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Preventive control plan templates for importers

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  1. Checklist for foreign supplier preventive controls and food safety system
  2. Template for describing the hazards associated with your imported food and how those hazards are being controlled
  3. Templates for describing your PCP verification procedures and for recording your verification activities
  4. Template to describe the measures in place to meet consumer protection requirements

The preventive control templates provided in this document are meant to demonstrate what food importers need to consider and what needs to be addressed in a preventive control plan (PCP). The templates are generic and can be modified to suit your food business. Instructions for completing the templates, as well as examples, are provided within the document. The examples included in this document are not exhaustive and are meant to illustrate the type of information you could include in the templates and how you could complete the templates, should you choose to use them. The information you provide in your PCP will be based on your specific food business and import process.

The document A guide for preparing a preventive control plan – for importers explains what is generally included in an importer's PCP and describes a step-wise process of developing your PCP.

Before you get started, consult the Preventive control plan interactive tool to determine if you need a preventive control plan under the Safe Food for Canadians Regulations (SFCR).

Keep in mind

The SFCR includes PCP requirements for domestic food businesses (including animal welfare), exporters and importers. This document applies specifically to importers and provides guidance on how to prepare the food safety and consumer protection aspects of your preventive control plan.

Refer to A Guide for Preparing a Preventive Control Plan: Domestic Food Businesses and the Exporting food: A step by step guide for more information on addressing domestic food processing and export activities into your PCP.

There are four sets of templates for the PCP:

  1. Templates you can use to check that your foreign supplier has preventive controls in place that meet the food safety outcomes of sections 50-81 for their establishment and a food safety system in place that meets the requirements of section 89.
  2. A template you can use to describe the hazards associated with the food you import and how those hazards are being controlled that meets the requirement of section 89(c)(i).
  3. Templates you can use to describe your procedures for verifying your preventive control plan is effective to meet requirement and for recording your verification activities that meets the requirement of section 89(c)(vi) and 89(c)(vii).
  4. A template you can use to document the measures you have in place to meet the consumer protection requirements (for example, labelling, grading, standards of identity and net quantity) from the applicable sections referred to in 89(1)(a) and (b).

Note

The preventive control requirements are found in Part 4 of the Safe Food for Canadians Regulations (SFCR) and requirements for the written preventive control plan are found in sections 86 through 89. The requirements of a written PCP are further explained in Regulatory requirements: Preventive control plan (PCP).

Checklist for foreign supplier preventive controls and food safety system

Maintenance and operation of a foreign supplier's establishment checklist

You need to ensure that the food you import is prepared under conditions that provide the same level of food safety protection as food prepared in Canada. This means ensuring that your foreign supplier's establishment is operated and maintained in a manner that is consistent with the preventive control requirements in sections 50 to 81 of Part 4 of the SFCR. These requirements ensure the processing environment and personnel in the foreign establishment are not a source of contamination to the food.

The maintenance and operation of a foreign supplier's establishment checklist is designed to help you confirm this.

Here are suggestions for completing the template.

How is this requirement being addressed

Maintenance and operation of a foreign supplier's establishment checklist
SFCR section Requirement How is this measure being addressed
11
89(4)
50

Sanitation

  • The establishment, and any conveyances or equipment used in it, are clean and in a sanitary condition.
  • Cleaning and sanitizing activities do not contaminate food.
  • Supplier is located in the United States and there is a food safety recognition arrangement in place between Canada and the US that covers these imported foods and includes a requirement for sanitation consistent with what is described in section 50 of the SFCR.
  • Foreign supplier is in good standing with the competent authority in the United States – the US Food and Drug Administration.

Here is the full version of the Maintenance and operation of a foreign supplier's establishment checklist | PDF (73 kb) (printable version).

Foreign supplier food safety system checklist

You need to ensure your foreign supplier has a food safety system in place that is consistent with the preventive control plan requirements for food prepared in Canada. These requirements are described in section 89 of the SFCR and are based on Codex hazard analysis and critical control points (HACCP) principles. Specifically, you must ensure your foreign supplier has taken steps to identify hazards and associated control measures for the foods to be imported. They should also have taken steps to identify any critical control points (CCPs). Where there are CCPs, ensure that they have established critical limits, that they have procedures in place for monitoring critical limits and corrective action procedures for each critical control point.

The foreign supplier's food safety system checklist is designed to help you confirm this.

Here are suggestions for completing the template.

Is this adequately addressed

Justification

Foreign supplier food safety system checklist
Hazard identification by the foreign supplier
SFCR section Requirement Is this adequately addressed Justification
89(1)(c)(i) & 89(4)

Hazard identification and evaluation

Your foreign supplier has determined all biological, chemical and physical hazards that may be reasonably expected to pose a risk to the food and how these hazards are controlled.

This is done by considering each input, each processing step and each cross contamination point.

