On this page
- 1.0 Mission overview
- 2.0 Verification objective
- 3.0 Verification standards and criteria
- 4.0 Verification scope
- 5.0 Comments and observations
- 5.1 Element 1 – Process and product controls
- 5.2 Element 2 – Sanitation, biosecurity, biocontainment, Pest control and chemicals
- 5.3 Element 3 – Hygiene, biosecurity and employee training
- 5.4 Element 4 – Equipment design and maintenance
- 5.5 Element 5 – Physical structure, surroundings and maintenance
- 5.6 Element 6 – Receiving, transportation and storage
- 5.7 Element 7 – Traceability, recalls and complaints
- 6.0 Additional information
- 7.0 Follow-up
- 8.0 Conclusion
- 9.0 References
1.0 Mission overview
The Canadian Food Inspection Agency (CFIA) conducted 9 on-site verifications of fields and fresh produce packers in Mexico from October 18 to 27, 2022. They were conducted in the Puebla and Jalisco regions. These verifications included various fresh fruit and vegetable products that are eligible for export to Canada without certification. However, some producers of some commodities must be licensed under the Contamination Risk Reduction System (CRRS) to ship to Canada. CRRS certification is currently mandatory for cilantro and cantaloupe producers exporting to Canada.
The CFIA worked with Mexico's National Service of Agro-Alimentary Health, Safety and Quality (Servicio Nacional de Sanidad, Inocuidad y Calidad Agroalimentaria - SENASICA) to plan the verification. SENASICA and its State Committees were present on-site to help coordinate and execute the verifications.
The CFIA held an initial virtual opening meeting with SENASICA on October 13, 2022. SENASICA's presented the responsibilities and relationship between SENASICA and the regulated parties regarding the CRRS. The CFIA presented an overview of the verification including the objective, scope, verification procedures, and the food safety standards used in Canada.
A virtual closing meeting was held on November 10, 2022. The CFIA presented a high-level overview of verification observations.
2.0 Verification objective
The objective of establishment verifications is to observe how the exporting or manufacturing establishments produce or sell safe, unadulterated products that are eligible for the Canadian market. In addition, the verification team observes how the identified products meet Canadian requirements or provide the same level of food safety as food made in Canada. Information gathered will further assess the risk associated with imported products and promote compliance with the different participants along the food supply chain.
3.0 Verification standards and criteria
The verification standards used by the CFIA are based on international standards, such as those developed by the Codex Alimentarius Commission (Codex). Within the scope of the verification, the principles outlined in these standards were employed:
- RCP 1-1969 – General Principles of Food Hygiene
- STAN 1-1985 – General Standard for the Labelling of Prepackaged Foods
- GL-20-1995 – Principles for Food Import and Export Inspection and Certification
- GL-21-1997 – Principles and Guidelines for the Establishment and Application of Microbiological Criteria Related to Foods
- RCP 44-1995, and 1-2004 – Code of Practice for Packaging and Transport of Fresh Fruit and Vegetables
- RCP 53-2003 – Code of Hygienic Practices for Fresh Fruits and Vegetables
The CFIA structured its verification criteria using the CFIA's Integrated Agency Inspection Model (iAIM) 7 elements of a preventive control plan:
- Process and product controls
- Sanitation, biosecurity, biocontainment, pest control and chemicals
- Hygiene, biosecurity and employee training
- Equipment design and maintenance
- Physical structure, surroundings and maintenance
- Receiving, transportation and storage
- Traceability, recalls and complaints
For more information:
The CFIA's inspection model (iAIM) is outcome-based. Manufacturers can be flexible in choosing a food safety system (such as Hazard Analysis and Critical Control Points (HACCP) or good manufacturing practices (GMP)) for their preventative control plan. Any food product imported into Canada must meet the food safety, composition and labelling requirements from the Safe Food for Canadians Act, the Food and Drugs Act, and their Regulations.
4.0 Verification scope
The establishments were selected based on SENASICA's recommendations.
