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Converting your program from a Provincial to Federal program

Perhaps you're now seeking to expand your market outside of Ontario and to the other provinces. This isn't as nearly daunting as you may think! All that is required is to bring your Quality and Food Safety program up to the Federal standards. As a Provincial facility you already have a good start. Many of the prerequisites that are required to become a federally-registered establishment are similar to those that you already have for your Provincial program. It is simply a matter performing a gap assessment on your current programs. A gap assessment is performed by reviewing your existing programs against the Federal regulations to identify where your program meets the requirements and where additional steps / processes need to be added in order to meet the requirements. Now this may sound really simple but it may not be as easy as it sounds. It will take a lot some work to convert the documentation (prerequisite bullets into the Federal format of A to G bullets). And you will wish to ensure that you have commitment from your entire facility to become a Federal plant. But if this is your desire and you aren't sure how to get started, FS&RD Consulting can help you with any part or all of it. I did my first conversion almost 20 years ago when HACCP became mandated for any federal meat facility and we became the first frozen entree manufacturer to be HACCP recognized. So, I know that, with some effort, it can be done!

For details regarding the federal program you can copy the following link and it will provide you with all of the complete details.

http://www.inspection.gc.ca/food/safe-food-production-systems/food-safety-enhancement-program/program-manual/eng/1345821469459/1345821716482?chap=4#s6c4

A quick synopsis:

The Federal system is set up based on HACCP System which includes;

      1. Prerequisite programs (See Section 3.1)

      2. HACCP program (See Section 3.2)

      3. Validations (See section 3.3)

      4. Maintenance and re-assessment of the HACCP system (see section 3.4)

Prerequisite programs

Prerequisite programs are similar to the programs that you will already have in place, for example Building Inspection, Maintenance, Sanitation, Shipping and Receiving and Production paperwork documentation.

Prior to developing HACCP plans, you will need to develop and implement prerequisite programs to assist in controlling the likelihood of introducing food safety hazards to the product through the work environment and operational practices. The provincial regulations that you already abide by will go a long way with the development of these prerequisite programs as they are already fairly covered within your existing program.

The prerequisites will need to be updated to be documented within the Federal format. The Federal format is set up with the following (7) prerequisite programs:

  1. Premises – Building design – both internal and external

  2. Transportation, Purchasing/Receiving/Shipping and Storage – Purchasing and the receiving of raw materials, the approval of suppliers, storing of ingredients and shipping and storing of finished products

  3. Equipment – All of the equipment design and maintenance of the equipment

  4. Personnel – Good manufacturing practices and training of employees on their various roles within the facility

  5. Sanitation and Pest Control – Sanitation of the building and the equipment and the pest control program

  6. Recall – traceability, customer complaints and recall program

  7. Operational Prerequisite programs – processing aids, preservatives, labelling and metal detection

These programs are sub-divided into Elements, Sub-elements and Bullets which break out each requirement.

For each of the bullets you will need to create a documented program that responds to each prerequisite program bullet requirement. This program shall include the specific procedures as per the bullet and then monitoring, deviation and verification procedures. By putting your existing programs into this format you will easily identify the areas that you may need to take additional steps to meet the requirements.

The next step in your federal program is to put together a HACCP: Hazard Analysis Critical Control Program.

HACCP Program

To begin the development of the HACCP program the first step is to determine how many HACCP plans your facility requires. If you have different processes (e.g.. ready to eat and dry cured for instance) you will want to separate these into different HACCP plans. By separating products that are produced on separate lines or processes it will make it easier for both you and an auditor to follow along with the programs. Once this is determined, there are 12 steps to developing each HACCP plan. These steps are as follows:

  1. Assemble your HACCP team.

  2. Describe the product(s) and identify their intended use

  3. List product ingredients and incoming material

  4. Construct a process flow diagram

  5. Construct a plant schematic

  6. Identify and analyze hazards - you will be focusing on biological, chemical and physical.

  7. Determine any critical control point(s) (CCP) and other control measures e.g. process control (PC) and prerequisite programs (PP) that may be needed within your process. Once these are determined you will need to establish documented procedures that outline;

    • critical limits for CCP, PC or PP

    • monitoring procedures

    • deviation procedures

    • verification procedures

Validation

The next step is to ensure that all of the CCPs that you've identified during the creation of the HACCP program can be validated. Validation is a study that reviews the entire CCP process and is used to ensure that you can achieve the necessary limits (for hazard control) consistently. Therefore, all of your CCPs will need to be validated.

Validation is performed at the time the CCP is designed, and the validation documentation may include:

  • Scientific, technical or regulatory support to demonstrate that the selected critical limit is effective for control of the hazard

  • Commissioned testing data specific for a piece of equipment (ie pasteurizer) to demonstrate that the equipment is capable of meeting the selected critical limit

  • Supporting data to demonstrate that the monitoring procedures are effective enough to detect loss of control at a CCP before the finished product leaves the control of the producing establishment

If you want more information on validation please see my article where I explain the difference between validation studies and challenge studies.

http://www.fsrdconsulting.com/news/2017/1/16/validation-studies-vs-challenge-studies-how-are-they-different

A good example of a process that will require validation is cooking: with it you will need to develop a validation that ensures that all spots within the oven will ensure that the product is fully cooked.

Maintenance and Reassessment procedures for your HACCP system.

Whenever there are changes within your process for example when you add a product, change supplier etc. you will need to have a procedure in place to ensure that you will review the programs that may be affected by this change.

This will ensure that you update the parts of the HACCP system affected by these changes or situations, and if necessary you will reassess that section of your HACCP system and re-validate the CCP if it is needed.

Additionally, you will need to develop a program that will reassess your system. This will ensure that a minimum of once per year you will review and assess the prerequisite program, HACCP program and validations. This is done to ensure that they are still current and up to date and nothing has been missed being added throughout the year. FS & RD can assist by performing the initial or yearly review of anything within our HACCP system (e.g validations)

Summary

Although this may seem a little daunting when you first try and tackle it, it really is not as bad as it sounds. Your current Provincial programs cover at least 80 % of the Federal prerequisite programs you will just need to set up in a different format. FS& RD consulting would be able to assist you along this path. Email me now at: melissastevenson@fsrdconsulting.com


 

Melissa Stevenson