Before the year 2012, Canadian Food Regulations consisted of 14 separate sets of Acts and Regulations. Each food commodity had its set of rules which would sometimes be inconsistent across products. To modernize food safety regulations in Canada, the Safe Food for Canadians Act was passed into law in 2012 and improved Safe Food for Canadians Regulations (SFCR) came into effect on January 15, 2019. One set of regulations is now applied throughout the food industry and requires the development, implementation and maintenance of a Preventive Control Plan or PCP Plan. What is the secret to running effective PCP plans to sell in Canada?
The SFCR scope is human food, including ingredients used in food for human consumption. It also applies to the slaughter of food animals and commercialization of meat products. Although the regulations apply to federally traded products, some of the food traceability, labelling, advertising, and grading requirements are required for products sold within each Canadian province. Activities may include food import, cold storage (meat products, certain export requirements), domestic manufacturing for interprovincial trade and food export. Businesses involved in the manufacturing and/or commercialization of food maintain an SFCR business license which identifies the food products and activities they undertake.
5 Key tips for running effective PCP plans to sell in Canada
Since July 20, 2020, most food importers and processors in Canada are required to have an effective and fully implemented PCP plan. PCP plans follow the Codex HACCP guidelines which means that an HACCP/food safety plan and good food manufacturing and distribution programs are necessary for compliance. Every year, CFIA inspectors perform compliance reviews to verify that the law is applied. Both processing facilities and warehouses are inspected following a risk-based approach, and must maintain PCP records. Not sure how to get started? Read our authoritative blog on Importing Food to Canada.
A complete PCP plan includes a group of written procedures to control food safety risks (biological, chemical, physical risks) through out the food chain. The risk evaluation process follows HACCP requirements. Businesses must source safe food products, ingredients and packaging. They must follow safe food handling and storage procedures and apply processing controls that will result in safe food consumption. Finally, they must label food accurately and react quickly to customer complaints and recalls.
For companies who are new to food manufacturing and importing, maintaining a large number of procedures and records can seem intimidating and even overwhelming. So how can we clarify the regulations and help you with running effective PCP plans to sell in Canada? Here are 5 key tips to help you get started.
Tip #1 – Management Commitment and Food Safety Culture
For a PCP plan to be effectively implemented and maintained, the most critical factor is having management commitment in your business. Without leadership and resources, the PCP plan will be superficial and hard to implement. Running effective PCP plans to sell in Canada centers on securing management commitment. By commitment, we mean more than just providing financial support. Communicating expectations to staff and following up by performing audits and inspections are essential. To gain the commitment of business owners and top management, we need to show that the PCP plan means more than just staying in business.
A PCP plan is a written food safety program (“a management system”) that clarifies the key procedures to ensure the quality and safety of food. Imperative procedures include pest control, warehousing, shipping/receiving, water/ice potability, building and equipment maintenance, staff training and processing controls, traceability/recall, and customer complaint handling. Staff must understand the reason why such procedures and controls are required and what to do if they cannot be attained. A successfully implemented PCP plan will not only reduce product defects and customer complaints, but will also identify points of improvement and contribute to better efficiency and less waste. Before you get started, make sure to understand Canada’s AIRS system.
Tip # 2 Delegation, Supervision and Training
Once you secure senior management commitment, the next important step is to delegate different tasks and procedures to the right people in the right areas of the business. Having different functions and first line operators involved in developing and maintaining the PCP plan will ensure fast implementation and training of the PCP procedures. These procedures can also be maintained by approved contractors such as with pest management, building and equipment maintenance and upkeep.
It is essential to listen to the first line operators’ recommendations on the procedures and to work with them to resolve any difficulties that they are facing when implementing the PCP plan. Based on risks, some controls will need daily monitoring (e.g. the cold chain, allergen management, food labeling and safe baking/cooking/cooling); some will need follow up every week, month, quarter or year. The PCP plan is never meant to create hardship for operators. If your objective is running effective PCP plans to sell in Canada, you need to delegate the responsibilities to develop and maintain the plan to the first line operators. This will build trust and a strong food safety culture within the organization. This culture will become your greatest asset when maintaining your PCP plan and growing your business.
Of course, no delegation can truly happen without proper training, education and supervision. When we talk about training, we think of expensive courses, certificates and lengthy training sessions in a meeting room. However, the way people receive training has changed. A good organization trains continuously on the job and reinforces the training through micro courses and annual refreshers.
Training employees and their supervisors builds a culture of sharing knowledges and promoting improvement. A company that provides good training encourages the operators to learn more than just the task but the whole process. Employees must spot issues and support their coworkers. They must know how to do the job but also what the consequences will be if procedures and records are not maintained. A system should be built to have the more experienced employees to continuously train the less experienced workers. A trained operator will help you identify a needed process improvement and a trained team will help you keep the PCP plan running smoothly. Your written PCP plan must always reflect the changes you make on the production floor.
