Supplier Food Safety Assurance Program

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.

Introduction

Having a Supplier Food Safety Assurance Program (SFSAP) is one type of control measure that can help ensure that the ingredients, materials and non-food chemicals you receive as part of your food business are safe and suitable for use.

A SFSAP could enable you to:

  • determine the ability and willingness of a supplier to meet your product specifications; and
  • establish a formal agreement with your chosen supplier(s) to ensure compliance of the products you receive. Establishing a formal agreement helps ensure that they share the responsibility for safe food and may reduce the level of preventive controls needed by you upon receiving

Purpose

The Canadian Food Inspection Agency (CFIA) created this document as guidance to help regulated parties comply with the Safe Food for Canadians Regulations.

It's your choice

You may use other guidance documents that have been developed by provincial governments, industry associations, international partners or academic bodies, as long as they can achieve the same outcome. Always ensure that the document you choose is relevant for your particular business, product or products, and market requirements.

What's included

This guidance document outlines the recommended elements of a SFSAP:

  • defining product specifications
  • supplier selection
  • terms of a supplier agreement
  • supplier list
  • maintenance and verification (SFSAP and agreements)

Refer to the Tell me more! section for additional sources of information that may help you develop your SFSAP.

What's not included

While this guidance document provides information that can help you develop a SFSAP, it is not exhaustive—the specifications of a SFSAP will be unique for each business.

The criteria and requirements of a Supplier agreement will depend on the size and complexity of the food business and the hazards that present a risk of contamination of a food.

Roles and responsibilities

Food businesses are responsible for complying with the law. Compliance is demonstrated by ensuring that the commodities and processes for which they are responsible meet regulatory requirements. If a written preventive control plan (PCP) is required, the food business develops a PCP with supporting documents, monitors and maintains evidence of its implementation, and verifies that all control measures are effective.

CFIA verifies the compliance of a food business by conducting activities that include inspection, and surveillance. When non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.

Supplier Food safety assurance program

With a SFSAP you can:

  • establish product specifications and the criteria/requirements your suppliers need to comply with
  • clearly communicate the product criteria/requirements to suppliers
  • establish a list of suppliers willing and able to provide products that are safe and suitable for use

A SFSAP should include the following six elements.

1. Product specifications

For each product you are sourcing, determine and outline the specifications (criteria, requirements and guidelines) that apply. For example:

  • Microbial food safety factors such as:
    • guidelines on the microbiological safety of food
    • time and temperature controls to prevent growth of pathogens as an ingredient or food moves through the processing steps
    • parameters to prevent growth of pathogens such as water activity or pH
    • use of inhibitors to prevent growth of pathogens
  • Chemical food safety factors such as:
    • veterinary drug and pesticide residue limits
    • permitted food additives
    • maximum levels for contaminants and toxins
  • Allergens
    • food ingredients considered a priority allergen in Canada
  • Compositional requirements
    • grades
    • composition
    • quality
  • Suitability factors such as:
    • no signs of deterioration or damage
    • maintained under sanitary conditions
    • free from filth, insects, chemicals and other foreign substances
  • Food labelling requirements such as:
    • declaration of allergens present or that may have come in contact with the food or ingredient
    • list of ingredients
    • product name
    • storage conditions
    • cooking instructions
    • net content declaration
  • Packaging requirements such as:
    • food grade
    • container size
    • permeability
  • Storage temperature requirements such as:
    • Refrigeration at 4°C or less to prevent spoilage or growth of pathogens

2. Supplier Selection

Select your suppliers on their ability and willingness to provide products that comply with your specifications. A questionnaire can be used to gather the information needed to better understand a supplier, their products and the food safety controls in place. It can help you obtain information on whether the company has adequate controls to ensure the safety and suitability of the products supplied and whether they are subject to oversight by a recognized body.

