Integrated Agency Inspection Model – Consultation Draft (December 4, 2013)
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The permission requirements proposed in the model apply to importers of regulated commodities. For importers with a licence and preventive control plan, some example strategies can be found in Annex B, Element 1, sub-element 1.3. In some cases, such as a one-time permission, preventive control plans may not be required. However, import conditions will be specified as part of the licensing process.
Products entering Canada must meet regulatory requirements, including those for safety, nutrition, composition, product identification (e.g. tagging or labelling), packaging and quality, and freedom from pests and diseases as applicable.
When dealing with food imports, the CFIA may require importers to provide documentation or information to demonstrate that the commodity is compliant with the legislation. For imports with animal and plant health regulatory requirements, documentation will be required, including the zoosanitary and phytosanitary conditions.
Inspection, surveillance and quarantine of imported commodities are key activities when:
- on-site verification of the processing and production controls or foreign country evaluation cannot be conducted by the CFIA, or
- the foreign country oversight system is not sufficient.
- they are recognized international standards for trade
The CFIA would use these activities as tools to identify gaps and trends, to determine sector performance, or to provide baseline information such as the level of chemical contaminants, disease or pests in certain commodities. Analysis of this type of information would provide a mechanism for continuous improvement including adjusting the risk-based inspection oversight framework, changing standards or requirements, and planning work.
6.1 Preventive control plans
Importers do not have direct control over production in other countries and would therefore need to develop other strategies to address risks, including having records to demonstrate how these strategies are effective.
Importers would need to include elements of the preventive control plan that apply to their operation (see Annex B). For example, importers without facilities would not be expected to address physical structure and maintenance. However, all importers would, at a minimum, need to include the following elements in their preventive control plans:
- Element 1: Process and Product Controls
- Element 7: Traceability, recall and complaints
Importers who are involved in further handling or repackaging of commodities would need to address all seven elements of the preventive control plan.
The inspection approach outlined in Section 5 would be used to verify the effectiveness of the importer's preventive control plan.
If an inspector has reasonable grounds to believe that an imported commodity does not comply with import requirements, the CFIA may order that it be removed from Canada or, if removal is impossible, that it be destroyed. In the case of critical and serious non-compliance, the CFIA would take steps to inform stakeholders and the competent authority in the exporting country.
When notified of a non-compliant commodity, the CFIA would take steps appropriate to the nature and severity of the issue to prevent further product from entering the marketplace until corrective action had been taken.
Depending on the nature and severity of non-compliance, the CFIA might review technical arrangements or other bilateral agreements with implicated countries to determine whether amendments would be required.
6.3 Foreign country evaluation
Canada is a significant importing nation. Conducting a foreign country system audit is a means of assessing risk and determining whether a country's inspection system is equivalent or comparable to Canadian standards.
Equivalence or comparability does not mean that the foreign country's system must be the same as Canada's inspection system. Rather, it is based on the ability of an exporting country's system or risk mitigating measures to achieve the same outcome or provide for the same "appropriate level of protection" as Canada's system or risk mitigating measures.
The CFIA would conduct foreign country audits according to the national treatment provisions of the World Trade Organization Agreement on Sanitary and Phytosanitary Measures.
Based on risk and available resources, the CFIA may choose to perform on-site foreign country system audits to review the requirements that a foreign country imposes on its domestic manufacturers. The results of these audits would feed into the risk-based inspection oversight framework as part of the CFIA's risk intelligence gathering and analysis activities. The CFIA is developing its policy on comparability assessment of trading partners and will be carrying out consultations as appropriate.
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