Dairy Import Activities
1.6 Inspection Procedures

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1.6.1 Point Of Entry (ISC Task)

The CFIA has established three regional Import Service Centres: (ISC) Eastern Region – served from Montreal; Central Region – served from Mississauga; and Western Region – served from Burnaby. These are the CFIA primary contact points with brokers and importers for import documentation and procedures.

Dairy products' entry documents are generally presented to the ISC. Brokers or importers submit the following documents to the ISC for processing:

  • the Request for Release Approval (for cheese, import licence number indicated in the comments section) (CFIA/ACIA 5272; Appendix 7),
  • Import Declaration (for cheese, import licence number indicated in box 4) (CFIA/ACIA 4560; Appendix 2) and Import Declaration Annex A - Dairy Products (CFIA/ACIA 5304; Appendix 3) if necessary,
  • any supplementary documents such as the commercial invoice, manifest, cargo control document

These documents are initially reviewed for completeness and accuracy by the ISC staff, including validation of the CFIA cheese import licence number. Specific requirements for import declaration for the importation of dairy products are found in Appendix 8.

When submitted, if entry documents are found to be incomplete, the Request for Release Approval is not further processed. The ISC issues a Reject Notice with justification and faxes both the Request and the Reject notice back to the broker or importer for follow up.

When submitted, if entry documents are found to be complete, the Request for Release Approval is stamped and initialled. Alternately, if it is an EDI transaction, the release will be approved via the EDI program, and a paper stamp will not be used. EDI sends a release notification directly to the CBSA and the broker. The ISC generates an invoice for the collection of fees for standardized dairy products only. Specific fee requirements are found in Appendix 8 and Appendix 9. The Import declaration(s), and if applicable, the invoice and/or stamped (dated) Request for Release Approval are faxed back to the broker or importer who then submits the release package to CBSA.

In addition, the ISC inspector forwards a copy of the Dairy Import Declaration and any related documents to the CFIA regional office nearest to the product destination for further inspection purposes. Dairy inspectors receive these documents. See Appendix 10.

All Import Declarations and import documents are archived by ISC for reference.

1.6.2 Import Declaration Review and Product Verification (Dairy Inspector's Tasks)

1.6.2.1 Import Declaration Review (at CFIA office):

The dairy inspector must verify all import declarations for completeness and accuracy and to determine whether it is necessary to conduct an inspection of the imported product(s).

All dairy products must be listed on the Import Declaration (CFIA/ACIA 4560) or, on an attached supplementary sheet, Import Declaration Annex A - Dairy Products (CFIA/ACIA 5304).

For cheese varieties, the thermal process (pasteurized, unpasteurized (heat treated or raw milk) must be included along with the common name. For raw milk soft and semi soft cheeses from France, the Health certificate to export of some raw milk cheeses to Canada must be included in the documentation package. (See Appendix 11 for background information on the policy for raw milk soft and semi soft cheese from France, as well as a copy of a sample of certificate.) The inspector must also check other foreign certificates, if attached, for accuracy and completeness.

It is important that the import declaration is signed by the person who is legally responsible for bringing the imported product into Canada. For dairy products imported under quota, the quota holder is the legally responsible party and therefore should be the name and address used in Box 4 on the Import Declaration.

All non satisfactory (inaccurate, incomplete, etc.) or non-applicable import declarations must be followed up with the importer or Import Service Centre.

1.6.2.2 Product Verification (at facility site)

Product verification activities include label verification, net quantity verification, container integrity verification, lab sampling, follow-up inspections and follow-up to issues identified by environmental scanning.

The type of product inspection activities are based on the Import Dairy Program Activities Table (Appendix 4) and the compliance record of the importer and of the imported product.

The specific information regarding product inspection tasks and follow up to non-compliance is detailed in other documents of the Dairy Products Inspection Procedures.

1.6.3 Importer Verification (Dairy Inspector's Tasks)

This task assesses whether the importer assumes responsibility for the safety and compliance of imported dairy products. There are different importer facility types and inspections as follows:

