Canadian Partners in Quality (C-PIQ)
2. General requirements for C-PIQ establishments
The written procedures and control measures contained in the Company QA Manual must address all of the following general requirements for C-PIQ establishments. The Industry Checklist for Development of Company QA Manual (Annex E) has been developed as a tool to assess the completeness of the Company QA Manual for compliance with C-PIQ Program requirements.
2.1 Quality policy statement
CFIA requires a company applying for participation in C-PIQ to have a strong commitment to quality, clearly evident to its staff. A statement describing the aims of the Company in this regard must be included in the Company QA Manual. Such a statement shall authorize the policies and procedures documented in the manual and may incorporate the requirements for the chief executive declaration outlined in the next section.
2.2 Declaration of commitment
This is a mandatory statement signed by the chief executive of the Company (the person in the top management position). It shall express the full support of Company management in directing appropriate staff in meeting the requirements of their QA system, and endorse the procedures outlined in the Company QA Manual. The declaration shall also include a statement of commitment that the quality system in place will be maintained at a level of integrity which will ensure that all products and processes meet all requirements of applicable Acts, Regulations, policies, foreign country import requirements (for exporters), and the Company itself.
Certain positions within the organization are key to the maintenance and operation of the C-PIQ establishment, and to the production of safe and quality food. The application for registration must include the name of the owner of the establishment, the name of the Operator of the establishment, and the person responsible for the supervision of the preparation of the product. The Operator must ensure that a QA system is established in accordance with the requirements of C-PIQ and appoint/designate a person that will have the responsibilities of a Quality Assurance Manager.
The Operator of an establishment must identify in the Company QA Manual the personnel responsible for:
2.3.1 Quality assurance manager
The Quality Assurance Manager, irrespective of other responsibilities, shall have defined authority for ensuring that a QA system is established, implemented and maintained in accordance with the C-PIQ Program, regulatory requirements and product standards, which should include
- reviewing the QA system;
- verification of monitoring and corrective action records; and
- acting as the liaison with CFIA on matters relating to C-PIQ, corrective actions, and audit findings.
2.3.2 Other key quality assurance positions
Key quality assurance positions must be identified, including: grade/lot verifiers, and certificate controllers.
It is a requirement that the duties and responsibilities, as well as back-up personnel, for each key quality assurance position, be identified in the Company QA Manual. When specifying duties of key QA personnel, it is important to remember that the person responsible for verification of records may not be the same person as the one doing the actual monitoring. Changes to identified personnel or their duties must be reflected in an amendment to the Company QA Manual.
2.4 Maintenance of reference materials
The Company QA Manual must also include a list of Reference Materials such as pertinent Acts, Regulations and procedural documents. The Establishment must explain where these Reference Materials are available, as well as how and by whom they are maintained to ensure these are current at all times.
It is the Operator's responsibility to ensure that staff is trained. As per SFCR 75 any person who is involved the manufacturing, preparing, storing, packaging or labelling of a food must have the competencies and qualifications necessary to perform their duties. Training must be provided to all required staff, as appropriate, upon hire and a minimum of once per season thereafter and cover the following topics:
- the safe preparation and handling of food (all staff);
- the quality assurance system implemented within the establishment;
- U.S. import requirements;
- defect identification and tolerances;
- inspection procedures;
- control and completion of documents, including C-PIQ Export Documents and Transfer Documents; and
- traceability and lot identification.
Personnel that have responsibility for the training program within the establishment must be clearly identified in the Company QA Manual. Details pertaining to the employee training program shall also be included in the Company QA Manual outlining training frequency, training topics and materials, target audience, as well as records to be maintained. Training of personnel is to be documented and kept on file by the establishment.
2.6 Floor plan of facility and process flow diagram
Under SFCR section 59, a facility must be designed, constructed and maintained in a manner such that the movement of persons and things within, into and out of it is controlled and the movement must not present a risk of contamination to the food.
