Canadian Food Inspection Agency's On-site Assessment Report of Mexico's Food Safety Control System for Fresh Fruit and Vegetables – 2017
8. Closing meeting

8.1 Observations

During the closing meeting 23 observations were shared with the CA.

1. Although the CRRS is voluntary (except in the case of specific Arrangements with importing countries), there is great commitment and dedication not only from SENASICA, but also from the auxiliary parties involved in the implementation of the CRRS.
2. CRRS operations recognize the benefits of the program, and are working to bring their suppliers on board by promoting the food safety culture, funding training, etc.
3. Without a specific agreement with an importing country, SENASICA does not have the authority to mandate the CRRS program for exports. Food safety oversight of exporters who are not recognized under the CRRS was not observed, but exports need to meet the requirements of the importing country.
4. The roles and responsibilities within SENASICA's DIAOOPA are well defined and delegated.
5. SENASICA staff has established good working relationships with the CBs, TPPs, TPSs, operators and laboratories.
6. Auxiliary individuals involved in the implementation of the CRRS are well trained and are committed to the delivery of the system.
7. The number of operators who are recognised under the CRRS increases each year, for example, 862 new operators were recognised in 2016.
8. The recognition period for both operations and auxiliary parties (CBs, TPPs, TPSs and laboratories, etc.) is relatively short (2 years) and the current process of renewal is overly cumbersome and a burden on both applicant and SENASICA.
9. SENASICA's recognition process does not appear to take into consideration previous recognition of the organization/individual by SENASICA or, third party certification, for example, Primus, Global Food Safety Initiative, the British Retail Consortium, etc.
10. Although SENASICA is committed to conducting a number of oversight activities, they were unable to meet their goals for the monitoring of TPSs, and, reviewing CAs resulting from internal audits, third party audits and SENASICA inspections in a timely manner. SENASICA explained that this was a result of limited resources in 2016.
11. There are no established criteria or frequency for conducting SENASICA inspections of recognized operators. They are currently determined by a random draw process. We understand that this process is being revised to focus activities on risk and triggers/complaints.
12. SENASICA provides training to all organizations involved in the CRRS to bring consistency in the understanding of how to implement the program.
13. The same checklist is used for different oversight activities conducted by, for example, TPPs, TPSs and SENASICA inspectors. This practice may limit the ability to thoroughly assess the program. In addition, since the assessment process is predictable, operators tend to focus only on the items in the checklist. This can limit their ability to think outside the scope of the checklist. As a result, they may not be fully prepared to respond to food safety issues.
14. CBs (and their TPPs) play a critical role in promoting and implementing the CRRS by providing operators with ongoing technical assistance, training, and supplemental equipment (signage, etc.).
15. CBs are supervised regularly by SENASICA through annual and monthly reports, as well as on-site visits.
16. CBs do not apply a consistent approach to monitoring the work of the TPPs across the 32 states. For example, some CBs monitor the work of their TPPs on a yearly basis, focusing on the number of visits and quality of their work. Others CBs conduct on-site visits at operators to observe the work of the TPP.
17. Although SENASCIA provides some training to TPPs and TPSs as part of their ongoing learning requirements, there is no national approach to training delivery to achieve consistency and maximize limited resources.
18. Individual employee profiles are not maintained and training records are not documented to facilitate the identification of training requirements, for example, employee training files contain numerous certificates as opposed to a training plan with goals and achievements.
19. Although there is no national procedure for the coordinated response to a foodborne disease outbreak, each department has their own procedures as per their authorities, and communications between departments are well established.
20. Organic: SENASICA is currently adding additional requirements to their organic regulations that will require mandatory sampling. In addition, they are modifying some of the internal guidelines related to the activities of the Certification Bodies.
21. SENASICA inspectors can take samples as part of their inspections of recognized operators, in response to complaints/alerts/outbreaks, and for special programs (cantaloupes, papayas, cilantro and avocadoes).
22. SENASICA has a monitoring and surveillance program for chemical residues and microbiological contamination in domestic and imported FFV.
23. SENASICA and COEFPRIS establish a collaborative base to define the actions and collaboration topics for both Agencies. With this collaborative base they establish and generate the management mechanisms to act during a sanitary risk related to the consumption of contaminated food, in order to give an immediate response, organized and planned in order to prevent risks related to consumer's health.

8.2 Gaps

1. It was not clear how TPPs who work independently are overseen by SENASICA.
2. Due to resource constraints, SENASICA was not able to deliver the planned number on-site assessments of TPSs in 2016 (10%).

8.3 Recommendations

The CFIA assessment team offered 11 recommendations which could further strengthen the CRRS.

1. Revise the 2 year recognition process in order to reduce the administrative burden on all parties and re-allocate funds to areas of higher risk.
2. Review the current processes for the authorization and monitoring of auxiliary parties (TPPs, TPSs, laboratories) to take into consideration the previous history of the individuals/ organizations and consider the potential value of third party certifications, for example, Primus, Global Food Safety Initiative, and the British Retail Consortium. The revised authorization process should focus on results of oversight activities, training received in the past 2 years, and any certifications granted.
3. Consider developing a national CB network to identify best practices, share training resources and other information/experience to ensure consistent national delivery of the program.
4. Consider developing a standardized template for the training and assessment of TPPs and TPSs as well as for recording and tracking employee training to facilitate the identification of training requirements.
5. Re-assess the need for the ongoing presence of a TPP in the implementation of the CRRS once an operation has been recognized.
6. Review SENASICA's CRRS oversight process that verifies the requirement for operators to develop and implement a 'database on the indicator's behaviour of products, water sources and contact surfaces' to ensure that operators understand what is expected of them and, they have the capacity to conduct trend analysis, etc.
7. Review the oversight process for evaluating operator's traceability procedures to ensure that they are well-prepared to respond to real-life issues. For example, mock recalls should include players such as SENSASICA, CBs, etc. and CAs.
8. Re-consider SENASICA's role in assessing CAs that are generated by TPSs, that is, conformities that they have not directly observed.
9. Consider developing new outcome-based tools/checklists to asses conduct internal audits, third party audits and SENASICA inspections. This will allow the different parties involved to observe the operation from different perspectives, leading to a more comprehensive assessment of their implementation of the CRRS. This should also better prepare operators to respond to food safety issues.
10. Evaluate the needs for additional program resources in order to meet increasing demands as more companies join the program.
11. Review the current prioritization process to allocate resources to activities that are truly critical to the success of the program.

8.4 Conclusions and next steps

As a result of this visit, the CFIA assessment team has established a general understanding of Mexico's CRRS, and a solid foundation for good working relations with SENASICA.

SENASICA acknowledged the observations and recommendations presented by the CFIA team and expressed their future interest in collaboration.