Verification 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.
Verification is an integral component of an effective preventive control plan (PCP) that, in addition to monitoring procedures, ensures ongoing control. It is the sixth principle in the internationally recognized Hazard Analysis Critical Control Point (HACCP) approach to food safety.
Verification activities are used to confirm and demonstrate that all control measures and related procedures outlined in your PCP are consistently implemented and effective in achieving the intended outcome.
The Canadian Food Inspection Agency (CFIA) created this document as guidance to help food business operators comply with the regulations set out in the Safe Food for Canadians Regulations.
You may use other guidance developed by provincial governments, industry associations, international partners, or academic bodies as long as they can achieve the same outcome. Always ensure that the guidance you choose is relevant for your particular business, product or products, and market requirements.
What is included
The document outlines the steps involved in developing verification procedures, using generic criteria and by providing:
- background information
- an example of a template that can be customized as part of an individualized PCP
Refer to the Tell me more! section for additional sources of information that may help you establish your verification procedures.
What is not included
The examples presented are not exhaustive. The verification activities depend on the size and complexity of the food business and will be unique for each business.
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 verification procedures
In your verification procedures you explain how you would ensure each control measure and procedure is consistently implemented and is effective at ensuring safe and compliant food.
Every written verification procedure should answer the basic questions: who, when, what, why and how. The procedure should also identify the records used.
Step 1. Identify who conducts the verification activities and the verification frequency:
- name a competent responsible person or team, other than the person who conducts the monitoring or corrective actions
- use external qualified third parties when verification cannot be carried out by in–house staff
- determine a frequency appropriate to the hazards associated with the food and process that is being verified
- for example, conduct critical control point verification at a higher frequency than verification of other control measures
- adjust the frequency of verification in response to the identification of problems with monitoring or corrective actions
Step 2. Describe the verification activities to be conducted, for example:
- directly observe an employee performing monitoring activities to ensure that the written procedures are being followed
- directly observe corrective actions taken by an employee to ensure that the written procedures are being followed
- review records documenting the monitoring activity to ensure the proper version of the record is used, records are complete and filled out as per the written procedures
- for example, review of retort or pasteurization charts
- review records documenting the actions taken in response to a deviation
- sample and test the environment or a food to confirm the safety of the food
- for example, swab equipment to verify the effectiveness of a sanitation program or testing final product for compliance to a microbiological guideline
- verify the calibration of equipment (for example, thermometers, timing belts and pumps)
- interview/observe employees to ensure written policies and procedures are being followed
Use multiple verification techniques, especially for critical control points. This will increase confidence that monitoring procedures are effective. For example:
- observe a person monitor a critical limit and create a record
- review past records
- conduct a microbiological analysis
You can summarize your verification procedures in a table for quick reference.
|Lab tech||End of batch||Finished food testing to ensure standards are met||Assess product cook-kill step||Lab instructions||Finished product testing analysis record|
|QA manager||End of each month||Monitoring trends to identify loss of process control||Implement improvements and catch/prevent deviations||Review of records/graphs||Document trend review record|
|QC manager||Monthly||Employee hygiene practices||Assess that employee hygiene procedures are being followed and monitored properly as per the written program||Observe floor supervisor monitoring employee hygiene||Verification control log (see example below)|
You can refer to the Preventive control plan templates – For domestic food businesses and exporters for another example.
Step 3. Describe the records that are completed to document the verification activities completed and the results of those activities.
Step 4. Specify additional procedures that relate to appropriate follow-up when problems are identified during verification. The procedure to follow may differ depending on the nature of the issue (monitoring or corrective actions, or if it is with the effectiveness of the PCP itself in maintaining control of the food safety standards or regulatory requirements).
- design your verification records to include space to comment on the outcome of the verification including what corrective action (if needed) was taken
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.
- Corrective actions
- Determining critical control points and their critical limits
- Monitoring procedures
- Preventive control plan templates – For domestic food businesses and exporters
- Step-by-step guide for domestic food businesses and exporters: Preparing a preventive control plan
- 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
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