Canada. We recognize that you, as an importer, are likely not present in the foreign food establishments from which you source your imported food and that you do not have direct control over the food safety control measures applied in those food establishments. For this reason, assessment of your foreign supplier is critically important in ensuring that hazards are identified by the foreign supplier and effective control measures are in place to deal with these hazards. There are several strategies an importer can use to obtain these assurances. Some examples of these strategies are provided in this document. You may choose to use other strategies as appropriate for your import business model to meet the hazard identification and control measure requirements.

Hazard identification

For each type of food you import, you need to ensure that the hazards (biological, chemical and physical) that may reasonably be expected to contaminate the food have been identified and described. Complete hazard analysis requires you to consider both the hazards inherent to the food and hazards that may be caused by the foreign supplier's processes and procedures. As such, the hazard identification and analysis section of your PCP should include the following:

Keep in mind

You may choose to use the expertise of a trade or professional association or a consultant to help you analyze potential biological, chemical and physical hazards, and develop your PCP.

The Reference Database for Hazard Identification (RDHI) is also available to help you identify potential hazards in food processing.

Demonstrating hazard identification in your PCP

The following are examples of how you may demonstrate in your PCP that you have adequate assurances that all relevant hazards in the food to be imported have been identified and analyzed:

Example:

You are importing spices. Regardless of your foreign supplier's operational procedures, you should identify in your preventive control plan the common hazards in spices associated with potential on farm contamination, such as pathogenic microorganisms (for example, Salmonella spp.), viruses (for example, Hepatitis A virus), fungi, yeast, moulds and mycotoxins (for example, aflatoxin). You should also ensure your foreign supplier has identified and analyzed these hazards.

There are also process related hazards for spices such as contamination with pathogenic microorganisms due to failure to clean tools/equipment, improper employee hygiene or improper separation of raw/untreated product from treated product. These are examples of hazards you would want to ensure your foreign supplier has identified and addressed.

Control Measures

Your preventive control plan needs to include evidence that there are control measures in place that are effective in controlling all hazards associated with the food you import. In most cases, the hazards associated with imported foods are controlled by the foreign supplier at the time the food is manufactured, prepared, stored, packaged or labelled in the foreign establishment.

Demonstrating effective control measures in your PCP

Similar to the strategies described above for the identification of hazards, there are several strategies that can be used to demonstrate that each of your foreign suppliers is implementing effective control measures. For example:

Verifying that the control measures are effective

In addition to the above strategies for demonstrating that your foreign supplier is implementing control measures, you must verify the effectiveness of these control measures. The following actions would provide assurance that your control measures are effective:

2. Foreign supplier controls and procedures

Under subsection 89(4) of the SFCR you are required to include in your PCP a description of your assurances that each of your foreign suppliers has:

Your PCP must demonstrate that your foreign supplier has taken the following steps as applicable to their operation:

Verifying that critical control points are implemented

Similar to the strategies above, there are several options you may want to consider to demonstrate that your foreign suppliers are implementing the critical control points and verification steps described in 89(1)(c)(ii) to (v). For example:

Procedures for verifying your preventive control plan is effective

Your verification procedure details what you will do 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:

Your PCP also includes the supporting documents you used to determine your verification procedures, which may include:

3. Consumer protection requirements

Describe the measures you have in place to ensure the food you import meets the applicable consumer protection provisions such as labelling, standards of identity and grades, packaging.

B) Implementing your preventive control plan

Once you have developed your written preventive control plan, you need to implement it into your day-to-day operations. This involves:

Verifying your preventive control plan is effective

There are several options you may want to consider to demonstrate that your preventive control plan is effective in ensuring the food you import is safe and meets all applicable requirements of the SFCR. For example, for each type of food you import and/or for each foreign supplier, you may want to have a procedure in place for verifying your incoming food shipments meet Canadian requirements. The frequency and level of verification should be consistent with the risks associated with the imported food.

The following are measures you may want to consider implementing to verify the effectiveness of your preventive control plan:

Your preventive control plan also needs to include evidence that you have implemented your plan (such as, service contracts, processing records, and other day to day records).

C) Maintaining your preventive control plan

Once you have developed and implemented your preventive control plan, maintain it by reassessing it at a frequency appropriate to your food business, for example annually, and revising it as necessary.

The preventive control plan also needs to be reassessed and revised when:

Reassessing your plan includes reviewing records and may include following up with your foreign supplier to ensure all hazards are being managed appropriately.

Keep in mind

You also need to meet the investigation, notification, complaints, and recall requirements referred to in sections 82 to 85 of the Safe Food for Canadians Regulations.

More information is available in Food safety and emergency response.

Tell me more! References and further reading

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