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CFIA Assessment of Establishment 38, XL Foods Inc.
Section 4: Commitment to Food Safety

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4.1 Management Presence and Engagement

During the temporary resumption of processing operations, the CFIA observed the presence of senior establishment management in the processing and sampling rooms prior to and during operations. The managers were seen evaluating the implementation of the establishment's food safety programs, and discussing and receiving feedback from front line employees and supervisors.

An additional number of quality assurance personnel and supervisors were also noted to be present at the entrance of the processing area at start-up, and within the processing room during operations to ensure oversight of, and adherence to, the establishment's good manufacturing practices program.

4.2 Establishment Cooperation with CFIA Staff

During the period of temporary operations, Establishment 38, XL Foods Inc., management acted upon all CFIA inspection staff requests in a timely fashion.

Establishment representatives immediately addressed all onsite observations identified by CFIA inspection staff and implemented corrective actions in an appropriate manner. As time progressed through the three days of operations, CFIA inspection staff noted fewer deficiencies, and this finding suggests the establishment was becoming more proficient at correcting deficiencies without CFIA involvement.

All establishment documents and records were made available to the CFIA upon request. Following receipt of laboratory results, the establishment's E. coli O157:H7 test results were made available without delay to CFIA inspection staff for verification.

4.3 Management Commitment to Food Safety

The adoption of an effective food safety culture, at all levels of the Establishment 38, XL Foods Inc. organization, is one of the most important means of assuring the production of safe food. There are a number of important elements that are key to achieving this objective, including:

  • Senior management affirmation and communication of the organizations' commitment to food safety;
  • A robust food safety governance, including senior positions responsible for overseeing and implementing the organization's food safety program and working with CFIA inspection staff to monitor overall food safety system performance; and
  • A strategy for ongoing employee engagement, including training and communication.

Accordingly, the CFIA requested that Establishment 38, XL Foods Inc., provide a written description of the steps that the establishment has taken and plans to take, in order to ensure that a commitment to food safety is reflected in organizational practices on a daily basis.

On October 18, 2012, XL Foods Inc. responded by providing the CFIA with a letter, which described plans for senior management to:

  • Re-affirm and communicate the establishment's commitment to food safety to all employees;
  • Provide enhanced food safety training sessions to management and staff; and
  • Re-validate certain food safety intervention strategies.

The letter touches on some of the key elements required to put in place an effective food safety culture.  However, it did not define specific timelines or means to measure successful implementation. This letter is attached as Annex C.

The establishment also made a presentation to the CFIA and Health Canada that outlined its plans for enhancing food safety controls going forward. This presentation described XL Foods Inc's plans to enhance their food safety controls, including revised sampling and testing protocols, enhanced corrective action processes, and employee training.

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