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Operational procedure: Planned food sample collection

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1.0 Purpose

The purpose of this document is to provide guidance to Canadian Food Inspection Agency (CFIA) inspection staff on sample collection procedures related to planned sample collection in the Food Business Line (FBL) Sample Collection Plans for all food commodities.

Refer to Appendix 1 for an overview of the sample collection plans.

This guidance 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 document is intended to be used in conjunction with the Operational guideline: Food sample collection.

2.0 Authorities

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

Common inspection references

Food inspection references

Commodity specific inspection references

DSDP sample collection specific references

Other references

4.0 Definitions

Definitions are located in the documents listed below:

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 guidance specific to planned food sample collection for the FBL, under the Food Sample Collection Plan (accessible only on the Government of Canada network).

An inspector may collect planned samples as part of the annual work plan (for example, National Chemical Residue Monitoring Program (NCRMP), National Microbiological Monitoring Program (NMMP)). Sample cases are uploaded into the DSDP system at the beginning of the fiscal year. Monitoring samples fall under the scope of planned sample collection. Directed samples that are targeted may also fall under the scope of planned sample collection.

This procedure is to be used by CFIA inspection staff once a Sample Collection Plan case is received in the DSDP inspection queue and when planned sample results require further action.

DSDP is used to capture planned sample collection information for the following purposes:

  • Sample collection: Work planning and tracking of CFIA collected samples
  • Sample results: Documenting the communication and further actions for sample results reported as anything other than satisfactory
    • Includes CFIA and third party collected samples
    • Excludes all shellfish harvest area sample results (compliant and non-compliant)

The Issues Management System (IMS) is also used to track sample collection information when sample results trigger the Food incident response process (FIRP). If the FIRP is triggered, time spent on the food safety investigation, including, but not limited to the recall activities, effectiveness checks etc. should be tracked in IMS. Refer to the Operational procedure: As required sample collection for more information.

6.1 Prepare for the inspection

Refer to SIP, Section 3, Step 1 and Operational guideline: Food sample collection, Section 6.1. In addition to the general guidance provided in these documents, the following guidance applies to planned sample collection.

Review the Sample Collection Plan cases in the DSDP inspection queue to determine which samples require collection. One Sample Collection Plan case is used to track the collection of one target sample identified in the Food Sample Collection Plan (accessible only on the Government of Canada network). Multiple Sample Collection Plan cases will be assigned if more than one sample is to be collected.

6.2 Conduct the inspection

Refer to SIP, Section 4, Step 2 and Operational guideline: Food sample collection, Section 6.2. In addition to the general guidance provided in these documents, the following guidance applies to planned sample collection.

6.2.1 Collect the sample

Using the annual sample collection plans distributed by the Area/Regional Operations and the commodity specific sample guidelines, determine the sample that is required to be collected. Inspectors will consult with regional contacts to determine which regulated party to collect the samples from, based on criteria such as the commodity being sampled, product availability and distribution. Inspectors should collect samples at the manufacturer or importer level, wherever possible, unless the Food Sample Collection Plan (accessible only on the Government of Canada network) or Food misrepresentation direction (accessible only on the Government of Canada network – RDIMS 13862494) indicate otherwise. The Import Control Tracking System (ICTS) (ICTS.net – accessible only on the Government of Canada network) can be used to search for imported products.

  • Any products that are grown/produced/harvested in Canada and packed domestically (for example, grown in New Brunswick, packed in Ontario), should be submitted under the appropriate domestic plan.
  • Any products that are grown/produced/harvested outside of Canada should be submitted under the appropriate import plan. Samples collected under an import plan can be packed in Canada or outside of Canada.

Multiple surveillance samples under the same sample plan may need to be collected from one regulated party location during the fiscal year. If this is the case, inspectors should avoid collection of samples of the same or similar products from the same establishment within a short period of time to ensure samples are independent of each other.

Refer to the Food misrepresentation direction (accessible only on the Government of Canada network – RDIMS 13862494) for additional documentation requirements for samples collected under this direction.

6.2.2 Record information in Laboratory Sample Tracking System (LSTS) and submit the sample for analysis

The following LSTS guidance is for samples collected and submitted by CFIA inspectors; it does not apply to third party samples.

Refer to the LSTS User Services User Guide (accessible only on the Government of Canada network – RDIMS 3495373) for instructions on how to record sample collection data in LSTS.

Refer to the commodity specific sampling guidelines and assessment criteria (accessible only on the Government of Canada network) for instructions on LSTS submissions which are sent to CFIA laboratories and LSTS data entry for third party laboratories that are under contract with CFIA.