2.6.1 Floor plan
The establishment must provide the CFIA with a floor plan of the facility. The floor plan shall illustrate the general layout of the facility including:
- receiving areas (for product and materials), sorting and grading areas, packaging areas (bulk or packaged product), storage areas and the shipping area;
- lunchrooms, washrooms, mechanical rooms, offices, etc.;
- location of major equipment;
- flow of product to illustrate the movement of product through all production steps (receiving, washing, sizing, rough grading, finish grading, packaging (identify each package line), storage, shipping, etc.);
- location and identification of all sampling sites.Footnote 1
2.6.2 Process flow diagram
The Company QA Manual must also include a process flow diagram which illustrates the flow of the product through each step in the process from receiving to final shipping with particular attention to any cross-over of product lines which could negatively affect the quality of the product. The process flow diagram shall identify control points for quality, lot identification and other factors that need to be controlled, as well as sites where samples are taken and monitored.
This process flow diagram must be correlated to the floor plan to ensure a clear understanding of the process.
2.7 Calibration of equipment
In order to meet SFCR 53 (g) respecting calibration, the establishment must identify the equipment used to grade the product and monitor control points (i.e. thermometers, temperature gauges, sizing equipment, scales, electronic grading equipment, etc.) and document the procedures for calibration of equipment including:
- person(s) responsible;
- procedures for calibration, and record keeping;
- frequency of testing and tolerances for equipment; and
- corrective actions if equipment is found in non-compliance with requirements.
This information may be put in the form of a table for easy reference.
2.8 Facility and operational requirements - registered and maintain registration
The establishment must meet the Safe Food for Canadians Regulations and C-PIQ requirements for the operation and maintenance of C-PIQ registration as outlined in (Annex A) prior to and during registration. These basic requirements aim to provide environmental conditions favorable for the production of safe food and the preparation of quality product. It is the Operator's responsibility to ensure that the establishment is operated and maintained in accordance with the minimum requirements at all times throughout the registration period. The Operator of the C-PIQ establishment is responsible for all produce received into the establishment and for its compliance with C-PIQ and any applicable Acts and Regulations.
2.9 Traceability and lot identification
Traceability of product as it passes through the establishment is an important element in C-PIQ. This is to ensure that product destined for shipment to the United States has not been co-mingled or inadvertently certified as meeting US import requirements. Traceability applies to all product entering and exiting the establishment. The Operator of the establishment shall have a policy and procedure which permits the identification and traceability of all product from receiving to shipment. The establishment must maintain records to provide a clear link between the receipt of the product, any preparation or monitoring within the facility, and the ultimate disposition of the product. Lot identification must permit product to be traceable. The establishment may use shipping documents, manifests, purchase orders, etc. as part of their procedures for traceability, providing that the C-PIQ requirements of this section are met. Under SFCR Part 5 operators must ensure that traceability documents are kept for two years after the day on which the food was provided to them and they provided the food to another person. All traceability documents must be accessible in Canada.
2.9.1 Incoming product
C-PIQ traceability and lot identification requirements for incoming product do not apply to loose product off-loaded from vehicles directly into storage for either short or long-term storage. Traceability of loose product commences once the product enters the production line, at which time a record of receipt is required.
A record of receipt is required for each lot of packaged product entering an establishment, whether it is in bulk containers (bins, totes, sacks) or palletized.
The record of receipt should contain the following information:
- Date of receipt;
- Type of product;
- Quality declared (if applicable);
- Source or origin;
- Ministerial exemption number (if the product is received in bulk from another province or country)Footnote 2;
- C-PIQ Transfer Document number (if applicable).
For incoming product, the method of traceability must include unique identification of the lot on each bulk container or pallet of packaged product within the lot and provide a clear link to the record of receipt. For incoming product, each establishment may utilize any numbering system of lot identification that is suitable for their operation, as long as the total quantity of product from each lot is traceable.
If graded produce is coming from another C-PIQ establishment, product will already be identified with the unique pallet/bulk container identification number, but must be linked with the record of receipt.
Production records and sample site documents must be able to be linked to the record of receipt via the lot identification numbers. Culls/rejects must be accounted for by quantity through shipping records and must be identified while in the establishment with the words" Do Not Ship".
2.9.2 Finished product
C-PIQ requirements include lot identification of all product that has gone through the production line to the pallet or bulk container level and traceability through to the consignee or receiver of the product. Finished product identification is a method to identify individual containers or pallets of product with a unique identification number and tie them to a C-PIQ Export Document, C-PIQ Transfer Document and/or other shipping records.
