Corrective action procedures for your preventive control plan
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.
Establishing corrective actions for each Critical Control Point (CCP) is the fifth principle of a Hazard Analysis Critical Control Point (HACCP) system and is an essential part of a Preventive Control Plan (PCP). A deviation from the critical limits established for a CCP can lead to unsafe food. Corrective action procedures document the steps to be taken when a deviation occurs and help you re-establish control by:
- identifying and isolating the affected food, evaluating its safety and stopping unsafe food from reaching the market
- determining the root cause of a deviation and preventing recurrence
- documenting the deviations and corrective actions taken
The Canadian Food Inspection Agency (CFIA) created this document as guidance to help food businesses comply with the requirements of the Safe Food for Canadians Regulations.
You may use other guidance that has been developed by provincial governments, industry associations, international partners, or academic. Always ensure that the corrective actions guidance you choose is relevant for your particular business, product or products, and market requirements.
What is included
This document outlines the steps for establishing corrective action procedures at CCPs and preparing corrective action records. It provides background on corrective actions and a template that you can customize to create individualized corrective action procedures and records.
Refer to the Tell me more! section for additional sources of information that may help you establish your corrective action procedures.
What is not included
The examples provided are not exhaustive. The level of detail required will be unique for each business.
The document does not specify the corrective actions to be taken.
Roles and responsibilities
Food businesses are responsible for complying with the law. They demonstrate compliance by ensuring that the commodities and processes for which they are responsible meet regulatory requirements. If a written 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.
The 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.
Designing and implementing corrective action procedures
When there is an indication that a deviation from a critical limit has occurred, you have to be prepared to take corrective actions to re-establish product control. Your corrective actions should follow a standard, documented approach that is flexible enough to deal with any deviation that may occur.
Every written corrective action procedure should answer some basic questions related to who, what, how, as well as what record to document corrective actions on.
Step 1. For each control measure, identify who takes the corrective actions:
- identify the person(s) responsible for the corrective actions, someone who is competent and qualified to determine what needs to be done and act on it
- identify the person who implements the corrective action.
- it may be the person performing the monitoring, or be the superior the monitor reports to that is responsible for taking the corrective action(s)
Step 2. Document what will be done to re-establish control and how it will be done. For example:
- immediately isolate and identify all food or production lots that may be affected including the food produced after the last acceptable monitoring result was taken
- stop production, if necessary, to prevent unsafe food from being produced
- conduct a food safety assessment of the affected food (the assessment may include such things as sampling and testing) and determine the appropriate disposition, including if the food is assessed as:
- safe to consume, the food may be sold or used as an ingredient or component in another food
- not safe to consume but can be brought into compliance. For example, a heat treatment can be applied to the food or the food can be reworked to make it safe before it is distributed or sold
- not safe to consume and cannot be brought into compliance
- it is disposed of appropriately (for example, destroyed)
Step 3. Document the steps for investigating, identifying and following up if an unsafe food has entered the marketplace or has entered into the food supply chain as an ingredient for another food.
Step 4. Document the steps for determining the root cause of the deviation and preventing recurrence:
- investigate and determine what went wrong to cause the deviation
- implement corrective action(s) to restore control
- once implemented, verify the effectiveness of corrective action(s) to ensure that the parameter(s) have been brought back under control
- if corrective actions were not effective in ensuring control has been established, the food is controlled as above and additional corrective actions developed, implemented and their effectiveness verified
- if during the process of determining the root cause and adjusting control measures to prevent recurrence, you identify a hazard that was not considered during the development of the PCP, you should review your PCP to determine whether it needs to be controlled
Step 5. Prepare a standardized record to document the details of the corrective actions as outlined in steps 1 to 4, including:
- the date and time the deviation was observed or reported
- nature of the deviation including, detailed product description (for example, lot code and name of food) and specifying if food or food contact surfaces were affected
- whether a food safety assessment is made, its outcome of that investigation and details of product disposition
- what corrective actions are to be taken
- the timeframe for completion of the corrective actions including:
- a target date for completion of corrective actions
- the actual completion date for these corrective actions
- control measures to be taken to prevent recurrence, including:
- a target date for completion of these control measures
- the actual completion date for these control measures
- signature of the responsible employee
- documentation, including verification date, time and signature indicating that the verifier approves that the activity (corrective actions) were completed satisfactorily and that the corrective action was effective
Appendix 1 provides an example of a corrective action record.
Tell me more! Further reading
The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. The CFIA is not responsible for the content of documents that are created by other government agencies or international sources.
- Conducting a hazard analysis
- Determining critical control points and their critical limits
- Monitoring procedures
- Record keeping
- Step-by-step guide for domestic food businesses and exporters: Preparing a preventive control plan
- Verification procedures
- Codex Alimentarius Commission, Recommended International Code of Practice, General Principles of Food Hygiene - Annex: Hazard analysis and critical control point (HACCP) system and guidelines for its application, 2003
Appendix 1: Example of a Corrective action(s) record
Date and time deviation was observed:
Completed by (Name & Position):
Part A Deviation description
1. Description of deviation:
- What was affected; food or food contact surfaces?
- Identification of all food (include name, type, code, amount & weight) affected:
- How was food controlled?
- Was production stopped?
- Has any food left the control of the operator? (If so – follow recall procedures)
Part B Food safety assessment
2. Was food safety compromised? Yes No
- Description of food safety hazard:
- How was food tested or evaluated?
- Results of testing or evaluation:
- Disposition (released, reworked, destroyed):
Part C Corrective action(s)
3. Description of all corrective actions taken or to be taken:
Part D Completion of corrective action(s)
4. Was/were corrective action(s) completed immediately?
- Yes Box If Yes, sign and date
- No Box If no, the target date for completion; sign and date upon completion
Part E Root cause and control measures
5. Was the root cause identified? Yes No
- If yes, detail the root cause:
- What will be done to prevent recurrence?
- Have unforeseen or previously unidentified hazards been identified?
- Target date for completion of control measures:
- Actual completion date of control measures:
Part F Verification
6. Corrective action(s) were completed and effective Yes No
7. Control measures were completed and effective Yes No
8. Verified by:
9. Date and time:
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