Link the LSTS sample submission to the DSDP Sample Collection Plan case by entering the DSDP case number in the LSTS "Comments" field in the section "Display comments on Report of Analysis" (select "Yes"). Refer to section 6.2.3 for additional information.

Note: For domestic raw milk samples, the responsible party is the name of the Provincial authority which collected the sample. The Provincial authority maintains the information necessary for traceback purposes.

Refer to the following references for commodity specific shipping instructions:

6.2.3 Record information in DSDP

Refer to Annex A: DSDP data entry – CFIA sample collection (accessible only on the Government of Canada network – RDIMS 14985319) for step-by-step instructions on how to document sample collection data in the DSDP Sample Collection Plan case.

Select the appropriate Sample Collection Plan case from the DSDP inspection queue, using the sample plan code, which depends on the commodity being sampled.

Within the DSDP Sample Collection Plan case, verify prepopulated information and populate the applicable sample collection task data (refer to Table 1).

Table 1. Recording inspection data in Digital Service Delivery Platform (DSDP)
DSDP field DSDP data field selection
Inspection trigger Sample Collection Plan
Task type Sample Collection
Inspection task level 1 Food Sample Collection Plan
Inspection task level 2

Select the appropriate analysis type:

  • Microbiological
  • Misrepresentation – Composition
  • Extraneous Material
  • Chemical Residue
  • Other
Inspection task level 3

Plan Code:

For samples collected by the CFIA: Refer to the "Special Instructions" field (displayed in the inspection case) which will indicate the sample plan code to be entered into the "Inspection Task Details" and "Inspection Task Level 3".

Inspectors will link the LSTS sample submission to the DSDP Sample Collection Plan case by entering the System Identification (ID) in the Additional Reference IDs field.

Note: Task time entries are recorded in DSDP for the time associated with sample collection only. The time taken to enter the samples into the LSTS or shipping of the samples is not included in DSDP. If a third party collects the sample and the CFIA enters the data into LSTS or ships the samples, this time is not tracked in DSDP.

Note: Shellfish harvest area: for inspection case validation, the following fields are not mandatory: "Party", "Establishment", "Regulatory Contact" and "Location of inspection". At this time, DSDP is being used as a work planning tool and for tracking of sample collection by CFIA inspection staff. The location of the shellfish harvest area is not entered into DSDP and DSDP is not used to document follow-up activities. For non-compliant shellfish harvest area sample results, the inspector is to refer to the Operational procedure: control response plan for molluscan shellfish test results exceeding Canadian maximum levels, standard or guidelines.

The following sections (6.2.4 to 6.4) are not applicable to shellfish harvest area samples.

***The first part of the sample collection task is now complete; the sample has been collected and sent to the lab for analysis. The second part of the sample collection task will be initiated once the sample results are received. Refer to section 6.2.4 for more information.***

6.2.4 Determine if immediate control action is required

Review the sample results reported in LSTS or in the monthly Chemical Residue Violation Report to determine next steps. Refer to the Operational guideline: Food sample collection, Section 6.2.6 for more information.

If satisfactory sample results are reported, the inspector is not required to take any further action. The satisfactory results are not entered into DSDP, and they do not need to be communicated to the regulated party, unless the regulated party has held the product pending receipt of the results.

Sample results reported as anything other than satisfactory require further action.

For sample results that are considered a food safety risk, refer to Food inspection guidance: Incident response (accessible only on the Government of Canada network) for guidance that may be applicable.

6.2.5 Identify the regulated party

Using the information collected at the time of sampling and entered into LSTS, determine the regulated party (ideally the licence holder, if applicable). It is at this regulated party that the inspector will conduct further actions and follow-up regarding the non-compliant sample. Refer to Table 2 for more information.

Table 2: Identify the regulated party and refer the DSDP case
If Then
The regulated party responsible for the manufacture or import of the product is unknown Contact the regulated party where the product was sampled to determine this information.
The sample was manufactured or imported in a different sub-district than it was collected

The work unit that collected the sample will receive the sample result. This result will need to be referred by email to the correct sub-district for their action. Information related to the sample (for example, sample result, product photos, parent sample collection case number, communication) should be shared by email.

After creating a new Sample Collection Plan (sample assessment) case in DSDP, the correct sub-district responsible for the product will enter the Sample Collection Plan (sample assessment) case number in the notes section of the original deactivated sample collection plan case. (Note: the original case will not need to be reactivated to enter a note. This field remains active after deactivation.) Refer to Annex C: DSDP data entry – 3rd party and referred – sample results otherthan satisfactory (accessible only on the Government of Canada network – RDIMS 15000355) for more information.

