The Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019. The food safety requirements rest on three pillars: Business Licensing, One-step forward/One-step back Traceability and Preventative Controls for food safety. The term “Preventive Controls” is now widely used, from the Codex HACCP guidelines (2020 publication) to the FDA Food Safety Modernization Act requirements. Preventive controls are measures taken to reduce or eliminate food safety hazards such as bacterial pathogens, undeclared food allergens or glass shards. A Canadian Preventive Control Plan (PCP) is a written document based on Codex HACCP principles. It outlines the procedures food manufacturers utilize to ensure food is free of significant hazards, is fit for human consumption and is labelled accurately and truthfully.
Food companies in search of guidance on food safety compliance may decide to follow the Canadian FSEP (Food Safety Enhancement Program) program to implement their PCP plan. FSEP is the Canadian Food Inspection Agency’s Food Safety Program that is followed by federally registered establishments. FSEP is a HACCP-based program.
The FSEP program has been revised to reference federal PCP Plan requirements. More specifically, by implementing the elements of FSEP, food manufacturers fulfill section 89 of the SFCR and create a written PCP plan that’s compliant with Canadian regulations. Other requirements may apply, such as local or provincial regulations.
Let’s review the contents of the CFIA’s FSEP Program and how they fulfill the PCP plan requirements.
Program Responsibilities
This is the first step in developing a PCP plan. Management commitment is an essential part of a food safety program because it ensures that the PCP plan is well-resourced. Management or the owner of the food business must designate a HACCP team and provide the team with access to training and resources. It is common for the HACCP team leader to be formally HACCP trained.
Prerequisite programs (Maintenance and Operation of Establishment requirements in SFCR – Section 50-81)
- Premises
- Food conveyance, purchasing, receiving and storage
- Conveyances and equipment in the establishment
- Personnel
- Sanitation and pest control
- Recall System
- Operational prerequisite programs
The pre-requisite requirements of FSEP (sections A to G) ensure that the site is suitable for food production. This section cross-references the SFCR regulations. Pre-reqs address process controls, sanitation, pest control, equipment maintenance and calibration, flow, food handling and employee training requirements of SFCR in more detail. They also address traceability, recall and customer handling requirements under “F- Recall System”. When developing Standard Operation Procedures, make sure to describe who is responsible for the monitoring of the tasks, the frequency of monitoring, the actual procedure, which forms (electronic or paper copy) will be used and who will verify that the tasks were completed. SOP implementation will follow. Ensure your employees are trained on performing food safety monitoring and record-keeping activities.
Market fairness requirements (89(1)(a) and (b) of the SFCR)
Under this section, food products must be evaluated to ensure that grade, labelling requirements such as net quantity, nutritional claims are adequate to protect the consumer. A critical step of food packaging is to review the food labels before they are printed to ensure compliance. Analytical testing including sensory analysis of food may be used to validate nutrition and gustatory claims as well as grade standards. You will need to reference your label design and compliance program, your food testing program and any quality control checks you may perform on the finished product.
HACCP plans
This section references the food safety study pertaining to your process(es) and product(s). A HACCP plan or food safety plan follows the 12 steps of the CODEX HACCP standard which are 5 preliminary steps followed by 7 Codex principles. HACCP captures the critical process and operational controls (the CCPs) needed to mitigate risks.
We recommend that the PCP plan teams attend a HACCP training course (one or 2 days, virtual or in person) to learn how to implement a food safety plan based on Codex HACCP.
Validation documentation/Evidence of effectiveness
In keeping with good practices, CCPs must be validated. This means that your critical limits must be achievable and scientifically valid. You may cite government standards for safety, reference scientific journals, or contact a food safety expert who will assess your process for safety. Demonstrating program effectiveness also applies to pre-requisite programs. If your company is food safety certified or inspected by CFIA, you will be able to use audit reports and regulatory inspection records as verifications that your PCP plan is functioning properly. To learn more about system verification, consult our FSMS validation and verification blog.
Maintaining your FSEP
Once the Pre-requisite program, Market fairness Protection Requirements and HACCP plan(s) are developed, implemented and verified, the PCP plan must be routinely reassessed to ensure effectiveness and to capture change (change in products, processes or manpower). A good practice is to perform yearly reassessments to verify compliance. A verification SOP and verification schedule must be developed and implemented. Verification is carried out by competent employees who are independent — where possible — from the tasks being reviewed/audited. PCP Plan records must be retained for 2 years.
Forms
under this FSEP section, you will be able to access HACCP templates.
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Sirocco Consulting offers a SFCR Bundle to meet your PCP plan manufacturing needs: The Sirocco Bundle includes Pre-requisite Programs including site GMPs as well as Recall, Traceability, Complaint Management and Verification SOPs.