Corrective action procedures for your preventive control plan

Introduction

Establishing Critical Control Point (CCP) is the fifth principle of a Hazard Analysis Critical Control Point (HACCP) system and is an essential part of a Preventive Control Plan (PCP). A deviation from the critical limits established for a CCP can lead to unsafe food. Corrective action procedures document ahead of time the steps to be taken when a deviation occurs so that you are ready to re-establish control promptly when a deviation occurs at a CCP.

Keep in mind

Although corrective action procedures are required in your PCP for CCPs only, you still need to take corrective action for any deviation from your other preventive controls.

Purpose

The Canadian Food Inspection Agency (CFIA) created this document as guidance to help food businesses comply with the requirements of the Safe Food for Canadians Regulations.

What is included

This document outlines the steps for establishing corrective action procedures at CCPs and preparing corrective action records. It provides background on corrective actions and a template that you can customize to create individualized corrective action procedures and records.

What is not included

The examples provided are not exhaustive. The level of detail required will be unique for each business.

The document does not specify the corrective actions to be taken.

Roles and responsibilities

Food businesses are responsible for complying with the law. They demonstrate compliance by ensuring that the commodities and processes for which they are responsible meet regulatory requirements. If a written PCP is required, the food business develops a PCP with supporting documents, monitors and maintains evidence of its implementation, and verifies that all control measures are effective.

The CFIA verifies the compliance of a food business by conducting activities that include inspection, and surveillance. When non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.

Designing and implementing corrective action procedures

When a deviation from a critical limit has occurred at a CCP, prompt corrective action is necessary in order to re-establish control at this critical step in your process. A corrective action procedure facilitates prompt action and should anticipate any deviation likely to occur at that CCP. Correcting a deviation includes:

• identifying and isolating the affected food, evaluating its safety and stopping unsafe food from reaching the market
• determining the root cause of a deviation and preventing recurrence
• documenting the deviation and corrective actions taken

Every written corrective action procedure should answer some basic questions related to who, what, how, as well as what record to document corrective actions on.

Step 1. For each control measure applied at a CCP, identify who will take the corrective actions:

• identify the person(s) responsible for overseeing the corrective actions; someone who has a thorough understanding of the product, the process, and the preventive control plan
• identify the person who implements the corrective action.
  • it may be the person performing the monitoring, or the superior the monitor reports to who's responsible for taking the corrective action(s)

Step 2. Document what will need to be done to re-establish control and how it will be done. For example:

• immediately adjust the process to bring it back under control, if possible
• immediately isolate and identify all food or production lots that may be affected including the food produced after the last acceptable monitoring result
• stop production, if necessary, to prevent unsafe food from being produced
• conduct a food safety assessment of the affected food (the assessment may include such things as sampling and testing) and determine the appropriate disposition, including if the food is assessed as:
  • safe to consume, the food may be sold or used as an ingredient or component in another food
  • not safe to consume but can be brought into compliance. For example, a heat treatment can be applied to the food or the food can be reworked to make it safe before it is distributed or sold
  • not safe to consume and cannot be brought into compliance
    • it is disposed of appropriately (for example, destroyed)

Step 3. Document the steps to be taken if the deviation affects the safety of other production lots that have already entered the marketplace.

Step 4. Document the steps for determining the root cause of the deviation and preventing recurrence:

• investigate and determine what went wrong to cause the deviation
• implement corrective action(s) to restore control
• once implemented, verify the effectiveness of corrective action(s) to ensure that the parameter(s) have been brought back under control
• if corrective actions were not effective in ensuring control has been established, the food is controlled as above and additional corrective actions developed, implemented and their effectiveness verified
• if during the process of determining the root cause and adjusting control measures to prevent recurrence, you identify a hazard that was not considered during the development of the PCP, you should review your PCP to determine whether it needs to be controlled

Step 5. Prepare a standardized record to document the details of the corrective actions as outlined in steps 1 to 4.

Appendix 1 provides an example of a standardized corrective action record.

Tell me more! Further reading

The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. The CFIA is not responsible for the content of documents that are created by other government agencies or international sources.

CFIA references

• Conducting a hazard analysis
• Determining critical control points and their critical limits
• Monitoring procedures for your preventive control plan
• Record keeping for your preventive control plan
• Guide for preparing a preventive control plan for domestic food businesses
• Verification procedures for your preventive control plan

Other references

• Codex Alimentarius Commission, General Principles of Food Hygiene, CXC 1-1969, 2020

Appendix 1: Example of a Corrective action(s) record

Report number:
Date and time deviation was observed:
Completed by (Name & Position):
Establishment name:

Part A Deviation description

1. Description of deviation:

1. What was affected; food or food contact surfaces?
2. Identification of all food (include name, type, code, amount & weight) affected:
3. How was food controlled?
4. Was production stopped?
5. Has any food left the control of the operator? (If so – follow recall procedures)

Part B Food safety assessment

2. Was food safety compromised?  Yes Box  No Box

1. Description of food safety hazard:
2. How was food tested or evaluated?
3. Results of testing or evaluation:
4. Disposition (released, reworked, destroyed):

Part C Corrective action(s)

3. Description of all corrective actions taken or to be taken:

Part D Completion of corrective action(s)

4. Was/were corrective action(s) completed immediately? Yes Box No Box

1. If Yes, sign and date
2. If no, the target date for completion; sign and date upon completion

Part E Root cause and control measures

5. Was the root cause identified? Yes Box No Box

1. If yes, detail the root cause:
2. What will be done to prevent recurrence?
3. Have unforeseen or previously unidentified hazards been identified?
4. Target date for completion of measures to prevent recurrence:
5. Actual completion date of measures to prevent recurrence:

Part F Verification

6. Corrective action(s) were completed and effective  Yes Box No Box

7. Control measures were completed and effective  Yes Box  No Box

8. Verified by:

9. Date and time:

10. Signature