The correct sub-district is unknown The Regional and/or Area contacts may need to be engaged to ensure the sample result is referred appropriately.
The party profile is not found Contact the regulated party and request that they enroll in My CFIA. If the regulated party does not enroll, follow the process outlined in the SIP, 3.3.1 Regulated party/commodity information to create a establishment profile in DSDP.
The NCRMP samples were collected by third party samplers The name of the regulated party may be available on the initial sample submission form. Submission forms and photos of the samples can be requested from the Food Safety Science Services Division (FSSSD) Chemistry following existing communication channels.
The TS samples were collected by third party samplers The necessary information for further action will be provided to inspection staff by the Office of Food Safety and Recall (OFSR), Policy and Programs Branch (PPB) and/or Area/Regional Operations following existing communication channels.

6.2.6 Record sample results in DSDP

Sample results reported as anything other than satisfactory must be documented in a DSDP Sample Collection Plan case, either by reactivating the original Sample Collection Plan case, or by creating a new Sample Collection Plan (Sample Assessment) case. The approach to documenting sample results in DSDP depends on who sampled the product. Refer to Table 3 for more information.

Table 3: Documenting planned sample results in DSDP
If the inspector's Then the inspector will
Sub-district collected the sample

Reactivate the original Sample Collection Plan case

Refer to Annex B: DSDP data entry – CFIA sampled – results other than satisfactory (accessible only on the Government of Canada network – RDIMS 14996797)

Sub-district was referred the sample result from another sub-district

or

Sub-district received the sample result from a third party collected sample

Create a new Sample Collection Plan case (Refer to Table 3)

Refer to Annex C: DSDP data entry – 3rd party and referred – results other than satisfactory (accessible only on the Government of Canada network – RDIMS 15000355)

Refer to Flow chart for documenting planned sample results in DSDP (accessible only on the Government of Canada network – RDIMS 16549873) for a visual representation of Table 3.

Refer to Table 4 for DSDP task data for a new sample collection plan case (third party and referred).

Table 4. Recording inspection data in DSDP for a new Sample Collection Plan (Sample Assessment) case (third party and referred)
DSDP field DSDP data field selection
Inspection trigger Sample Collection Plan
Task type Sample Collection
Inspection task level 1 Food Sample Collection Plan
Inspection task level 2 Sample Assessment
Inspection task level 3

Plan Code:

  • For samples collected by the CFIA: Select the sample plan code from the drop down list, if known.
  • For samples collected by third party samplers: Refer to the communication received from OFSR, PPB or FSSSD Chemistry's monthly Chemical Residue Violation Report for the sample plan code. If the sample plan code is not in the drop down list, select "other".

6.2.7 Determine compliance

Refer to Operational guideline: Food sample collection, Section 6.2.6.2 and SIP, Section 4.6. Refer to Appendix 2 for background information on the management and assessment of Sample Collection Plan sample results for specific CFIA national programs.

6.2.8 Categorize non-compliance

All non-compliant NCRMP samples are categorized as a minimal non-compliance. For all other national sampling programs the inspector will determine the categorization of non-compliance. Refer to the SIP, Section 4.7 for more information.

6.3 Communicate the inspection results

Refer to SIP, Section 5, Step 3 and Operational guideline: Food sample collection, Section 6.3. In addition to the general guidance provided in these documents, the following guidance applies to planned sample collection.

All sample results reported as anything other than satisfactory, except results reported as "no decision", should be communicated to the regulated party (ideally the licence holder, if applicable). For "no decision" results, consult commodity specific guidance to determine if the results should be communicated to the regulated party, depending on the level of detection of the analyte.

Note: For samples analyzed by third party contracted laboratories, an external Record of Analysis (ROA) is available upon request for sample results reported as anything other than satisfactory.

When non-compliant domestic samples are identified, Area/Regional Operations may communicate the results to the appropriate Provincial authorities for follow-up.

Table 5. Additional group(s) inspectors may be required to contact when non-compliant domestic NCRMP samples are reported
If non-compliant Then Area/Regional Operations may contact
Domestic commodities of animal origin Provincial authorities
Domestic egg
Domestic fish
CFIA Animal Health (Feed Program)
Domestic raw milk

Provincial officials responsible for collection of raw milk samples

Refer to Basic Guidelines for the Collection of Raw Milk Samples for the National Chemical Residue Monitoring Plan (accessible only on the Government of Canada network – RDIMS 3147092) for more information

6.4 Conduct the follow-up inspection

Refer to SIP Section 6, Step 4 and Operational guideline: Food sample collection, Section 6.4. In addition to the general guidance provided in these documents, the following guidance applies to the follow-up inspection for NCRMP samples.

