Dairy Program Record of Decision

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Subject:

Canadian Food Inspection Agency's (CFIA) Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products (commonly known as the Reference Listing)

Question or Description of Problem:

Due to the repeal of the Reference Listing from the Egg Regulations and the Fish Inspection Regulations, the Reference Listing will no longer be updated.

  1. How will the inspector evaluate that the packaging materials, construction materials and non-food chemicals are safe for use in registered dairy establishments and importer facilities?
  2. What will the regulated party need to do to ensure the safety of the packaging materials, construction materials and non-food chemicals they use in their establishments?

Background:

The Reference Listing is a list of construction materials, packaging materials and non-food chemicals which have been found by the CFIA to be acceptable for use in establishments operating under the authority of the Agency. The primary purpose of this publication (database) was to provide a ready reference for both inspection personnel and representatives of the managerial staff of establishments as a recommendation to indicate acceptance status for products intended for use in establishments.

The regulated party continues to remain responsible for ensuring that any packaging material, construction material or non-food chemicals used for food processing establishments and importers are safe and effective for their intended use and that all regulatory requirements are met.

In the Dairy Establishment Inspection Manual (DEIM), the use of the Reference Listing is referenced in numerous DEIM tasks, as follows:

  • Chapter 3: Industry Guide to Dairy Registration
  • Chapter 10: Prerequisite Programs
    • 1.10.01.04 Building Interior
    • 1.10.01.09 Water/Steam Quality & Supply
    • 1.10.02.03 Incoming Material
    • 1.10.02.08 Non Food Chemicals
    • 1.10.05.01 Sanitation Program – General
    • 1.10.05.04 Pest Control
  • Appendix 19-12 - Water Reclaimed from the Condensing of Milk and Milk Products

In the Inspection Procedures, previously referred to as the Dairy Product Inspection Manual (DPIM) the use of the Reference Listing is referenced as follows:

  • Import Activities - 1.6.3.2.B.5 (e) On-site practices – Non-Food Chemicals

Decision:

The Reference Listing continues to be available on the CFIA website (current up to December 2012).

The following measures will be used to assess the acceptability of packaging materials, construction materials, and non-food chemicals being used in federally registered dairy establishments and importers' facilities.

Industry

Federally registered establishments and importers remain responsible for using materials and/or chemical agents that are safe and effective. The CFIA recommends one of the following:

  1. Registered establishments and importers are responsible for updating their written programs to reflect that the packaging material, construction material and non-food chemicals is already in the Reference Listing; has a Letter of No Objection (LONO) from Health Canada, or has a Letter of Guarantee (LOG) from the manufacturer/supplier.
  2. Registered establishments and importers may wish to demonstrate that packaging material, construction material and non-food chemicals, are acceptable and that they are being used in accordance with manufacturer's directions/requirements.
  3. The Letter of No Objection from Health Canada or the Letter of Guarantee (see Appendix I) from the manufacturer/supplier should be received prior to using the packaging material, construction material or non-food chemical.

Inspectors

The CFIA continues to monitor through in-depth inspections and GIP inspections, that packaging materials, construction materials, and non-food chemical agents are safe, effective and meet regulatory requirements. Registered dairy establishments and importers are not required to use products contained in the Reference Listing.

  1. If the packaging material, construction material, non-food chemical is included in the Reference listing.
    • The inspector will accept proof from the registered establishment and the importer that it is in fact on the CFIA Reference Listing.
  2. If the packaging material, construction material or non-food chemical is not included in the Reference Listing:
    • Inspectors will request to see a LOG or a LONO:
      • LOG will be provided from the manufacturer to the registered establishment or importer, and kept on file.
      • The registered establishment or importer is responsible for ensuring that the proposed minimum requirements for the LOG (See Appendix 1) are met.
    • The inspector will verify the letter meets the criteria.
      • LONO will be provided by Health Canada to the registered establishment or importer, and kept on file.
    • Inspectors will accept proof that the material is accepted by a foreign country, if the final product is exported to that country:
      • Acceptable proof may be a letter from the importing country, or if the importing country maintains a list of acceptable packaging materials, construction materials and non-food chemicals.
  3. If the requirements as listed in items above are met, the inspector will rate the current DEIM tasks (Chapter 3, 1.10.01.04, 1.10.01.09, 1.10.02.03, 1.10.02.08, 1.10.05.01, 1.10.05.04) and task (1.6.3.2. B.5 (e)) from the GIP inspection as satisfactory with respect to the Reference listing.

Inspectors must contact their Area Program Specialist if they require assistance in determining the appropriateness of a packaging material, construction material or non-food chemical.

Dairy Establishment Inspection Manual / Inspection procedures

The DEIM and Inspection procedures/Importing activities will be updated to reflect these new requirements.

Paul Kirkby
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Recommended by: Process Evaluation Specialist, Dairy and Egg Programs

23/12/2013
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Date

Judy Scaife
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Approved by: A/National Manager

23/12/2013
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Date

Appendix 1 Letters of Guarantee (LOG)

  1. Letter of guarantee for food packaging materials:
    • Statement that the packaging material complies with Division 23 of the Food and Drug Regulations
    • Brand name of the packaging material
    • Name of the manufacturer/supplier
    • Conditions of use of the food packaging material
      • Details in regard to the use
        • (e.g. direct food contact, type of foods, etc.)
      • Temperature or state at which the food can be packaged
        • (e.g. Hot fill temperature, fresh, frozen, etc.)
      • Temperature at which the packaged food can be processed
        • (e.g. thermal process - maximum temperature - maximum exposure time)
      • State in which the packaged food can be stored
      • Temperature at which food product can be reconstituted in the package
        • (e.g. microwave – maximum temperature and exposure time)
      • Other critical limits/parameters
    • Signature of an official of the manufacturer/supplier
  2. Letter of guarantee (LOG) for non-food chemical products coming into contact with food or food contact surfaces:
    • A statement that the non-food chemical product is suitable for use as intended in food establishments;
    • Brand name of the non-food chemical product;
    • Name of the manufacturer/supplier;
    • Directions for use in food establishment;
    • Signature of an official of the manufacturer/supplier.
  3. Letter of guarantee (LOG) for construction materials:
    • A statement that the construction material is durable free of any noxious constituents;
    • Brand name of the construction material;
    • Name of the manufacturer/supplier;
    • Where applicable, directions for use in food establishment;
    • Signature of an official of the manufacturer/supplier.
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