Canadian Partners in Quality (C-PIQ)
1. General program information
This manual sets out the program requirements and operational procedures of the Canadian Partners in Quality (C-PIQ) Program. The C-PIQ Program is an integrated inspection system, which provides an alternative to the traditional hands on inspection by the Canadian Food Inspection Agency (CFIA) for tablestock potatoes exported to the United States. Companies wishing to operate under C-PIQ must meet a number of requirements in order to be registered by CFIA and obtain export certificate and must maintain a specific performance standard in order to remain in C-PIQ.
Participation in the program is voluntary. Operators will be required to sign a participation agreement with the CFIA. This agreement will outline the commitment and responsibilities for both the company and CFIA, right of CFIA access to company premises, criteria for termination, as well as fee structure.
In addition to meeting the criteria for C-PIQ, participants must meet all applicable requirements under the Safe Food for Canadian Act (SFCA) and the Safe Food for Canadians Regulations (SFCR) which will include obtaining a Safe Foods for Canadians (SFC) licence. The requirements for the operation and maintenance of C-PIQ registered establishments (Annex A) apply to establishments registered under the C-PIQ Program. In the case of export shipments, produce packed in C-PIQ establishments must meet the requirements of the importing country.
As a licence holder participants must meet part 5 traceability and part 4 preventative controls requirements of the SFCR. Division 6 requires the documentation of preventative controls in a written preventative control plan (PCP) that must address both food safety and consumer protection. This includes the requirement to perform and document a full hazard analysis to identify any chemical, physical or biological hazards that require control. The plan must also detail the measures taken to ensure any requirements related to grade, standard of identity, labelling are being met.
Participants are responsible for the development of their own quality assurance system and production controls in accordance with C-PIQ requirements, which are implemented to ensure that quality (grade, size, maturity), and applicable packaging and labelling requirements are met. The quality assurance system will reflect the nature of their operation, type of product and the physical layout of their facility. The written procedures and control measures will constitute the Company Quality Assurance (QA) Manual, which must be provided to the CFIA at the time of application. The condition of the facility and the quality of the product are the responsibility of the Operator of the C-PIQ establishment. Credibility of the establishment in controlling their operation on a consistent basis is critical in maintaining C-PIQ integrity.
It is the Operator's responsibility to implement effective measures and procedures that are well documented and maintained for review by CFIA. It is the Operator's responsibility to provide training to staff and to control and complete export documents. Definitions set out in (Annex B) may be useful in understanding terminology relating to quality assurance systems.
The CFIA will maintain full responsibility and authority for the design and implementation of C-PIQ, registration of participants, verification of compliance, enforcement of
C-PIQ and legislated requirements, and issuance of C-PIQ export documents to C-PIQ establishments. CFIA will follow an established audit process to evaluate compliance with the C-PIQ Program.
1.2 Acceptance process
The C-PIQ acceptance process is designed to be consistent across the industry and to verify that companies are knowledgeable about and fully compliant with the principles of the C-PIQ Program. A company must demonstrate, on a consistent basis that they have operational control of their QA system and that product meets required quality standards.
Steps for registration under the C-PIQ program
- Application – A copy of the application for consideration as an establishment under the Canadian Partners in Quality Program (C-PIQ) (Annex C), the C-PIQ Program Manual and participation agreement may be obtained from the local CFIA inspection office.
- Companies who wish to proceed with registration must return a completed application form to the local CFIA office along with the appropriate application for consideration fee, which is non-refundable. The Operator will provide a written and electronic copy of the Company QA Manual. It is against this written plan that the operation and maintenance of the establishment will be assessed. Please note that the application fee is valid for 12 months, unless the applicant does not satisfactorily complete the pre-validation or validation periods, at which point the company will need to re-apply as a new applicant and submit another application for consideration along with the applicable fee.
- The CFIA will review the Company QA Manual to confirm that it is acceptable to begin pre-validation, and ultimately, prior to granting registration, that it meets the requirements of the C-PIQ Program.
- The Operator shall perform a self-assessment of the establishment (facilities, surroundings, equipment, etc.) using the Establishment Inspection Report (Annex D) making corrective actions where the establishment does not comply with the necessary requirements. The completed Establishment Inspection Report must be submitted prior to the request for pre-validation audit.