6.4.1 NCRMP only – Communicate completion of follow-up to Science Branch

For NCRMP samples, upon completion of the follow-up activities, inspection staff should notify Area/Regional Operations. They will send the following information to Science Branch (NCRMP Samples / Échantillons PNSRC (CFIA/ACIA)):

  • DSDP Sample Collection Plan case ID
  • DSDP Sample Collection Plan follow-up case ID (if applicable)
  • the unique sample number corresponding to the non-compliant or investigative sample

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

7.0 Appendix

Appendix 1: Overview – Sample collection plans

The Food Sample Collection Plan (accessible only on the Government of Canada network) includes both CFIA and Health Canada (HC) sample plans.

CFIA national plans

The NCRMP, NMMP, and AAACIN Plans support Canada's international agreements and obligations to conduct government oversight and verification of safety of food marketed for sale in Canada. The sampling plans assist PPB in the identification of potential problem areas which may require subsequent surveillance and compliance activities.

  • NCRMP
    Conducted annually to assess human dietary exposure, perform risk assessments, monitor trends, and verify industry compliance with Canadian standards and guidelines for chemical residue contaminants.
  • NMMP, AAACIN
    Conducted annually to assess for potential health risks, perform risk assessments, monitor trends, and verify industry compliance with the Canadian standards.
  • Targeted Surveys (TS)
    Generates information on certain hazards in Canadian retail foods that enables the CFIA to focus its surveillance activities on the identified areas of highest health risk.

NCRMP, NMMP, AAACIN and TS samples are randomly collected samples from both licence holders and non-licence holders, which are referred to collectively as regulated parties.

  • NCRMP samples are collected by both CFIA inspection staff and contracted third party samplers
  • NMMP and the Additives, Adulteration, Allergens, Composition, Irradiation and Nutrition (AAACIN) samples are collected by CFIA inspection staff
  • TS samples are collected by contracted third party samplers
  • Molluscan shellfish ("shellfish") harvest area samples are collected by CFIA inspection staff and contracted third party samplers as part of the Canadian Shellfish Sanitation Program (CSSP)

The CFIA maintains a marine biotoxin monitoring program in classified shellfish harvest areas to prevent the harvesting of shellfish containing elevated biotoxin levels; samples are collected as part of the control response process to test for various microbiological and chemical contaminants. Based on the results, the CFIA may recommend to Fisheries and Oceans Canada the closing and opening of shellfish harvest areas. For further information on marine biotoxin monitoring sample collection, refer to regional Marine bio-toxin monitoring control plans and the Molluscan Shellfish, Canadian Shellfish Sanitation Program (CSSP) – Sample guidelines and assessment criteria (accessible only on the Government of Canada network – RDIMS 16050338).

Mycobacterium Bovis (Bovine Tuberbulosis (TB) surveillance) (Granuloma Submission Program (GSP))

For information on this program, refer to section 6.2.1 Mycobacterium Bovis of the operational guidance Slaughter floor operations sampling and testing chemical residues and microbes (accessible only on the Government of Canada network – RDIMS 10796096) for additional information.

HC sample plans

Total Diet Study (TDS)

There is a Memorandum of Understanding (MOU) between HC and CFIA to conduct the TDS in a major city within Canada every year. Under this study, a total of 1500 samples are collected in a 5 week period. Samples are collected and prepared as outlined in the annual Food Sample Collection Plan (accessible only on the Government of Canada network) and HC's Sampling Guideline.

HC Vibrio

There is a MOU between HC and CFIA to conduct the Vibrio study from May to October within Canada every year. Information regarding this study is outlined in the annual Food Sample Collection Plan (accessible only on the Government of Canada network) and HC's Sampling Guideline.

For both HC TDS and Vibrio samples:

  • CFIA simply collects the samples and sends them to HC in Ottawa for laboratory analysis
  • CFIA does not enter or submit these samples into LSTS, as no laboratory analysis is conducted by CFIA
  • CFIA is not involved in any follow-up on non-compliances; HC conducts all follow-up actions
  • The samples are required to be entered into DSDP for time tracking purposes only

Appendix 2: Management and assessment of Sample Collection Plan sample results – CFIA national programs

NCRMP sample results

The results from contracted third party laboratories are sent directly to FSSSD Chemistry and not directly to the respective inspector. Results from CFIA laboratories are sent to the respective inspector without an assessment and do not need to be assessed by the inspector. FSSSD Chemistry is responsible for reviewing and assessing all NCRMP laboratory results reported by both contracted third party laboratories and CFIA laboratories.