Each establishment verification included an opening meeting, a walk-through of the establishment, a documentation review, interviews with company representatives, and a short closing meeting.
The establishment verification scope included all 7 elements of a preventative control plan. The CFIA team focused on Elements 1 (Process and Product controls) and 7 (Traceability, Recalls and Complaints).
Commodity and establishment type | No. of sites visited | State(s) |
---|---|---|
Fresh whole tomatoes / Distribution center Greenhouse producer Packer Exporter |
5 | Puebla and Jalisco |
Fresh herbs (including cilantro) / Grower Producer |
2 | Puebla |
Fresh berries (raspberry and blackberry) / Grower Packer |
1 | Jalisco |
Fresh whole bell peppers / Greenhouse producer |
1 | Jalisco |
5.0 Comments and observations
Preventive control plan element | Total no. of observations |
---|---|
Element 1 - Process and product controls | 7 |
Element 2- Sanitation, biosecurity, biocontainment, pest, and chemicals | 4 |
Element 3 - Hygiene, biosecurity and employee training | 0 |
Element 4 - Equipment design and maintenance | 0 |
Element 5 - Physical structure, surroundings and maintenance | 0 |
Element 6 - Receiving, transportation and storage | 1 |
Element 7 - Traceability, recalls and complaints | 10 |
Total | 22 |
5.1 Element 1 – Process and Product Controls
This element covers the controls implemented by the establishment related to incoming ingredients, processing steps in production, testing, and labelling of the final product, focusing on products destined for the Canadian marketplace.
Total observations for this Element: 7
HACCP plans
- HACCP plans were not being met as designed and written in 3 establishments. 2 of the establishments were not meeting their Critical Control Point monitoring. This includes Listeria monocytogenes (Lm) environmental sampling, and wash and disinfect steps. 1 establishment was not meeting its sampling plan.
- 1 HACCP plan did not include all possible hazards for the product (including Lm).
Environmental sampling
- Controls for microbiological hazards may not be sufficient as implemented in 1 establishment. Environmental swabbing for pathogenic bacteria is conducted after cleaning and disinfecting. For example, using swab techniques to test conveyor belts for Lm. Lm environmental sampling in 1 establishment is not being conducted on all areas that present favourable conditions for Lm growth.
5.2 Element 2 – Sanitation, Biosecurity, Biocontainment, Pest Control and Chemicals
This element addresses the effectiveness of the sanitation and pest control programs implemented at the establishment, the use and control of chemicals, and the controls in place to prevent the introduction or spread of any pests or diseases.
Total observations for this Element: 4
Pest control measures in 2 establishments were ineffective in preventing pests from entering the receiving and processing areas.
- In both establishments, gaps between the loading doors and the floors were large enough for rodents and insect pests to enter.
- In 1 establishment there were multiple gaps between the roof and the ceiling large enough to allow insect pests to enter.
5.3 Element 3 – Hygiene, Biosecurity and Employee Training
This element addresses the training provided to employees and the adherence to procedures related to hygienic practices.
Total observations for this Element: 0
The verification team reviewed Element 3 – Hygiene, Biosecurity and Employee Training through on-site visit and record review. No observations were reported.
5.4 Element 4 – Equipment Design and Maintenance
This element addresses the equipment and utensils used in the establishments and the procedures in place to ensure that they are maintained, calibrated and used in a manner that does not contaminate products or packaging materials.
Total observations for this Element: 0
The verification team reviewed Element 4 – Equipment Design and Maintenance through on-site visit and record review. No observations were reported.
5.5 Element 5 – Physical Structure, Surroundings and Maintenance
This element covers the on-site conditions of the premises and surroundings, the effectiveness of the building maintenance, and the controls in place for water supply and waste disposal to prevent contamination of commodities.
Total observations for this Element: 0
The verification team reviewed Element 5 – Physical Structure, Surroundings and Maintenance through on-site visit and record review. No observations were reported.
