Operational procedure: Onion Pilot Project for Canadian Partners in Quality Preventive Control Inspection

1.0 Purpose

The purpose of this document is to provide guidance to Canadian Food Inspection Agency (CFIA) inspection staff on preventive control and traceability inspection procedures for the Onion Pilot Project for the Canadian Partners in Quality (C-PIQ) Preventive Control Inspection (PCI).

This document is intended to be used in conjunction with CFIA guidance as referenced in Section 3.0.

This document is written with the assumption that inspection staff have been trained in the Standard Inspection Process (SIP) and the Digital Service Delivery Platform (DSDP).

This pilot project will run from October 1, 2021 to August 31, 2024. The information in this operational procedure is subject to change as required during the pilot project period.

2.0 Authorities

Safe Food for Canadians Act (SFCA)
Safe Food for Canadians Regulations (SFCR)

The inspection powers, control actions and enforcement actions authorized by the above legislation are identified and explained in the Operational guideline: food regulatory response guidelines.

3.0 Reference documents

4.0 Definitions

Definitions are located in the documents listed below or as a defined word where it is intended to supersede the definitions within the glossary documents:

5.0 Acronyms

Acronyms are spelled out the first time they are used and are consolidated in the Food business line acronyms list.

6.0 Operational procedure

This operational procedure provides inspection procedures specific to the Onion Pilot Project for the C-PIQ PCI. Where more specific PCI guidance is required compared to what is provided in the Standard Inspection Process – Volume 3.0 (SIP), it will be indicated in this section. The general method of verification provided in the Canadian Partners for Quality (C-PIQ) program manual is to be followed unless otherwise stated in this document. The SIP approach is to be followed to complete all required inspection sub-elements (SE) and commodity inspection requirements for entry in the Digital Service Delivery Platform (DSDP) (accessible only on the Government of Canada network). The DSDP trigger to be selected for all PCI's related to CPIQ establishment is 'Export Permission'.

6.1 Acceptance process

Participation agreement

Upon request to enter the Onion Pilot Project for the Canadian Partners in Quality (C-PIQ) PCI, operators will sign the program Participation agreement (accessible only on the Government of Canada network – RDIMS 15665147) provided by inspectors.

Requests for establishment number

Inspectors will submit an electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network) to the Food Import Export Permissions Operational Guidance and Expertise Group to request the reservation of a C-PIQ establishment number.

Establishment list

Once assigned, inspectors will ensure that establishment information is entered accurately in the Onion Pilot C-PIQ Registration List (accessible only on the Government of Canada network – RDIMS 15650400).

Mock export document review

Under the pilot project, inspectors will test a minimum of 25 mock C-PIQ export documents (accessible only on the Government of Canada network – RDIMS 3388920) prepared by the operator for the corresponding export shipments.

Since the establishments are not fully registered yet, these shipments will continue to be graded and certified by CFIA for export to the United States (US) (Operational procedure: fresh fruits or vegetables grade verification, Operational procedure: issuing an export certificate for fresh fruits and vegetables (accessible only on the Government of Canada network – RDIMS 11179558)) which includes all applicable inspection fees (CFIA Fee Notice (accessible only on the Government of Canada network)).

At the discretion of the inspector and based on establishment history, volume of exports, etc., the number of mock export documents can be increased during the acceptance process. The mock inspections should be completed over a minimum of 2 weeks. Once completed, the operator will be fully registered into the C-PIQ program and be subject to C-PIQ audit and export document fees which are included in the Canadian Partner's in Quality (C-PIQ) Fees.

Mock export document review is to include:

proper completion of documents
verification of the operator's worksheet connected to products included on each official certificate
verification of training for the employee signing the export document
verification of training for employees completing grade verification
verification that product meets United States (US) import requirements
verification of traceability of certified product (trace the commodity from the source level to the next point of distribution) of at least 1 of the 25 mock document reviews

Registration tracking

Please refer to Annex A which provides the Onion C-PIQ Pilot Project Registration Tracking Sheet (accessible only on the Government of Canada network – RDIMS 15627763 checklist for inspectors to track that all requirements are met for an establishment to be included in the Onion Pilot Project for the C-PIQ PCI. It also tracks the mock export document reviews.

Assign establishment number

Upon successful completion of the mock export document review, CFIA will assign a C-PIQ registration number to the operator.

C-PIQ logo

When an establishment is nearing satisfactory completion of the acceptance process, CFIA may provide the C-PIQ logo template to the establishment, upon written request, in order to permit the establishment to make arrangements for pre-printing of the logos. Annex B provides instructions for inspectors on how to prepare the logo. The establishment must be informed that CFIA will not be held liable for any costs incurred for printing of the logo should C-PIQ registration be ultimately denied.

The logo may appear in either black and white, or may be depicted in colour. If in colour, the colours must be as per the official CFIA C-PIQ logo. It is recommended that the C-PIQ logo used on pallets be of a minimum 3 inch diameter.

Registration certificates

Once an establishment has completed the acceptance process, inspectors will prepare a registration certificate using the C-PIQ certificate of registration template (accessible only on the Government of Canada network – RDIMS 4036766) and provide it to the operator.