  • Yes
  • No
  • Supplier is certified against a British Retail Consortium (BRC) food safety standard
  • This standard includes a Hazard Analysis and Critical Control Points (HACCP)-based food safety plan that is consistent with the requirements of 89(1)(c)(i) of the SFCR.
  • supplier has provided proof of certification that is up-to-date
    [Note: you should keep a copy of this information in your PCP and indicate this in your checklist]

Here is the full version of the Foreign supplier's food safety system checklist | PDF (53 kb) (printable version).

2. Template for describing the hazards associated with your imported food and how those hazards are being controlled

Hazard identification and control measures template

When preparing a PCP, you are required to have a description of the hazards (biological, chemical and physical) and the control measures that are in place for each type of food you import. You can get this information by discussing with your foreign supplier the hazard associated with the food and how those hazards are being controlled by the foreign supplier at the time that the food is manufactured, prepared, stored, packaged or labelled in the foreign establishment.

The hazard identification and control measures template is designed to help you describe this information.

Here are suggestions for completing the template.

Food type / Common name

Biological hazards/Chemical hazards/ Physical hazards

How are hazards being controlled

Supporting documentation/evidence

Hazard identification and control measures template
Food Type Common name Biological hazards Chemical hazards Physical hazards How are hazards being controlled Supporting documentation/evidence
Grain-based food Biscuits or cookies n/a Undeclared Allergens – peanuts, eggs, wheat Plastic from packaging Addressed by foreign supplier during packaging and labelling step – supplier located in USA and is in good standing with USFDA – US food safety requirements include hazard identification and control measures Purchase order showing origin of product is the USA

A mock-up of the package design with allergen statement.

Dried herbs and spices Black peppercorns Salmonella Pesticides Aflatoxin n/a Supplier conducts fumigation following a validated treatment procedure, sift/screening and metal detection

Foreign supplier fumigation, sifting / screening, and metal detection records.

Food Safety Practices Guidance For Spice Manufacturers

Inspection records from the foreign food safety authority

Honey Liquid honey n/a Drug residues Glass or packaging material Assurance from supplier that apiary has a procedure for administering drugs to their bees Letter of from supplier
Fresh fruit or vegetables Broccoli E. coli O157:H7
Norovirus
Pesticides n/a

Supplier implements Good Agricultural Practices ensuring that their farming and harvesting practices do not contaminate the produce

Supplier analyses produce at a certified laboratory

Company has CanadaGAP certification

Here is the full version of the Hazard identification and control measures checklist | PDF (40 kb) (printable version).

3. Templates for describing your PCP verification procedures and for recording your verification activities

Your PCP must include how you verify that its implementation results in in the import of safe and compliant food.

PCP verification procedures template

You need to develop and record verification procedures that will be followed by yourself or someone in your import business to verify your PCP. A verification procedure is an explanation of how you ensure that the foreign supplier control measure is consistently implemented and effective at controlling the hazard associated with your imported food.

The PCP verification procedures template was designed to help you describe your procedures. The information in the template would need to be updated if you start to import new products or if you need to update your verification procedures or frequency.

Here are suggestions for completing the template.

Food type / Common name

Description of control measures to be verified

Verification procedures (what, how, who)

Frequency

Please note, the SFCR does not prescribe how often you should conduct your verification procedures. Your frequency will depend on the type of food you import, the hazard being controlled and how often you import.

Justification of Frequency

Records

PCP verification procedures template
Food Type Common name Description of control measures to be verified Verification procedures (what, how, who) Frequency Justification of frequency Records
Grain-based foods Biscuits Allergen labelling Quality control person to check the label has appropriate allergen labelling. When label changes When the label is changed the shipments are spot checked to ensure all information is required is on the new label design. Receiving logs and the label design mock-up
Grain-based foods Biscuits – nut free Allergen control Quality control person to take 3 random samples in shipment – send to laboratory for allergen testing. Every 6 months or when recipe changes No issues with supplier so far – if an issue is found I will increase frequency Certificate of analysis from laboratory
Dried herbs and spices Black peppercorns Biological contamination Quality control person to take 3 random samples in each lot - send to laboratory for microbiological testing. Every shipment Shipments are once a year Receiving logs
Certificate of analysis from laboratory
Honey Liquid honey Drug residue contamination Agreement with supplier to provide certificate of analysis to ensure drug residues meet Canadian requirements - Person receiving shipment to check for certificate with shipment and give to quality control person Every shipment Just started to import honey from this supplier. Will adjust frequency once the supplier has shown good history with their product Certificate of analysis from supplier
Shipment logs
Fresh fruit or vegetables Broccoli Pesticide residue and
biological contamination
Agreement with supplier to provide certificate of analysis to ensure pesticide residues are within the MRL and there are no microbial contaminates – Person receiving shipment to check for certificate with shipment and provide to quality control person. Every new growing season or new lot Growing conditions change which affects the application of pesticides and the conditions of soil; different lots could come from different farming plots which may have different growing conditions

Certificate of analysis from supplier for pesticide residue analysis and microbiological analysis

Receiving logs and checklist

Here is the full version of the PCP verification procedures template | PDF (41 kb) (printable version).