  1. Non Registered Facilities: An importer that stores, distributes and/or further prepares dairy products for intra-provincial shipment, is inspected using Appendix 12 (see sections 1.6.3.1, 1.6.3.2 of this procedure for details).
  2. For an importer that does not store product, documentation is verified at the location where the records are stored using the Importer Verification Worksheet (Section A.0 – Importer Controls  A.2 – A.5, A.7, A.9, A.10 only).
  3. In addition to an inspection using Section A.0, storage facilities/warehouses receiving, distributing and/or further preparing dairy products may be inspected using the Importer Verification Worksheet (Section B.0 – Onsite Practices) during visits to perform product sampling/verification activities.
  4. Establishments importing dairy products for use as an ingredient in other food products (e.g. bakeries, restaurants) are not inspected by the Dairy Program.
    Note: Facilities further preparing imported products for intraprovincial trade may also be inspected by provincial and/or municipal authorities. When interprovincial trade of cut, shredded and/or repackaged imported dairy product occurs, the facility must become federally registered.
  5. Registered Facilities that also import: For registered facilities that also import, no extra facility inspection is required - follow the DEIM inspections or FSEP-HACCP Audit procedures

For identification and tracking purposes, importers are entered into the Client Management System (CMS) using importer as the client type. Each importer will be assigned a code (4 digits) according to the distribution below:

6000-6100 Atlantic (6001-6040NB, 6041-6080NS, 6081-6090PE, 6091-6100NF)
6101-6400 QC
6401-6700 ON
6701-6999 West (6701-6750MB, 6751-6800SK, 6801-6900AB, 6901-6999BC).

At non registered facilities the first four tasks of the Importer Verification Worksheet (Section 1.0 -1.1 – 1.4) are inspected at every visit (see Section 1.6.3.3). The Inspector verifies the Importer's controls and procedures and inspects on-site product storage conditions once a year. This activity should be performed in conjunction with one or more other product inspection activity(ies). No advance notice should be given prior to an Importer Verification inspection. Tasks must be assessed according to the criteria on the Import Verification Worksheet (Appendix 12) and the explanations provided below. The tasks are to be rated as Satisfactory, Non-Satisfactory, Not Applicable, Not Rated. Tasks with an * have a higher health and safety risk and therefore have a higher impact on overall assessment

Any deficiencies must be recorded on the CFIA/ACIA 950 form and the appropriate worksheet. All non-satisfactory tasks must be discussed with the importer and the CFIA/ACIA 950 signed by the importer or importer's designate and the inspector. Dates for the corrective measures must be set and noted on the CFIA/ACIA 950.

1.6.3.1 Completing the Importer Verification Worksheet (Appendix 12):
Section A.0 Importer controls

A.1 Import Documentation:

At the storage facility, the inspector ensures that the information provided on the import declaration matches the actual goods.

To evaluate this task, the inspector takes the appropriate import declaration and any supplementary documents (e.g. Sanitary certificates from France, IREP documents) and compares them with the related products available onsite. Items to be verified on the import declaration include: product identification, net quantity, pasteurized or unpasteurized, country of origin.

For soft and semi-soft cheeses made from raw milk and imported from France, a Health Certificate is required from French authorities confirming that:

  • the product is from a recognized establishment; only those recognized establishments are authorized to export raw milk, soft and semi-soft cheeses from France
  • the establishment performs microbiological self-testing of their production,
  • the establishment has had official sampling and analyses of its product within the last three months performed by the French authorities. (Note: the French document does not necessarily relate to the particular lot being imported.)

This certificate is acceptable in lieu of the 60 day storage requirement for unpasteurized cheeses.

If any non-conformity has an impact on food safety or fraud or when documents are missing, this task is rated as Non-satisfactory.

A.2* Product Specification Sheets:

The importer demonstrates that the dairy products imported meet the requirements of the Food and Drug Regulations, Dairy Products Regulations and the Consumer Packaging and Labelling Regulations and other applicable regulations. These sheets are required for the first shipment and updated whenever the formulation changes.

  1. Food ingredients, additives and allergens:
    Written specifications related to the products being imported are available. The specifications contain all details of the product as follows:
    • identification of specific ingredients,
    • components (ingredients of ingredients),
    • food additives (e.g. common name, type, specific name of food colours);
    • added nutrients
    • allergens
  2. Composition Requirements:
    Where regulatory standards for composition exist, (e.g. fat, moisture, total solids, casein content), evidence that substantiates that these requirements are met is included. Section .5.2.1 provides an explanation of acceptable documentation to assess compliance to the revised compositional standards for cheese.
  3. Packaging Material:
    Packaging materials coming in direct contact with the dairy products do not pose a contamination risk to the product (FDR, Division 23). Further documentation could be requested (e.g. certification from foreign regulatory authority, letters of no objection etc.)

To evaluate this task, the inspector reviews the product specifications. The inspector checks to see that food additives and product specifications meet Canadian requirements. The inspector also identifies presence of any potential allergens.

If the product specification sheets are incomplete, not available, or indicate that the product does not meet Canadian standards, this task is rated as non-satisfactory.