- Note: If the establishment has implemented Canada Gap (the Potato Producers and Packer On-Farm Food Safety program) and has been audited by an independent auditor within one year of application, the Operator may provide proof that the establishment has satisfactorily implemented all requirements, in lieu of the Establishment Inspection Report.
- Prior to registration, a pre-validation audit by the CFIA must be requested by the Operator to verify compliance with the C-PIQ Program. This request is made when the Operator feels that all the required pieces of the establishment's QA system are in place, and the establishment is ready for assessment. As part of this pre-validation audit, the CFIA will ensure the establishment meets the requirements set out in (Annex A) and has in place the control measures described in their Company QA Manual. This pre-validation audit is designed to identify any deficiencies and the need for changes or improvements. The Operator will be informed if there is a need for additional preparation and subsequent audits before proceeding to the validation period. The number of pre-validation audits shall not exceed 3. If this number is exceeded, the Operator will need to re-apply as a new applicant and submit another application for consideration along with the applicable fee.
- The validation period is designed to confirm that the company is implementing C-PIQ on a consistent basis in accordance with their written quality assurance system, applicable regulations and C-PIQ requirements. During this validation period, all export shipments to the United States from the establishment must be inspected and certified by the CFIA. In addition, the CFIA will audit the QA system weekly to confirm the establishment is maintained and operated in accordance with C-PIQ. The validation period will be for, the greater of, a minimum of 5 weeks or 25 export shipments to the United States (where a shipment is 25,000 pounds or greater). In the case of low volume or infrequent packers of export shipments to the United States, upon agreement between the CFIA and the Operator of the establishment, the company's QA system may be assessed taking into consideration interprovincial shipments occurring during the validation period provided a certain number of shipments are export shipments.
- Before an establishment may be recommended for registration, 3 consecutive satisfactory audits must be obtained. More than 5 audits may be required where the Operator is unable to satisfactorily meet the requirements for validation. However, if more than 8 audits are required, the Operator of the establishment must conduct and document a thorough review of the QA system and manual to fully address the non-conformities preventing validation.
- If the Operator has not obtained a minimum of 3 consecutive satisfactory audits after12 validation audits, additional audits will not be performed. The Operator must re-apply as a new applicant and submit another application for consideration along with the applicable fee.
- A C-PIQ Audit Report will be completed by CFIA auditors after each visit, and once the establishment has successfully completed the validation period, an audit report will be issued recommending registration as a C-PIQ registered establishment. An Operator of a C-PIQ registered establishment will be required to sign a participation agreement and pay the C-PIQ registration fee. Once the participation agreement is signed, CFIA will provide the company with a certificate of registration for prominent display as long as the company meets the requirements for participation in the program.
- Submission of the application for consideration and registration of an establishment under the Canadian Partners in Quality Program (C-PIQ) (Annex C) form is required only at the time of initial registration. Submission of this form is also required at the time of renewal of C-PIQ registration for payment purposes and processing of registration renewal. C-PIQ Operators are required to provide CFIA with any changes to the initial registration.
- The participation agreement is signed annually and the C-PIQ establishment registration fee is submitted at time of signing the participation agreement. The participation agreement covers the period of September 01 to August 31 and states the responsibilities of both the CFIA as well as the management and personnel of the C-PIQ registered establishment.
1.3 Verification/audit process
The C-PIQ Program utilizes an audit based inspection process to verify compliance with the Company QA Manual. Product quality, monitoring and control procedures, and C-PIQ export document completion are the responsibility of the Operator of the C-PIQ establishment. The Operator may choose the type of monitoring system to implement as well as have some flexibility in the method and limits for monitoring. However, it is essential that the establishment is operated and maintained in accordance with (Annex A) and that the product meets quality requirements. Failure to do so may result in additional audits and enforcement action by the CFIA, as necessary, to maintain the overall integrity of the program.
The role of CFIA is to verify that:
- operational control is maintained by the company (actually doing what they say they are doing)
- operations comply with C-PIQ requirements
- product prepared in the establishment meets the quality (grade, size, maturity), and applicable packaging and labelling requirements
The C-PIQ Audit Report is a summary of the audit findings and corrective actions necessary, if any.
Non-compliance's observed by auditors are identified and categorized based upon the impact on program integrity and product quality. Continued failure by an Operator of a C-PIQ establishment to demonstrate satisfactory controls may result in the suspension or cancellation of registration. CFIA audit frequency is based upon the ability of the Operator to maintain effective control of their QA system.
