If you are a BC food processor, you have probably received a letter from the BC Ministry of Health regarding compliance to new food safety requirements. This regulatory change was initiated in 2013 when sections 23 and 24 of the Food Premises Regulation under the Public Health Act were updated. The new requirements are aligned with similar regulatory changes taking place at the federal and international levels.
The scope of the regulations includes food processors involved in trade within the province of British Columbia. Food service establishments are another group of BC businesses that must comply with the food safety regulations. Canadian businesses who import food to be sold in Canada or who prepare food for export are exempted from the regulations but will have to meet new federal regulations (see my blog post on the Safe Food for Canadians Act and proposed food safety regulations).
These new provincial food safety regulations require that B.C. food processors (“operators of food premises where carcasses are handled or where food is processed or prepared”) develop, maintain and follow a written Hazard Analysis Critical Control Point (HACCP)-based plan. The plans must be reviewed and approved by an environmental health officer by March 26, 2016.
According to the guidance documents provided by the BC Ministry of Heath, food processors must identify food safety hazards associated with the food they process and prepare on their premises. A food safety “hazard” is defined as “a material or agent that, when present in the food, can make food unsafe to eat and cause illness, injury or death.” In keeping with the HACCP methodology, Critical Control Points (CCP) must be determined. Under the new Food Premise Regulation document, a CCP is defined as “a step in the establishment’s procedures where failure to comply with the Act or this regulation may result in a health hazard.” Critical limits must be established for each CCP to control the identified hazards. Procedures have to be developed to monitor CCP processes and must list the actions to take when critical limits are not met.
For the purpose of meeting the minimum food safety requirements under the BC regulations, food processors will be required to develop and submit a basic food safety plan that follows most of the accepted HACCP principles. Companies won’t be required to submit a process list or map, will not need to identify the person(s) responsible for monitoring CCP activities and taking corrective actions when safe process targets are not reached. They won’t be required to validate and verify their plan, nor will they be required to maintain HACCP records. While the new regulatory requirements represent minimum food safety standards, the BC government highly encourages companies to verify their food HACCP plan and develop and implement record-keeping procedures. Companies may also decide to develop a traditional (described as a “full HACCP plan”) HACCP plan and submit this plan for review.
BC food processors are also required to develop a sanitation plan as part of their food safety program and submit it to the BC Ministry of Health for approval. Information regarding cleaning and sanitizing chemicals as well as pesticide usage must be documented. Cleaning and sanitizing procedures including chemical concentration and chemical application for interior and exterior areas of the food establishment must also be listed in the sanitation plan. Procedures must cover food contact and non-food contact surfaces, equipment and utensils. As with the HACCP plan, the Food Premises Regulation does not list provisions for record-keeping. However, the sanitation guidance document does reference a “cleaning record” that must be shown to health inspectors as part of a food inspection.
Tutorials on how to complete a HACCP plan and examples of food safety/sanitation plans are some of the resources available on the BC government website. Processors may also consult the Canadian Food Inspection Agency’s Reference Database for Hazard Identification when conducting their hazard analysis.