DEVELOPING THE PREVENTIVE CONTROL PLAN(PCP)
A PCP is a written plan to ensure that food is safe and fit for consumption and conforms to consumer protection requirements.
Preventive control plans are not a new concept for many food businesses. For example, federal meat and fish processors already have in place food safety systems such as the Food Safety Enhancement Program (FSEP).
These programs are examples of a PCP. It is, in fact, an internationally accepted approach based on the Codex Alimentarius General Principles of Food Hygiene. Therefore, the CFIA is allowing companies to use other PCP approaches that have been developed by other food safety authorities, or industry associations.
In brief, A HACCP plan and a PCP are both include a hazard analysis and a description of the control measures applied by a food business operator to ensure food safety.
It is always recommended to ensure that the information in the PCP is tailored for your particular business, foods, and market requirements.
Elements of The Preventive Control Plan
A written PCP includes the following:
1. A hazard analysis that describes the biological, chemical, and physical hazards that are reasonably expected to contaminate the food.
2. Descriptions of the control measures used to control those hazards, and the evidence showing they are effective.
3. Descriptions of the critical control points (CCPs) in your process, including the related: control measures, the critical limits, the monitoring and corrective action procedures.
4. Procedures to verify that the PCP has been implemented as written and is effective at preventing, eliminating or reducing to an acceptable level the hazards in the food.
5. Evidence that you have implemented your written PCP.
6. In addition, the written PCP includes the following:
a) Descriptions of the measures you have in place to meet the consumer protection requirements (such as labelling, packaging, grading, standards of identity and net quantity)
b) The supporting documents such as the information you used to determine your hazards, the rationale for identifying your critical control points, and other data.
Steps of Developing The PCP
Assemble the team
Include key people on your team to cover all aspects of your food operation for developing the PCP. Consider using people that: understand the practical aspects of food operations, such as the process flow, and the technology and equipment used in your facility and are knowledgeable in the area of food safety, including the microbial, chemical and physical hazards related to the food being prepared.
Ensure the establishment is operated and maintained as required
The first task is to make sure that the way you operate and maintain the establishment meets the requirements applicable to your operation. The requirements are the basic practices a food business must follow to reduce the risk of introducing hazards to the food through the processing environment.
Perform a hazard analysis and establish procedures
The next step is to perform a hazard analysis on your food, determine control measures and document it all by applying the following process.
Preventive Control Plan Implementation
Once the PCP developed, you need to implement it into your day-to-day operations. This involves:
1. Staff training.
2. Generating records that show you have implemented your PCP and retaining those records.
3. Verifying that the PCP is implemented as written and is effective in preventing food safety hazards, resulting in compliance with the SFCR.
Maintain the Preventive Control Plan
Once you have developed and implemented your PCP, maintain it by reassessing it at a frequency appropriate to your food business, for example annually, and revising it as necessary. The PCP also needs to be reassessed and revised when:
a) Something is new or has changed. For example, with the regulatory requirements, food produced, ingredients or incoming materials, product formulation, equipment, production flow, processing step or production volumes.
b) A problem has been identified. For example, a deficiency or deviation observed during in-house monitoring or verification procedures, non-compliance identified by CFIA or third-party auditors, customer complaints that reveal a problem with the PCP, food recalls or unsatisfactory laboratory results.
Reassessing your plan includes reviewing records and conducting on-site assessments of all preventive controls.
