Safe Foods for Canadians Information session
CFIA is currently hosting information sessions across Canada to provide all manufacturers with information on the SFCA(Safe Food for Canadians Act) legislation. Public consultation is currently underway and you can submit your comments until April 21st. All questions and concerns related to the current gazette issue of SFCA need to be sent to the government by that date in order for them to be reviewed. It will then take 12 to 18 months before the regulation is finalized. Once it is finalized the first group of manufacturers (anyone manufacturing processed food) will need to comply with these regulations. Processors of fresh fruits and vegetables will have 12 months from the date of implementation for compliance and all others will have 2 or 3 years to comply to the different sections. More details regarding compliance timing can be found on the CFIA website which details SFCA in greater detail.
The three main changes for most food manufacturers are:
Preventive Control Program
For many manufacturers that already have HACCP programs in place or are following a GFSI program, little change will be needed to comply. However, for some manufacturers, this will mean the implementation of a Preventive Control Program.
CFIA has constructed templates to assist manufacturers with the development of this program, which is essentially a condensed version of HACCP. You, as a manufacturer, will be required to review all of the hazards that are associated with your ingredients and processes and determine measures needed to control these hazards. Once you've identified the hazards that are not fully controlled within your facility you will put together procedures to effectively control them. Some of these will include Maintenance, Sanitation, Training & Knowledge of Employees. These procedures will have monitoring, verification and validations done on them to ensure that they are working. Deviation procedures will need to be pre-determined, to have steps in place when something doesn't happen the way it should.
Traceability is critical for consumer safety. Ensuring the ability to remove a product from the marketplace as quickly as possible, if necessary, reduces the potential that a hazard reaches consumers and potentially makes them ill. Most accounting programs have the capability to trace ingredients from purchase through manufacture and through to retailers. As part of the new regulations all manufacturers will need to have the ability to trace a product backwards to its supplier and forwards to the retailer and will need to have clear and readable records that show this. Retailers will also need to be able to trace product back to their original vendor. These traceability records will need to be maintained for a minimum of 2 years.
Under these new regulations, all manufacturers will need to have a license to produce / process product. Current facilities that are registered will move to the licensing format when their registration is due. CFIA has created a tool that can be found on their website. It will assist you in determining whether your facility will need a license or not. Licenses will be required for those who import, manufacture, process, export foods and those who slaughter, store or handle meat products.
As an importer you will also be required to comply with these requirements which will mean knowing your supplier in greater detail. You will be responsible for ensuring that your foreign supplier meets the same standards that required from our domestic suppliers. If you are exporting outside of Canada you will need to follow SFCA regulations, in addition to the regulations for the country that you are exporting to.
As manufacturers there is still a lot of time to put the programs in place to meet Safe Food for Canadians. However, time is running out to attend a webinar or information session on these changes and making your voice heard. Comments can be submitted until April 21st to raise concerns regarding the new legislation.
FS & RD Consulting can assist you with navigating through the revisions that are required with this new legislation. Check out our website at www.fsrdconsulting.com or give me a call for a free quote.