Operational procedure: Permissions verification of Safe Food for Canadians licence

1. Purpose

The purpose of this document is to provide guidance to Canadian Food Inspection Agency (CFIA) inspection staff on verification activities to determine if the licence holder has accurately identified the types of activities they conduct and commodities associated with those activities on their Safe Food for Canadians (SFC) licence.

This document is intended to be used in conjunction with other guidance documents as referenced in Section 3.0.

2. 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. Reference documents

4. Definitions

Unless specified below, definitions are located in either the:

5. Acronyms

Acronyms are spelled out the first time they are used and are consolidated in the Food business line acronyms list.

6. Operational procedure

Under the SFCR, there are businesses that are required to obtain a licence for the activities they conduct or plan to conduct. SFCA 13(2) together with SFCR 7(2) require that prescribed activities are accurately identified on the licence. A business may choose to apply for one licence that covers all of its establishments, activities and types of food commodities, or multiple licences that would cover unique combinations of establishments, activities and types of food commodities. Industry guidance: What to consider before applying for a Safe Food for Canadians licence provides guidance to industry to set up their licence structure.

Inspection staff must complete this Permission verification task as per the Program direction: Food commodity inspection (accessible only on the Government of Canada network – RDIMS 18180969) for all activities and commodities associated to each licence. One commodity inspection plan case will be pushed in the Digital Service Delivery Platform (DSDP) for each establishment. In cases where licence activities are not associated to an establishment, i.e. stand-alone party, one commodity inspection plan case will be pushed at the party level. Within the inspection case, separate permission verification tasks are then added for each licence.

As per section 5 of the Program direction document: Food commodity inspection (accessible only on the Government of Canada network – RDIMS 18180969), there may be situations where inspection staff will be required to create the inspection case using the Incident Response or the Commodity Inspection Plan trigger.

6.1 Prepare for inspection

Refer to the SIP section 3, Step 1.

Table 1 – Recording inspection data in DSDP
DSDP field	DSDP field selection
Trigger	Commodity Inspection Plan Incident Response
Inspection task type	Commodity Inspection
Inspection level 1 task	Verify Documents
DSDP Inspection level 2 task	Permission Verification

Note: This verification task should not be added to the scope of an inspection case already in process. The use of a pushed inspection case, or the creation of a new inspection case for this activity, will ensure that consistent case management business rules are followed to enable work planning and reporting processes.

6.2 Conduct the licence permission verification inspection

Refer to the SIP, Section 4, step 2 for general information about conducting an inspection. In addition to the general guidance provided in the SIP, the following applies.

Inspectors are not required to do an onsite visit for conducting the permission verification inspection.

6.2.1 Conduct verification activities

To verify the type of commodities and activities that are permitted under the licence, access DSDP and:

review the permission by selecting the profile name or establishment name
from the drop down menu adjacent to the party/establishment name on the site map (green banner that runs along the top of the screen), select SFC Activity Commodities
navigate to the drop down arrow beside the default view (SFC Activity Commodity associated view) and select NID-DRS SFC Licence Detailed View
review the type of activities, sub activities and commodity and sub commodity types that are authorized under the licence by exporting the list of activities for the licence holder from DSDP into an excel sheet and use the sheet to verify the accuracy of the information during the inspection.
To export the list of activities for the licence holder from the DSDP into an excel sheet:
- While on the NID-DRS SFC Licence Detailed View select Export SFC Activity Commodities drop down arrow;
- Choose Dynamic Worksheet (this allows you to add more Columns to the sheet)
- Click Export to have it open in a separate Excel spreadsheet, it will be automatically downloaded to your computer

Contact the licence holder's representative (for example, profile manager) to conduct an intervew to discuss the activities and sub-activities that are conducted and request that they provide you with a list (verbal or written) of them and compare it against the DSDP profile information gathered above. In some cases when the inspector has not obtained the information needed through the interview, additional documents could be requested from the licence holder (for example, preventive control plan (PCP), product lists) to demonstrate that they are conducting the activities/commodities listed on their SFC licence. Amendments to SFC licensable activities may trigger a Licence amendment verification (LAV). Refer to the Operational Guidance: Licence amendment verification (accessible only on the Government of Canada network RDIMS 12714242).

If, while completing this task, you are made aware that the licence holder does not have a PCP when they are required to have one, refer to section 6.2.1 of the Food Preventive Control and Traceability – Compliance verification of a system to confirm the scope and conduct sub-element 1.1 (a), 1.1 (b)(c), and 1.3, if applicable. If there are other non-compliances that fall outside of these inspection tasks, refer to section 6.2.1 of the PCI to confirm the scope and conduct any additional applicable sub-element(s).

Note: The following Industry Guidance documents are helpful resources for inspection staff when determining what licence activities are applicable as they provide information related to the different licence activities:

Industry guidance: Food business activities that require a licence under the Safe Food for Canadians Regulations
Industry guidance: What to consider when applying for a Safe Food for Canadians licence

6.2.1.1 Form 4198 verification of activities and commodities (meat only)

In the case where a licence is issued to slaughter a food animal, to manufacture, process, treat, preserve, grade, package, or label a meat product or to store and handle an edible meat product in its imported condition, review the Form 4198 - Supplement to Application for a Licence to Perform Meat Activities under the Safe Food for Canadians Act and Regulations associated with this licence holder. This form provides additional licensing details pertaining to meat commodities and activities.

Verify that the activities and types of meat products selected on the 4198 include all the meat products produced by the licence holder. If there are discrepancies discuss these with the licence holder and amend/update the form.

Amendments to the Form 4198 will trigger a Licence amendment verification. Refer to the Operational Guidance: Licence Amendment Verification (accessible only on the Government of Canada network - RDIMS 12714242).

6.2.2 Determine compliance

If a non-compliance to SFCA 13(2) and/or SFCR 7(2) is identified, follow the procedures in the SIP section 4.7 to determine the category of non-compliance and establish a reasonable time frame for corrective actions.

The inspector, in consultation with their supervisor, may take immediate action based on the results of the licence (permission) verification inspection. Follow the Standard regulatory response process to determine appropriate enforcement action (if applicable) and the Operational guideline: food regulatory response guidelines for inspection powers, control actions and enforcement actions.

Minor errors associated with licence and/or party profile information (for example, accidental over-selection of licensable activities that the licence holder has no intention to conduct or duplicate activities/commodities/sub activities at the same address and /or the same profile) must be assessed on a case by case basis to determine if the error warrants a non-compliance. In these situations, inspectors must work with the licence holder to determine if there is a need to update their licence and/or party profile information in My CFIA.

Note: Having duplicate profiles in My CFIA is not considered a non-compliance.

6.3 Communicate the results

Refer to the SIP, section 5, Step 3, to communicate any non-compliance to the licence holder. Record the inspection findings in the licence (permission) verification inspection case.

6.4 Conduct follow-up

Refer to the SIP section 6, step 4. In addition to the general guidance provided in the SIP, the following applies.

When a non-compliance is identified:

create a follow-up case in DSDP to record follow-up details by selecting "create follow up" from the non-compliance record within the parent case
consult with your Supervisor, Regional contacts, or Area Operations Specialist to determine if an immediate follow-up is required
conduct a follow-up to non-compliances related to the licence requirements [SFCA 13(2)], or condition of the licence (permission) [SFCR 7(2)]

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

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