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Operational procedure: Food preventive control inspection – Implementation verification

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1.0 Purpose

The purpose of this document is to provide guidance to Canadian Food Inspection Agency (CFIA) inspection staff on inspection procedures for preventive control (PC) and export controls for food. The requirements for PC are prescribed in Part 4 of the Safe Food for Canadians Regulations (SFCR). The policy outlining the system based expectations of licence holders eligible to export food is described in the Guide for Preparing an Export Certification Control Program (ECCP) Plan.

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

2.0 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.

3.0 Reference documents

References to be used when conducting verification activities of the Implementation verification tasks are found in the Annexes and:


4.0 Definitions

Definitions are located in the documents listed below or as a defined word where it is intended to supersede the definitions within the glossary documents:

5.0 Acronyms

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

6.0 Operational procedure

This operational procedure provides inspection procedures for verifying the implementation and development of specific control measures. Where more specific guidance is required than what is provided in the SIP, it will be indicated in this section, and is to be followed notwithstanding of what is indicated in the SIP.

The tasks focus on control measures that must be verified at frequencies not informed by the Establishment-based risk assessment (ERA) model. Refer to the Program Direction: Preventive control inspection frequencies for food (accessible only on the Government of Canada network - RDIMS 11010733) to determine when to conduct these tasks.

6.1 Prepare for inspection

Refer to SIP section 3, Step 1 – Prepare for the inspection. In addition to the general guidance provided in SIP, the following applies:

Table 1: Recording inspection data in DSDP
DSDP Field DSDP Field Selection
DSDP Trigger
  • Preventive control inspection plan
  • Incident response
DSDP Inspection task type
  • Preventive control inspection
DSDP Inspection level 1 task
  • Implementation verification
DSDP Inspection level 2 task
  • As defined in the tasks in the Annexes
Inspection Task Details
  • As defined in the task details in the Annexes, if applicable

6.2 Conduct the inspection

Refer to SIP, section 4, Step 2 – Conduct the inspection. In addition to the general guidance provided in SIP, the following applies.

6.2.1 Confirm the scope

If a potential non-compliance is observed part way through an inspection, which is not part of the selected scope, the following applies:

6.2.2 Conduct the verification activities

Determine whether the licence holder meets applicable regulatory requirements by reviewing the Acts and Regulations and/or importing country conditions listed in each task and using the outcome, performance criteria and verification activities as indicated in the Annexes.

Under SFCR, some licence holders are required to have a written PCP in place. If during the preparation of the inspection, it is determined that a licence holder is required to have a written PCP, however they do not have one, this may constitute a non-compliance to SFCR 86. Refer to SIP, section 4.6 – Determine compliance, for further guidance.

As per SFCR 47, all licence holders (regardless of whether they require a written PCP or not) are required to identify and analyse hazards and prevent, eliminate or reduce the identified hazards to an acceptable level using control measures shown by evidence to be effective.

Where a written PCP is required, the design and implementation of the PCP should include the requirements of a PCP found in SFCR Part 4, Division 6.

Where a written PCP is not required by regulations:

Perform sufficient verification activities to determine whether the outcome(s) for the task(s) have been met. Select the appropriate verification activities as indicated in the Annexes for each  task that will allow for the assessment of compliance.

During the course of a PCI, other inspection task types (such as sample collection and commodity inspection) can be conducted to support the information gathered to determine compliance. Caution should be exercised when deciding to take samples or conduct a commodity inspection when verifying compliance of PC/export controls. In some cases, sample collection or commodity inspections may not be useful to support an inspection assessment and could lead to a discrepancy between findings of the inspection and the results of the additional inspection task types.

Additionally, when conducting Implementation verification tasks, there may be situations that would warrant the review of the written program to verify the content meets PC requirements for the development and maintenance of the PCP using the sub-elements. If it is determined that a sub-element should be conducted, follow section 6.2.1 of the Food preventive control and traceability – Compliance verification of a system.

Before considering the use of additional inspection task types to support an inspection finding, consider the following:

6.2.3 Impact assessment

For Implementation verification tasks, "impact assessment" must be completed in DSDP as it is a mandatory field; DSDP data entry requirement is as follows:

  1. In the 'Is Non-Compliance Observed?' field of the inspection task screen:
    • If non-compliance has not been observed:
      • Select 'No'
      • Impact assessment is not conducted
    • If non-compliance has been observed
      • Select 'Yes'
      • Proceed to enter the impact assessment result
  2. Select "No Impact" in the 'Impact Assessment' field of the inspection task screen
  3. Continue data entry process

6.2.4 Document the non-compliance

For food, more than one regulatory reference can be captured in a non-compliance record. The regulatory reference(s) will be based on the findings within each task being assessed at the time of inspection. For example:

For food, when non-compliance(s) are determined when conducting a domestic or slaughter Verification implementation task, all regulatory reference(s) and the objective evidence which support the non-compliance(s) should be documented in one non-compliance record.

When the Implementation verification task is assessing importing country conditions, there may not be any regulatory references to identify on the non-compliance record. All objective evidence which supports the non-regulatory non-compliance(s) should be documented in one non-compliance record. Refer to Food export control policy for more information.

6.2.5 Categorise the non-compliance

Since a non-compliance record may have more than one regulatory reference with supporting objective evidence, the categorization of non-compliance should be based on the sum of all the documented objective evidence within that non-compliance record.

For non-compliances associated with importing country conditions, where no regulatory non-compliance exists, the categorization of non-compliance should also be based on the sum of all the documented objective evidence within that non-compliance record.

When verifying compliance to importing country conditions using the tasks found in Annex 2 - Export food - Implementation verification tasks, identified non-compliances related to the export of meat products can have a maximum timeframe for the completion of corrective measures of 60 days, including non-compliances categorized as minimal.

6.3 Communicate the results

Refer to SIP, section 5, Step 3 – Communicate the inspection results. In addition to the general guidance provided in SIP, the following applies:

6.4 Conduct follow-up

Refer to SIP, section 6, Step 4 – Conduct the follow-up inspection. In addition to the general guidance provided in SIP, the following applies to this OG:

6.4.1 Assess follow-up inspection results

If a state of compliance is not re-established, then the inspector:

The follow-up inspection case must remain open until compliance is re-established and can only be closed (deactivated) once follow-up inspection activities and the appropriate control and/or enforcement actions are complete. As the case cannot be closed (deactivated) at this time, the inspection report must be issued by other means than through the portal (such as in person/email/fax).

If subsequent follow-up inspections are required, create a new inspection task record to enter the findings, create another non-compliance record and issue an inspection report after each inspection.

Once compliance has been achieved and control and/or enforcement actions are complete, create a final non-compliance record without an associated task, indicating in the objective evidence that "Licence holder found to be in compliance on [date of inspection]" then issue the report and close (deactivate) the follow-up inspection case.

7.0 Annexes: Food Implementation verification task

The information presented for each task within the Annexes is organised as follows:

Inspectors may use discretion to expand verification of recommended items, as required.

Inspectors will select all available items if it is not possible to select the minimum number of recommended items.

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