FSSSD Chemistry also provides the following information for all non-compliant results in the monthly Chemical Residue Violation Report:

  • a note indicating OFSR was contacted, if applicable, for a Health Risk Assessment (HRA) and/or Technical Risk Assessment (TRA) based on the level or nature of the chemical residue detected, along with any potential recommendation
  • a recommendation as to whether the non-compliant result requires further action based on an internal administrative guideline or action level

A NCRMP sample is assessed as non-compliant when one of following situations has occurred:

  • a banned substance is detected at any level
  • an agricultural chemical (for example, pesticide) exceeds the established MRLs or general MRLs
  • an unapproved contaminant exceeds the established safe level (in other words, Maximum Limit (ML) or CFIA action levels)
  • use of a veterinary drug (for dairy, egg, honey, fish and meat)
    • that is at or exceeds the regulatory Limit of Quantification (LOQ), when no MRL is established
    • that exceeds the established MRLs or CFIA action level
    • that exceeds the recommended Working Residue Level (WRL) (for honey samples only)

FSSSD Chemistry will:

  • contact the OFSR when the presence of a banned substance, contravening the FDR and/or SFCR, is found or as deemed necessary based on the level or nature of the chemical residue detected
  • forward any non-compliant results at the end of each month to Area/Regional Operations, Strategy and Business Integration (SBI), International Affairs Branch (IAB) and PPB in the monthly Chemical Residue Violation Report, which will also indicate any non-compliant samples that were referred to OFSR, if applicable

All non-compliant NCRMP samples included in the monthly Chemical Residue Violation Report are assessed as one of the categories listed in Table 6. The table also provides next steps for each of the non-compliant sample assessments.

Table 6: Non-compliant NCRMP sample assessments and next steps
If reported as Then
Violation Document the non-compliance in DSDP and communicate the sample result to the regulated party. A follow-up inspection is required.
Violation – Banned Substance
Violation – Above Action Level
Violation – Below Action Level Document the sample result in IMS and communicate the result to the regulated party. The external LSTS ROA can be provided to the regulated party upon request. Since the result is considered low risk, a follow-up inspection is not required; however, the sample result should be taken into consideration when planning for the next scheduled inspection.

Note: When NCRMP samples are sent to CFIA laboratories, all results (including both compliant and non-compliant samples) are assessed by lab personnel as 'No Decision' on the ROA. CFIA laboratory results are exported out of LSTS and merged with the contracted third party laboratory data and managed in an external database by FSSSD Chemistry.

Compliant results are not reported in the monthly Chemical Residue Violation Report. A compliant NCRMP laboratory result means that the sampled lot is considered to be in compliance with Canadian requirements.

NMMP, AAACIN and TS sample results

The inspector receives sample results through LSTS notification or the monthly chemical residue violation report and is required to review the results to determine compliance.

The Laboratory Coordination Division (LCD) is responsible for reviewing and assessing all TS microbiological results. For non-compliant TS results, the LCD:

  • communicates non-compliant results to the OFSR and PPB. OFSR or PPB will provide direction to inspection staff for further action.
  • communicates investigative or non-compliant results not requiring OFSR input to PPB and Area/Regional Operations. PPB will provide direction to inspection staff for follow-up action.

The FSSSD Chemistry is responsible for reviewing and assessing all TS chemical hazards and allergens laboratory test results. FSSSD Chemistry

  • notifies OFSR of potential health risks for a HRA and/or TRA. OFSR will provide direction to inspection staff for further action.

FSSSD Chemistry provides all violations on the monthly Chemical Residue Violation Report then:

  • communicates investigative or non-compliant results to PPB and Area/Regional Operations. PPB will provide direction to inspection staff for further action, if applicable.

Note: Inspectors should reference Health Canada's Policy on Extra-Label Drug Use (ELDU) in food producing animals when drug residue sample results are reported as unsatisfactory. If the drug was used in accordance with the ELDU Policy, it may be deemed compliant after gathering additional objective evidence.

Annex A: DSDP data entry – CFIA sample collection

Annex A: DSDP data entry – CFIA sample collection (accessible only on the Government of Canada network – RDIMS 14985319)

Annex B: DSDP data entry – CFIA sampled – sample results other than satisfactory

Annex B: DSDP data entry – CFIA sampled – sample results other than satisfactory (accessible only on the Government of Canada network – RDIMS 14996797)

Annex C: DSDP data entry – 3rd party and referred – sample results other than satisfactory

Annex C: DSDP data entry – 3rd party and referred – sample results other than satisfactory (accessible only on the Government of Canada network – RDIMS 15000355)