Notice to the Canadian Food Inspection Agency (CFIA) accredited Certification Bodies on when and how to verify compliance when on-site inspections are not possible
To: All regulated parties under Canada Organic Regime (COR)
Date: March 24, 2022
This notice provides guidance to the Canadian Food Inspection Agency (CFIA) accredited Certification Bodies (CBs) on when and how to conduct remote or hybrid inspections.
The CB decision to perform either an on-site, hybrid, or remote inspection should be in line with this CFIA notice. The notice also applies to unannounced inspections.
In normal situations the CBs should conduct full on-site inspections as per the COR Operating Manual requirements.
For a new applicant the initial on-site inspection is a fundamental requirement – a remote inspection cannot replace an initial on-site inspection. Initial inspections must be conducted completely on-site before certification is granted.
Under unique circumstances when on-site inspections for continuation of certification are not possible, the CBs shall fully document the justification for a decision to conduct a remote or hybrid inspection, taking into consideration all government restrictions including the regional/ provincial health authority restrictions within the region(s) involved.
When the CBs plan and conduct remote or hybrid inspections, they shall consider information and communication technology that offer the functions that they need (live video, recorded video with date and Global Positioning System stamp, file sharing, screen sharing, still pictures etc.). These need to be easily available to the operations and verification officers and offer confidentiality and security protections.
The CFIA accredited CBs may conduct remote inspections for continuation of certification in emergency situations that make on-site inspection impossible due to health and safety reasons and/or imposed government restrictions.
As part of a remote inspection, information and communication technology shall be used to obtain evidence and to determine the extent of conformity to the certification criteria.
As part of transitioning back to normal mode of operations, when the Covid related restrictions are lifted, CBs may consider conducting hybrid inspections as long as they achieve the same outcome as a full on-site inspection.
As part of a hybrid inspection:
- interviews can be done by phone or other electronic means;
- most of the operator's documents can be reviewed electronically, and verified during the on-site portion;
- on-site inspection (tour) of the operation should follow all applicable provincial public health and safety guidelines for example social distancing, personal protection equipment (PPE), and any other facility specific guidelines ; and
- there should be no more than two weeks between the virtual and the on-site portion of a hybrid inspection.
Additionally, during the transition period fully remote inspections may be conducted only in the following cases:
- new properties or facilities are added to an operator that already has an organic certificate;
- an operator is processing organic products only once per year and an onsite inspection is required prior to the CB issuance of a product certificate as per C 2.2.11 of the COR Operating Manual;
- the new operator is a broker or trader and only paper work needs to be reviewed as there is no "product production/processing/storage site" to be inspected other than an office to visit.
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