Each bulk container (bins, totes, sacks) or pallet of finished product which has been graded or verified for grade within the establishment must be labelled with:
- the C-PIQ registration number of the establishment, as issued by the CFIA;
- the date of preparation and/or monitoring by the establishment; and
- a unique pallet/bulk container identification number.
An alternative to the date of preparation and/or monitoring is the use of a code, such as a Julian code, which represents the date. An Operator may wish to include additional information in the lot identification of finished product to identify growers, packing lines, hours of day packed, etc. for its own control purposes. If an Operator wishes to implement these additional requirements, the meaning of the identification system used must be clearly explained in the Company QA Manual, and the CFIA will audit against these additional requirements.
Example: The code may appear as A222160510NB06
In this example,"A" would denote the first pallet packed/monitored, "222" denote the C-PIQ registration number,"160510" denote the date of packing/monitoring of May 16, 2010, and the following additional information that the establishment would like to include: "NB" representing the code for the province, and "06" the grower number.
Each pallet of product intended to be exported to the United States or Puerto Rico must also be labelled with the CFIA C-PIQ Logo (Annex F) in addition to the C-PIQ registration number, date and unique pallet/bulk container identification number. The logo may appear in either black and white, or may be depicted in colour. If in colour, the logo and colours must be as per the official CFIA C-PIQ Logo.
Note: If graded product is loaded loose onto a truck, the appropriate lot identification requirements may be applied to the back of the truck door.
Product that is run through the production line but is not graded (i.e. product that is only sized or washed or run to remove debris) must also be identified at the end of the process with the following:
- the date of preparation; and
- a unique identifier on the container.
All lot identification on pallets must be a minimum of 6 inches (15.24 cm) in width and 4 inches (10.16 cm) in height. Lot identification must be clearly visible and legible, and securely affixed in the upper portion of the bulk container or pallet in a manner that cannot be easily removed or tampered with.
If any product is reworked, the establishment must document and control the removal of the original product identifier. A new lot identification mark must be affixed to this lot, and records must clearly link the new and old identification numbers.
Any product that has been monitored and found not to be in compliance with quality requirements must be identified in a manner that will ensure that the lot is not shipped.
2.10 Information and document control
2.10.1 Document control
The Export Document for C-PIQ Establishments (C-PIQ Export Document – CFIA/ACIA 5314) (Annex G) is a document to accompany each shipment exported to the United States.
18.104.22.168 Issuance of export documents
The completion of the C-PIQ Export Document is a joint responsibility of the C-PIQ establishment and CFIA. CFIA issues the C-PIQ Export Document to confirm that the establishment is operating under a CFIA recognized quality assurance program and is monitored and audited for compliance with the requirements of the program. The completion and the control of the C-PIQ Export Document is the responsibility of the C-PIQ establishment whereby they attest to the verification of quality and compliance with US import requirements.
22.214.171.124 Identification of staff
Each C-PIQ establishment must identify staff authorized to request and complete C-PIQ Export Documents, clearly identifying the names and titles of the authorized personnel in the Company QA Manual. These persons shall be trained in the control and completion of documents.
126.96.36.199 Control of export documents
The procedures adopted for the control and completion of Export Documents must be clearly identified in the Company QA Manual and be adequate to ensure control of the documents and the integrity of C-PIQ. The establishment must ensure that all C-PIQ Export Documents are controlled and completed accurately and truthfully, being used only for shipments of graded product eligible under C-PIQ. C-PIQ Export Documents are non-transferable. A C-PIQ establishment which permits another facility to use C-PIQ Export Documents which have been issued to their facility will be assigned a Critical Non-Conformity, will have their C-PIQ registration suspended or cancelled, and will lose the privilege to request, complete and issue C-PIQ Export Documents.
188.8.131.52 Requesting export documents
The C-PIQ establishment must submit a signed Request for Export Documents for C-PIQ Establishments (Annex H) to obtain C-PIQ Export Documents. The establishment must provide 24 hours advanced notice to CFIA for C-PIQ Export Documents. If the establishment is in good standing, CFIA will assess the request and provide the C-PIQ Export Documents. Additional documents may be provided upon request subject to adequate accountability of previously issued documents.