Tip # 3 The Importance of Recordkeeping
Many companies, especially small organizations, struggle with record keeping. Once documents are written and approved, they must be implemented. The sheer number of forms to be filled out can be overwhelming. We understand that sometimes the purpose of the documentation can seem a little bit unclear. Why should we spend so much time and effort to create a large pile of food safety and traceability records?
Here are a few good reasons:
- A good paper trail of records provides product traceability and helps us to identify why businesses fail to produce safe food. In the case of a product recall, good records allow a faster response and help avoid catastrophic results when there is a foodborne outbreak (think harmful bacteria in romaine lettuce, undeclared allergens in food, plastic or glass in food).
- A good set of records not only has value in tracing back the operational history, but also provides insightful forecast. A near miss or adverse trend can serve as an early alarm to prevent key parameters from going out of control (think failure of the cold chain, failure to retort or pasteurize food properly). For example, a sudden change of the temperature graph, although still within the limits, can indicate a problem with your refrigeration system.
- Good and lean documentation reflects the true procedure and simplifies the business operation. A well-designed form reminds operators of the steps and critical limits in their procedures and helps improve the operation’s efficiency. It reduces the chance of human error. It is even more true now with digitized documentation systems which remind workers that follow up is needed.
One important note about record keeping is that the records don’t need to be perfect and shouldn’t be perfect. It is completely fine to have corrections on the records. Corrections can indicate that there may be some ambiguity in the procedures that need to be clarified. Good record keeping allows employees to make wrong entries but also to correct them properly, and to have both the mistake and the correction kept on the record. This helps with critical thinking and making good decisions. Once your employees really understand why they are completing and verifying food safety forms, your business will be running effective PCP plans to sell in Canada.
Tip #4 Establishing Schedules and Leveraging Technology
Another key aspect of PCP plan management is to establish scheduled activities for each function of the business. Calendars and food safety software can help remind employees of tasks to be completed daily or weekly and verified monthly or yearly. When done early in the project planning process, this task may help identify the need for additional resources (such as a new contractor or new team member). PCP plan activities can also be automated using digitized forms with established rules for PCP compliance. For instance, workers might be unable to save an electronic record when a critical limit is not achieved, unless they issue or complete a deviation report. Non-compliance events can then easily be flagged by the system for immediate correction and follow up. So running effective PCP plans to sell in Canada is also a matter of using the right tools to reinforce the food safety culture within your business. All these action steps are additional effects.
Tip #5 PCP Plan Verification
Even with the best equipment and the best procedures, there will always be human errors. People will forget something and miscommunication will occur. All these events can lead to non-conformities. How can we know that staff are doing what they are supposed to do? That’s where routine verification comes into play. A “verifier”, usually a more senior employee, confirms that the procedures are followed by conducting regular, usually weekly or monthly, record reviews and on-site observations.
The routine verification confirms that the key elements of each procedure are followed:
- Who: Is the task done by the right person? Is the person trained and competent?
- When: Is the procedure carried out at right frequency? Is there missed entries on the food safety log or missed reports in the filing cabinet?
- What: Are the right targets being monitored for safety? Were customer complaints received? Did CFIA issue a non-compliance order?
- How: Are the approved and written procedures being followed?
A “no” to any of the questions above usually indicates lack of training and supervision. It may also signify a lack of understanding of food safety principles. To ensure the performance and efficiency of the PCP plan, it may be necessary to seek outside assistance and recruit the services of a food safety consultant.
While the routine verification focuses on avoiding discrepancies in the procedure and in the operation, the annual plan verification focuses on system compliance. We need to always remember that food regulations and food safety standards are dynamic; therefore, the PCP plan must be dynamic as well. Annual verification allows the PCP plan team to review the compliance of the current food safety system so that changes can be addressed. New development may include new food regulations, revised customer contracts or a new food process. An internal audit is usually an effective way to systematically verify the PCP plan and spot gaps. Consultants can also assist with performing these annual PCP plan verifications.
Running effective PCP plans to sell in Canada is not easy. However, it is rewarding and beneficial to the company. The PCP plan or other food safety management systems such as HACCP, SQF, BRCGS are effective management tools. It is through good management that a business can thrive and meet its legal obligations.
Blog Co-authored by Sean Xia and Karine Lawrence
Sirocco Food + Wine Consulting provides training and consulting services to Food Importers and Manufacturers who must meet Canadian SFCR regulations. From developing or auditing a PCP importer, manufacturing, or exporting plan, we help your business grow. Contact us to request a quote or browse our e-store to find the compliance solution that will fit your business needs.