PCP verification activity record template

Once you have developed your verification procedures you will need to keep a record of when those procedures were completed. This activity is a second assurance that your imported food is meeting the requirements of the Act and regulations and your PCP has been effectively implemented.

The PCP verification activity record template was designed to help all importers, including smaller importing businesses, to record their planned PCP verification activities.

Here are suggestions for completing the template.

Food type / Common name

Date shipment received

Verification conducted by

Findings

Follow up actions

Final decision

PCP verification activity record template
Food Type Common name Date shipment received Verification conducted by Findings Follow up actions Final decision
Grain-based foods Biscuits 2018-03-29 John Doe Label has allergens listed No further follow up actions needed n/a
Grain-based foods Biscuits – nut free 2018-01-12 Jane Doe Certificate of analysis received from lab on Jan 19/18 – no allergens found No further follow up actions needed n/a
Dried herbs and spices Black peppercorns 2018- 05-04 Jane Doe Certificate of analysis received from lab on May 20/18 – presence of Salmonella Holding shipment – sent the laboratory results to supplier to show findings – waiting on decision from supplier Shipment was destroyed and supplier will be replacing lot.
Honey Liquid honey 2018-02-14 John Doe Certificate of analysis not sent with shipment Holding shipment until supplier sends the certificate of analysis Certificate received from supplier on Mar 3/18 – honey sent to buyer
Fresh fruit or vegetables Broccoli 2018-05-30 John Doe Both certificate of analysis received with shipment No further follow up actions needed n/a

Here is the full version of the PCP verification activity record template | PDF (40 kb) (printable version).

4. Template to describe the measures in place to meet consumer protection requirements

Measures for consumer protection requirements template

In addition to the food safety requirements, you need to describe the measures that you have in place to demonstrate that you meet applicable requirements for labelling, packaging, standards of identity, grades, and net quantity for your foods – these are referred to as consumer protection requirements. These specified requirements found in section 89(1)(a) and (b) of the SFCR are listed in the measures for consumer protection requirements template. You should read the full requirement in the SFCR to understand which requirements apply to your products.

The measures for consumer protection requirements template is designed to help you capture these descriptions.

Here are suggestions for completing the template. The template is pre-populated with the SFCA/R section and the description of the requirements.

For the purpose of the example below, broccoli is not prepackaged, black peppercorns are prepackaged other than consumer prepackaged, biscuits or cookies and honey are consumer prepackaged foods.

Foods with this requirement

Measures to address requirement

Measures for consumer protection requirements template
SFCA/R section Description of requirement Foods with this requirement Measures to address requirement
201 Standards prescribed for food – common names Honey

Provided the Canadian Standards of Identity Volume 5 - Honey to my supplier.

Verified through laboratory testing every 6 months.

205 Prepackaged food, other than consumer prepackaged food – one official language requirement Black peppercorns Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details
206(1) Consumer prepackaged food – bilingual language requirement

Biscuits or cookies

Honey

Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details
208 Legibility of label All products except for broccoli which is not prepackaged Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details
218 Prepackaged food – information (common name, name and principal place of business, requirements of the Food and Drug regulations) All products except for broccoli which is not prepackaged Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details
221 Consumer prepackaged food – declaration of net quantity Honey
Biscuits or cookies
Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details
296 Label of edible meat products – exception (label does not meet requirements) n/a n/a
306 Mandatory grading Honey

Compositional grade requirements verified through laboratory testing every 6 months. Provided Canadian Grade Compendium Volume 6 – Honey and Volume 9 – Import Grade Requirements to my supplier.

All honey is imported with a grading certificate – if a grade certificate is not available – the honey will be sent to a laboratory for testing.

Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details.

307 Optional grading n/a n/a
316 Eggs – Canada A – size designation n/a n/a
317 Prepackaged fish – class and size designation n/a n/a
321 Fresh fruits or vegetables – size designation n/a n/a
322 Processed fruit or vegetable products – size designation n/a n/a
324 Honey – colour class Honey

Provided Canadian Grade Compendium Volume 6 – Honey and Volume 9 – Import Grade Requirements to my supplier. Verified through laboratory testing every 6 months.

Randomly check labels on shipments when doing shipment checks at receiving. See receiving logs/checklist for details.

325 Maple syrup – colour class n/a n/a
326 Prepackaged cut of beef n/a n/a
328 Livestock carcass – removal of marking n/a n/a
6(1) of Act Food is labelled and packaged in a manner that is not false, misleading, deceptive or likely to create an inaccurate impression. All Randomly check labels and packaging on shipments when doing shipment checks at receiving. Approved a mock-up of the packaging. See receiving logs/checklist for details and packaging mock-ups.

Here is the full version of the Consumer protection controls template | PDF (122 kb) (printable version).

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