5.6 Element 6 – Receiving, Transportation and Storage
This element addresses the controls at the establishment level for the receiving, transportation and storage of food products and packaging materials to prevent the damage, spoilage, or contamination of food commodities and to maintain their integrity.
Total observations for this Element: 1
In 1 establishment, the on-site storage temperature did not match the recommendations on the exterior shipping cases for 1 shipment.
5.7 Element 7 – Traceability, Recalls and Complaints
This element covers the controls over product traceability and recall/withdrawal capacity and the investigation conducted at the establishment level following an incident or a complaint to prevent the issue from reoccurring.
Total observations for this Element: 10
The verification team observed that the traceability system of 4 establishments is ineffective in adequately identifying and labeling received and final product.
Input level
- Product received in 2 establishments was observed to have lot code errors or missing lot codes.
- There were discrepancies in the incoming product quantity received and the accompanying shipping reports at 2 establishments.
On-site storage
- 1 establishment had un-labelled products in their cold storage.
Next point of distribution
- The lot coding on the final product in 2 establishments did not meet SENASICA requirements.
- 1 establishment mixed input product from multiple sources and did not reflect this on the final end-product labelling.
- The final end-product labelling of 1 establishment misrepresented the product as pesticide-free.
Comment: In 2 establishments, customers could dictate the information on the final end-product label, including the lot codes.
6.0 Additional information
For information only
The Mexican and Canadian controls being implemented for environmental sampling are different. Both SENASICA and the CFIA do environmental sampling for microbial pathogens immediately after cleaning and sanitizing. This is to validate the effectiveness of the cleaning and sanitizing procedures. However, the CFIA also conducts random sampling during production to assess and gather information on the microbiological level in the production environment. This is to validate the sanitation procedures and products during the entire production process.
The CFIA environmental sampling for Listeria monocytogenes (Lm) includes swabbing food contact surfacesFootnote 1 on a processing line and cold storage. Suggested food contact surfaces include:
- utensils (knives, trays)
- employee gloves/hands/aprons
- slicers, dicers, shredders
- blades of slicers
- cutting tables
- carts/racks
- conveyor belts
- scales (used to weigh Ready-To-Eat products before it is packaged)
- packaging tables
- packaging equipment (for example, vacuum packaging)
- packaging material
The final end-product is also sampled for Lm. This is critical to help identify the cause and source of Lm contamination if it happens.
Food businesses should remain vigilant regarding the presence of Lm if it has been identified as a food safety hazard to be controlled. To mitigate the risk from Lm, manufacturers are still expected to implement ood manufacturing practices (GMPs), sampling or end-product testing or both.
The CFIA website for reference:
7.0 Follow-up
The establishment, SENASICA and the State Committees took note of the observations identified during the individual establishment closing meetings.
The CFIA is confident that observations communicated on-site and within this report were addressed by the establishments. SENASICA provided the CFIA with their verifications that the corrective actions were completed.
8.0 Conclusion
These establishment verifications were completed successfully with the cooperation and support of SENASICA and the State Committees.
This mission has allowed the CFIA to:
- build on existing relationships with SENASICA
- ensure the safety of products exported to Canada
- better understand the multiple participants involved in the food supply chain
This verification permitted a direct exchange of information at the establishment level, facilitating future export of products to the Canadian marketplace. This verification provided an opportunity for the CFIA to share information on Canadian legislative requirements and contribute to compliance promotion for visited establishments.
9.0 References
For further information on the CFIA and Canadian import requirements, the following web pages may be consulted:
- The CFIA's website contains general information on the organizational structure of the CFIA, enforced laws and regulations in Canada, food recall warnings, and news on various regulatory initiatives.
- The CFIA's new consolidated Safe Food for Canadians Regulations (SFCR) requires that imported food be prepared with the same level of food safety controls as food prepared in Canada.
- The Industry Labelling Tool contains information on the requirements for food labeling and food allergens in Canada.
- The Automated Import Reference System (AIRS) shows the country and commodity specific import requirements for CFIA-regulated commodities.