Canadian Importers
The importer is responsible to make sure that the imported food is safe, and to ensure that the written preventive control plan meets the requirements of the Safe Food for Canadians Regulations.
In addition to the PCP requirements, importers should establish and maintain several other records and documents related to receiving and responding to complaints, recall and traceability.
Developing the Preventive Control Plan
The SFCR requires that imported food be subject to the same level of hazard analysis as food prepared in Canada. Since the Canadian importer has no direct control over the foreign supplier, the supplier assessment is critically important to ensure that hazards are identified by the foreign supplier and effective control measures are in place to deal with these hazards. A complete hazard analysis requires from the importer to consider both the hazards inherent to the food and hazards that may be caused by the foreign supplier. Therefore, to demonstrate hazard identification:
1. Conduct On-Site audits of the foreign supplier to identify and document all hazards associated with the food to be imported.
2. Source from a foreign supplier who is subject to internationally recognized third party evaluations.
3. Or source from a foreign supplier that is in a country that has a food safety recognition arrangement with Canada.
Implementing your preventive control plan
Once you have developed the written preventive control plan, importer needs to implement it into day-to-day operations.
Maintaining the preventive control plan
Once the CPC developed and implemented, maintain it, but reassessing it as necessary (for example, when deficiency or deviation observed during monitoring or verification procedures, or when non-compliance identified by third party auditors, customer complaints, or unsatisfactory laboratory results).
The Establishment-Based Risk Assessment Model
The CFIA is currently adapting the ERA model for food importers (Importer Risk Assessment model). The Establishment-based Risk Assessment model for food establishments (ERA-Food) is a tool developed by the CFIA to evaluate food establishments based on the level of risk they represent to Canadian consumers.
The ERA-Food model uses scientific data and establishment specific information gathered from the additional establishment information questionnaire provided to food license holder in My CFIA in order to evaluate a facility and determine an establishment’s level of risk. How often an inspection occurs will be guided by where a facility falls in the three categories of risk assigned by the ERA-Food model. Higher risk establishments will involve more error while lower risk establishments will involve less error. Below is the list of risk factors included in the ERA-Food model, as published in the CFIA website.
All prerequisite programs should be documented and regularly audited, and are established and maintained separately from the HACCP plan. It is defined as universal steps or procedures that control the operational conditions within a food establishment allowing for environmental conditions that are favourable to the production of safe food.
List of risk factors included in the ERA-Food model
Source: CFIA, the Establishment-based Risk Assessment model for food Establishments: The science behind it
Inherent Risk Factors
• Commodity*
• Type of products*
• Volume*
• Type of activities conducted at the establishment*
• Direct distribution to vulnerable population
• Processing steps (slicing, dicing, etc.)
* Related to the health impact (DALYs) attributed to these risk factors
Mitigation factors
• Presence of additional processes
• Presence of a sampling plan
• Food safety Certification
• 3rd part audits
• Full time QA personnel
• Control of incoming supplies (e.g. letter of guarantee, audits of suppliers, etc.)
• Presence of a sampling plan
• Food safety Certification
• 3rd part audits
• Full time QA personnel
• Control of incoming supplies (e.g. letter of guarantee, audits of suppliers, etc.)
Compliance Factors
• History of enforcement actions
• Recalls(class I,II, II)
• Food Safety confirmed complaints
• Inspector assessment:
• Recalls(class I,II, II)
• Food Safety confirmed complaints
• Inspector assessment:
1. Incoming inputs
2. Process control
3. Import control
4. Sanitation/ biosecurity/ biocontainment
5. Pest control
6. Chemicals
7. Hygiene and biosecurity
8. Employee training
9. Equipment design and maintenance
10. Buildings
11. Water, ice and steam
12. Waste disposal
13. Receiving, transportation and storage
14. Traceability and control
15. Complaints
Inherent risk factors represent those associated with a specific food commodity, operation or manufacturing process. These factors take into account the type of product, volume, and its direct distribution to a vulnerable population, such as residents of nursing homes, hospitals or daycares.
Mitigation factors are the measures or strategies that a food establishment is using to reduce the inherent risk and therefore reduce the risk of a food safety issue. Examples of these strategies include the implementation of an internationally recognized private certification scheme (such as HACCP or a preventive control plan), having a full-time employee responsible for quality assurance and food safety on site, and the application of specific risk-prevention processes (for example high pressure processing).
Compliance factors refer to a food establishment’s track record with respect to how well it has complied with its own preventive control measures and with regulatory requirements. This is assessed using the food establishment’s historical and current data such as information pertaining to recalls, inspection reports and enforcement actions.