Pre-validation audits are announced; in most cases verification audits are unannounced. All audits start with a brief meeting between company management and the audit team and conclude with another meeting following the verification process. The audit will be conducted by an audit team, one of whom will assume the role of lead auditor. During the audit, the team will observe, interview, ask questions, review records and inspect product. The results of the audit will become the objective evidence by which compliance will be determined. At the closing meeting, the lead auditor will outline the audit findings, request corrective action with time frames to address non-conformities, and provide an overall evaluation for the company. These findings will be confirmed in a C-PIQ Audit Report, a copy of which will be provided to the company.
1.4 Compliance and enforcement
The C-PIQ Program permits the Operator flexibility in the design and implementation of a quality assurance system. However, where the integrity of the C-PIQ Program is compromised, and where terms of the participation agreement have not been met, the CFIA will assess the non-compliance, and where appropriate, take enforcement action.
Enforcement action may include:
- the assessment of non-conformities and the request for corrective action
- warning letters
- suspension or cancellation of your C-PIQ registration and/or the SFC Licence
The Operator of the establishment will be advised in person and by way of a written C-PIQ Audit Report when there are grounds for suspension. Where the C-PIQ registration is suspended, the Operator must not issue C-PIQ export documents, and shipments marketed in export trade to the United States while the establishment is under suspension will require inspection by the CFIA.
The Operator will receive confirmation of the suspension by way of a written notice of suspension. This written notice of suspension will include a list of the non-conformities/ deficiencies leading to the suspension, a request for a comprehensive corrective action plan satisfactory to CFIA, and the date of suspension. A satisfactory corrective action plan must be provided to the CFIA and implemented within 30 working days from the date the notice of suspension is sent to the company.
The suspension will remain in effect until the required corrective actions have been taken and verified by the inspector as being effective in correcting the non-conformities and preventing a re-occurrence. Furthermore, in the case of a suspension issued in respect of a critical non-conformity, the suspension will remain in effect for a minimum of 7 calendar days. If a suspension is issued in respect of grading of product, traceability, lot identification or issuance of C-PIQ export documents or transfer documents, the suspension will remain in effect until the CFIA has inspected and certified a minimum of 125,000 kg of produce (shipped from the C-PIQ establishment in export trade to the United States). The Operator will receive written confirmation of suspension being lifted. A failure to meet requirements during the period of suspension may result in an extension of suspension.
Failure to provide and implement the effective corrective actions by the date specified in the notice of suspension, will result in CFIA initiating procedures to cancel registration and the establishment's participation in the C-PIQ Program.
The Operator of the establishment will be provided with a written notice of cancellation of participation in the C-PIQ Program from the CFIA identifying the date on which the cancellation will be effective, and will be provided with an opportunity to be heard, by way of a written submission, in respect of the cancellation prior to the date of the cancellation.
As of the effective date of the cancellation of the establishment's participation in C-PIQ, all references to the C-PIQ Program or the establishment's participation therein must be removed from all of the establishment literature, packaging, etc.. in whatever format it may exist, and the C-PIQ certificate of registration and all unused C-PIQ export documents must be returned to the CFIA.
The Operator of an establishment, for which a C-PIQ registration has been cancelled, may reapply as a new applicant, but must comply with the same criteria and requirements that apply to any new applicant.
The CFIA reserves the right to cancel an establishment's participation in C-PIQ after a total of 3 suspensions, or not to accept a C-PIQ application from an establishment that has twice had a C-PIQ registration cancelled.
1.5 Special circumstances
C-PIQ is an alternative to traditional hands-on inspection by the CFIA for tablestock potato shipments exported to the United States. Therefore the Operator of an establishment choosing to be registered under the C-PIQ Program will not normally request and receive inspection and certification for shipments prepared by the establishment. However, under unusual circumstances, an Operator may request traditional inspection and certification (subject to current inspection fees), and still maintain C-PIQ status. An example of such circumstance may be a request by a receiver for government inspection to meet an importing country's requirement (other than the United States). Requests for hands on inspection will be dealt with on a case by case basis as resources permit.
Shipments for which an inspection has been requested must be fully prepared and accessible for inspection by the CFIA. It is the responsibility of the Operator to ensure that all monitoring procedures are followed as per the Company QA Manual for product for which inspection is requested.
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