  • Consider the following questions when selecting a supplier to establish a supplier agreement:
    • Is the supplier a licence holder under the Safe Food for Canadians Regulations?
    • Does the supplier have a HACCP-based system in place that is audited by an independent and qualified auditor, or are they certified against a Global Food Safety Initiative (GFSI) recognized program or other accredited certification body?
    • Is the supplier subject to a foreign system of inspection that is recognized by Canada?
    • Is the supplier licenced or certified by a foreign regulatory body as eligible to produce and/or export those products?
    • Does the supplier train their employees in hygienic manufacturing practices, and food safety hazards?
    • Does the supplier have controls to ensure the maintenance and operation of their establishment, storage and/or transport of products in a clean and sanitary condition, including a focus on:
      • sanitation
      • personnel hygiene
      • pest control
      • condition of the establishment
      • removal of contaminated materials and waste in a manner that does not pose a risk of contamination
    • Does the supplier have a 3rd party audit of their food safety system?
    • Can the supplier provide audit reports?
    • Can the supplier provide Certificates of Analysis that demonstrates product compliance with specifications from a Canadian laboratory accredited by Standards Council of Canada (SCC) or a foreign laboratory accredited to internationally recognized standards?
    • Does the supplier have controls for allergens?
    • Does the supplier have controls to ensure the ingredients and materials they obtain to manufacture, prepare, treat or preserve a food ingredient or manufacture packaging materials and labels are safe and suitable?
    • Is the supplier only a distributor or are they the person that manufactures, prepares, stores, packages or labels the product? If yes, can they demonstrate that they have adequate controls to ensure that they obtain products that meet your specifications?
  • As applicable, obtain and review the following.
    • Specifications on their:
      • ingredients: for example, composition, storage conditions, shelf-life, physico-chemical properties such as pH, aw
      • packaging materials and labels: for example, chemical migration, physical dimensions, material specifications and performance specifications and recommendations for storage
      • non-food chemicals: for example, conditions of use including what it can be used on, the concentration for use (dilution with water), temperature of use, duration of application, rinsing and recommendations for storing
    • Their HACCP plan and controls for the maintenance and operation of their establishment in a clean and sanitary condition
    • Letters of no objection from Health Canada, or other references from Health Canada on the safety, suitability or acceptability for use
    • Certificates of analysis showing their product is safe and has a good history of compliance
  • When feasible, conduct an on-site visit of the supplier`s premises to confirm the accuracy and implementation of their controls. If the supplier is subject to third party audits, obtain a copy of the audit reports and review them.

3. Supplier agreement

The agreement you establish with a supplier states the terms they are expected to meet. For example, the agreement could define:

  • the documents to be provided by the supplier as ongoing assurance that the products they supply continue to meet the terms of the agreement:
    • Letter of continuing guarantee accompanying each product supplied
    • Certificate of analysis
    • Audit reports from an independent and qualified auditor
  • the requirements for notifying you of changes to the specifications of their products or ingredients of the food they supply
  • what they should expect in terms of on-site visits by you or a 3rd party to audit the accuracy and effectiveness of their controls
  • what is required of them when you identify an issue with their product
    • This could include documents showing that they took corrective actions to address the issue and prevent its re-occurrence.
  • the agreement duration and renewal

Each supplier agreement should be signed and dated by you and the supplier.

4. List of suppliers

It is important to maintain a list of the suppliers that you have established an agreement with, and to refer to this list when receiving products - to verify that they are from one of your suppliers.

A list of suppliers could describe:

  • the name and contact information of your supplier
  • a description of products covered by the terms of your agreement with them
  • date the agreement with them expires

The supplier list should be up-to-date and amended any time a new supplier is chosen, or an existing agreement with a supplier is terminated.

5. Verification of the SFSAP

The SFSAP should be verified at least annually to determine how well your supplier controls are working. Establish verification procedures that outline:

  • the activities to be conducted such as:
    • inspection/testing of incoming materials
    • on-site audit of suppliers to assess their food safety system, including their control measures, records and the state of the establishment and equipment
    • review of 3rd party audit records
  • the procedures for each activity:
    • who will conduct the verifications
    • how the activity is completed
    • frequency of each activity

6. Maintenance of the SFSAP and supplier agreements

Ensure that your SFSAP, including your supplier agreements are amended when there is:

  • a new or amended Canadian requirement
  • a change in the product specifications or ingredients
  • a change made to the terms of the agreement

When a supplier fails to take corrective actions, or does not provide evidence showing corrective actions were taken to address an issue with their product, the supplier agreement should be terminated.

Tell me more! Further reading

The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. CFIA is not responsible for the content of documents that are created by other government agencies or international sources.

CFIA references

Other references

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