C-PIQ Export Documents provided by CFIA will include the following information:
- a unique C-PIQ Export Document number;
- the C-PIQ establishment name;
- the C-PIQ registration number; and
- the name, and signature of a CFIA inspector.
184.108.40.206 Completion of export documents
For each eligible shipment, the authorized establishment personnel shall complete each C-PIQ Export Document as per instructions in (Annex G). The original of the document shall be signed by the authorized personnel and accompany the shipment. A copy of each completed and signed C-PIQ Export Document must be sent to the local CFIA office within 24 hours of shipment. Should the C-PIQ Export Document not be sent to the local CFIA office in a timely manner repetitively, C-PIQ Export Documents may be issued by the CFIA on a load by load basis.
A C-PIQ Export Document is considered to be issued once it has been faxed to the local CFIA office and the original copy has been provided to the transporting vehicle. Prior to the completion of the C-PIQ Export Document, faxing to the local CFIA office and the shipment leaving the establishment, minor changes may be made. Such changes are to be made by authorized personnel only and must follow the procedure for all corrections to records, i.e., a single line through the incorrect entry; the correct entry in close proximity to the incorrect entry; and the initials of the person making the correction.
220.127.116.11 Cancellation of issued export documents
Once issued and a copy has been sent to the local CFIA office, alterations to the C-PIQ Export Document are not permitted. Subsequent changes will require the cancellation of the issued document and the issuance of a replacement document. A line must be drawn diagonally across the inspection document with the word Cancelled appearing above that line. A copy of all cancelled C-PIQ Export Documents shall be sent to the local CFIA office. The original shall be maintained on file by the establishment for review by CFIA audit staff.
The establishment is required to maintain copies of C-PIQ Export Documents, shipping and production records for a minimum of two (2) years as per the Safe Food for Canadians Regulations Part 5 Traceability 90 (1)(2)(3). The local CFIA office should be contacted with regard to any questions or inquiries related to the Export Document and its use.
18.104.22.168 CFIA control of export documents
CFIA will maintain a record of C-PIQ Export Documents issued to and completed by each establishment. A copy of the Request for Export Documents for C-PIQ Establishments form will be maintained on file at the local CFIA office. Upon receipt of the sent document, CFIA staff will note the C-PIQ Export Document number and the date the document was issued, cancelled or returned by the establishment. The sent copy of the C-PIQ Export Document will serve as CFIA's official record of the shipment.
2.10.2 Transfer documents
Produce prepared (packaged or bulk) in a C-PIQ establishment may be transported to another C-PIQ establishment for the purpose of inclusion on an Export Document for shipment to the United States provided the following conditions are respected:
- both establishments are operating under C-PIQ and are monitored and audited by CFIA for compliance with C-PIQ Program requirements;
- the produce meets the Traceability and Lot Identification requirements as identified in 2.9;
- each shipment is documented with a C-PIQ Establishment Transfer Document (for movement of potatoes, intended to be exported to the United States, from one C-PIQ establishment to another C-PIQ establishment) (Annex I);
- the C-PIQ Establishment Transfer Document shall be printed on the establishment's letterhead paper and provide the following information:
- a unique tracking number for each C-PIQ Establishment Transfer Document;
- full name, address and registration number of the C-PIQ establishment;
- shipper (full name and address; indicate "same" if shipper is same as originating C-PIQ establishment);
- receiving C-PIQ establishment (full name and address)
- marks on packages, including brand name;
- product/type/variety (potatoes round or long type; variety name where declared; yellow-fleshed where applicable);
- number and type of packages (e.g. 500 master container, 10/ 5 lb 2.27 kg poly bags);
- grade name of the produce;
- size of produce (e.g. 2" minimum; Chef; or 10 oz. minimum);
- lot identification numbers;
- date that the produce was packed and/or monitored;
- province of origin of product (a plant health requirement);
- signature and date that lot was shipped, attesting to origin of the product; authorization to sign on behalf of the establishment; the accuracy of the information provided; and legal implications of providing false, misleading or deceptive information;
- produce shipped and included on the C-PIQ Establishment Transfer Document must, at all times, be controlled and identifiable;
- for each movement of eligible produce between C-PIQ establishments, a C-PIQ Establishment Transfer Document must be completed, the original kept on file and a copy must accompany the shipment. Within 24 hours from the time the shipment takes place, the C-PIQ Establishment Transfer Document must be faxed to both the local CFIA office and the C-PIQ establishment where the produce is destined for ultimate shipment to the United States;
- the issuance of the C-PIQ Establishment Transfer Document will be used in the calculation of shipping days for the frequency of audit.