Requesting export documents

Once a facility is fully registered into the C-PIQ program, the operator may request export documents from the CFIA using the Request for Export Documents for C-PIQ Establishments Fresh Fruits and Vegetables (Annex H of the CPIQ program manual). Inspectors are to track all export documents provided to industry using the Export Document Tracking Sheet (accessible only on the Government of Canada network – RDIMS 2377764).

6.2 Inspection frequency

The frequency of PCI for C-PIQ establishments is determined as follows (Table 1):

all program participants: Sub-Elements (SE) 1.2 and 1.4 each twice per year (exception: additional audits can be completed if inspectors have concerns over the operator's ability to meet C-PIQ requirements)
new program participants: the following SE must be verified within the first 6 months – 1.2, 1.4, 1.1(a), 7.1, 6.1, 3.2, 5.1
- All other SE to be completed within the first year
CanadaGAP certified C-PIQ participants: all SE over 36 months (satisfactory CanadaGAP report to be reviewed by inspectors annually during a PCI)
C-PIQ participants without CanadaGAP: all SE verified annually

Table 1. PCI scope and frequency determination for C-PIQ participants
Participant criteria	SIP sub-elements	Time frame for CFIA verification
All Participants	1.2, 1.4	2 times per year (exception: additional audits can be completed if inspectors have concerns over the operator's ability to meet C-PIQ requirements)
New participants	1.1(a), 3.2, 5.1, 5.2, 6.1, 7.1	Within first 6 months of program entry
New participants	As applicable^{Table Note 1}: 1.1(b)(c), 1.3, 2.1, 2.2, 2.3, 3.1, 4.1, 5.3, 5.4, 7.2	Within the first year of participation
Participants with CanadaGAP	All applicable^{Table Note 1} SE	Within 36 months, minimum 4 SE per year (satisfactory CanadaGAP report to be reviewed by inspectors annually during a PCI)
Participants without CanadaGAP	All applicable^{Table Note 1} SE	Every year

Billing

Audit fees as outlined in the C-PIQ Participation Agreement (accessible only on the Government of Canada network – RDIMS 15665147) are applicable to the mandatory twice per year audits that include SE 1.2 and 1.4. If inspectors must go in more than twice per year to complete all remaining PCI SE, there will no charge for the additional PCI's. Exception: at the inspector's discretion additional audits may be conducted more than twice per year for SE 1.2 and 1.4 should the inspector have concerns about whether the operator's controls meet C-PIQ requirements.

All CFIA audit documentation is to be uploaded into DSDP case files for record keeping.

6.3 Product verification audit

Lot verification of products is the only option to be used for the Onion Pilot Project for the C-PIQ PCI. Inspectors are to assess the establishment based on requirements outlined in section 3.4 of the C-PIQ program manual – Lot verification of product.

Note: onions for export to the US must meet the US marketing orders for grade and inspection requirements. Inspector must ensure that establishments are meeting US import requirements. Refer to Summary of US onion import requirements (accessible only on the Government of Canada network – RDIMS 18451600) for additional information.

Note: section 3.4.5 of the C-PIQ program manual indicates that 4 hour notice must be provided by operators to CFIA prior to all shipments prepared using lot verification. During the pilot project, this requirement will be modified to the following:

if product is not available for verification by inspectors during a required PCI for SE 1.2 and 1.4, operators are to notify the inspector prior to all shipments following the audit until inspectors have had the opportunity to verify product prior to the next audit. Inspectors are to complete the product verification as soon as possible following the audit.

6.4 Non-compliance

The Standard Inspection Procedure (SIP) sections 4.5 to 4.9 are to be followed for identified non-compliance during audits. Section 5 of the C-PIQ program manual can be consulted to assist in determining severity and overall impact on the integrity of the C-PIQ program.

When a non-regulatory non-compliance is identified during a PCI, it is to be included in the inspection report provided to the operator.

The following are examples of non-regulatory non-compliance control actions that can be taken:

meeting with the regulated party
refusal to sign export documents
reverting back to lot by lot grade verification (commodity inspection by CFIA inspectors, plus applicable fees)
removal from CPIQ program

Examples of non-regulatory non-compliance:

the written export controls do not describe the process the exporter has implemented to ensure the exported foods meet the foreign country requirements
there are no documents available that provide evidence that the exported products meet US requirements (requirements available in the Export Certification Task Table – United States – Onions (accessible only on the Government of Canada network – RDIMS 11359551))
verification records are not complete
export document scan was not sent to the CFIA office
an export document was missing

For general enquiries related to this operational procedure document, please follow established communication channels, including submitting an electronic Request for Action Form (e-RAF) (accessible only on the Government of Canada network).

Annex A Onion C-PIQ Pilot Registration Tracking Sheet

RDIMS 15627763 provides inspectors with the Onion Pilot Project for the C-PIQ PCI Registration Tracking Sheet (accessible only on the Government of Canada network – RDIMS 15627763).

Annex B – C-PIQ logo instructions

RDIMS 3397387 provides inspectors instructions for how to create a new C-PIQ logo (accessible only on the Government of Canada network – RDIMS 3397387).

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