Note: When a C-PIQ establishment transfers product intended for the domestic market to a C-PIQ establishment located in another province, this must be in accordance with the Safe Food for Canadians Regulations.
C-PIQ Establishment Transfer Documents may be used without a ministerial exemption for the interprovincial movement of finished bulk product between C-PIQ establishments for the purpose of inclusion in a C-PIQ Export Document for ultimate shipment to the United States.
Produce received from another C-PIQ establishment with a C-PIQ Establishment Transfer Document may be included on an Export Document for shipment to the United States provided the following conditions are met:
- the information provided on the C-PIQ Establishment Transfer Document must clearly link the final Export Document to the receiving/ production/shipping samples and records in the originating establishment;
- the C-PIQ Export Document must include the marks on packages, product type, declared grade, number and type of packages, and lot identification number of the produce packed in the originating establishment;
- produce more than 3 days from the time of packing/monitoring must be examined to verify that the quality of the product has not deteriorated.
Should product received from another C-PIQ establishment, by way of a C-PIQ Establishment Transfer Document, not meet U.S. import requirements, the receiving C-PIQ establishment must notify the local CFIA office for further instructions.
2.10.3 Notification requirements
The operator of a C-PIQ establishment must provide written notification by way of fax to the CFIA of any returned export or domestic shipment of product, irrespective of the reason for the return, no later than 24 hours following the shipment's return. If the returned load is returned under a CFIA detention, then notification must be immediate. The operator shall maintain the load intact and hold all returned shipments for inspection by the CFIA.
Failure to provide written notification within 24 hours or failure to hold a returned shipment for inspection will be deemed to be a Non-Conformity, which results in an Unsatisfactory Audit.
2.10.4 Amendments to company QA manual
The Company QA Manual will require regular updates to document new procedures, changing requirements or specifications, particularly when improvements are made to the quality system. The C-PIQ establishment must document and include in the Company QA Manual the procedure for making necessary amendments to the manual. A list of holders of controlled copies of the Company QA Manual must be documented to ensure that amendments are issued to each for inclusion in the manual. A page listing all amendments made to the Company QA Manual must be present at the front of the manual.
It is the responsibility of the C-PIQ establishment to ensure that the Company QA Manual is amended to accurately document the operation of its quality assurance system, and ensure it remains current at all times. The C-PIQ establishment must submit to the CFIA any amendments which result in changes to a process, critical limit or duties of key staff, and receive CFIA approval prior to implementation. For all other types of changes, the establishment must only forward a copy of the amended Company QA Manual page to the CFIA.
2.11 Internal audits
The Operator of a C-PIQ establishment must implement procedures for Internal Audit (self-assessment). The Operator must complete, and document a minimum of one (1) full internal audit (all parts of the QA system) per shipping season. These audits are necessary to assure the integrity of the C-PIQ Program, the establishment's own QA system, and the production of quality product. The Company QA Manual must identify and set out a policy to conduct these internal audits on a regular basis. The CFIA will review this record as part of the audit process to ensure that the C-PIQ establishment is maintained and operated in accordance with the C-PIQ Program.
Internal Audits should include such things as:
- a review of the Company's own QA Manual;
- an inspection of facilities, equipment, chemical storage, etc.
- a review of sanitation, maintenance and calibration procedures and records;
- a review of the policies and procedures in relation to monitoring, corrective action and verification;
- the examination of product to confirm monitoring procedures are followed;
- a review of inspection records;
- a review of lot identification and traceability procedures;
- a review of issued C-PIQ Export Documents;
- a review of training and training records;
- a review of other records and procedures for control of records.
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