A.3 Foreign Certificates of Analysis:

The importer maintains a documented history of adherence to specifications for each product (not each lot) e.g. analytical results (for both micro and composition). The tests required on the certificate of analysis depend on hazard identification including the type of product, and its end-use (e.g. cheese vs. caseinates). The analyses can be performed using approved test methodologies by the manufacturer, a private laboratory, or a competent authority in the country of origin. (Dairy Sampling Procedures and DEIM 1.10.07.03 and .04 in the Process Control Program for further details.

When an importer changes suppliers, purchases product from a new supplier or purchases a new product from an existing supplier, a new history is developed.

The certificate of analysis (in English or French) includes the following:

  1. sampling procedure(s) (e.g. number of sub samples, composite sample, sample size, environmental sampling of food contact and non-food contact surfaces etc.) and analytical method(s) used
  2. date sampled and analysed, tests performed and results, name of laboratory conducting the analysis, product identification (including brand name and lot number), and the name and signature of the analyst.

To evaluate this task, the inspector reviews a representative sample of the files containing the certificates of analysis from all imported dairy products. When no foreign certificates of analysis or no historical data is available, this task is rated as non-satisfactory unless enhanced sampling and analysis is performed by the importer (see A.4). If the importer maintains an effective sampling and analysis program, this task is rated as Not Applicable.

A.4* Verification of Analyses:

In addition to receiving foreign certificates of analysis, the importer has a program in place to verify the accuracy of certificates of analysis (microbiological and composition). This can be done by analysing a representative sample at a scheduled frequency. The analysis can be performed by the importer or a private laboratory. Priority is given to: raw milk cheeses, cheeses at higher risk for supporting the growth of Lm (e.g. washed rind and surface ripened, soft and semi-soft cheeses) when the importer does not have evidence that the foreign manufacturer has an environmental monitoring program for Listeria (see HC Lm Policy), products with a history of non-compliance, and products imported at a high frequency and/or volume. When the importer's analyses do not agree with the foreign certificate of analysis, the importer should follow up with the supplier.

For sampling of dairy products see the Dairy Sampling Procedures and the Dairy Product Sampling section (1.6) of this chapter.

If environmental scans or CFIA monitoring identify a chemical residue issue, then chemical residue sampling of imported product may also be required.

To evaluate this task, the inspector reviews the analytical results for products. If the importer is not doing any verification or does not follow up on identified issues, this task is rated as Non-satisfactory.

A.5 Foreign Manufacturer's Information:

Prior to importation, the importer verifies that the manufacturer is capable of providing dairy products that comply with Canadian requirements including Health Canada's Policy on Listeria mononcytogenes in Ready-to-Eat Foods. This is done by the importer by obtaining information demonstrating that the critical steps of the manufacturing process are adequately controlled to ensure safety, quality and to prevent misrepresentation and fraud. Control of critical steps of the manufacturing process refers to process description, Listeria environmental monitoring, audit reports, microbiological verification results. The evaluation of foreign manufacturers should be conducted by technically competent personnel.

In the absence of such controls, the importer conducts increased product control (e.g. sampling, product and laboratory evaluation) to ensure risks are mitigated.

To evaluate this task, the inspector asks the importer for information pertaining to the manufacturer. If this is not available then the inspector evaluates other practices (e.g. sampling) that the importer is undertaking to ensure imported products meet Canadian requirements.

When no information pertaining to the manufacturer or no other documentation regarding practices undertaken by the importer is available, this task is rated as Non-satisfactory.

A.6 Receiving and Shipping Procedures:

All incoming products and products distributed by the importer are visually inspected for packaging conditions and checked for appropriate receiving / shipping temperatures.

The importer or responsible personnel has acceptance / rejection criteria for each product plus adequate technical knowledge and understanding of the significance of any food safety concerns. Stock rotation is controlled to minimize deterioration and prevent spoilage that could present a health hazard, e.g. product exceeding shelf life.

To evaluate this task the inspector reviews the importer's product receiving / shipping procedures and if possible watches the receiving and shipping of product. If no shipping or receiving is taking place during the inspection, the inspector inspects the product in storage to evaluate product damage. This task is rated Non-satisfactory if:

  1. Damaged or broken packages are not being discarded,
  2. Receiving/ shipping temperatures are not appropriate for the product,
  3. No acceptance/rejection criteria is established
  4. Stock rotation is not controlled.

A.7 Product Control Procedures (label, net quantity and can integrity):

Label:
The importer has procedures in place to ensure that all mandatory information is properly declared on food labels in compliance with the Canadian food labelling requirements and that all label claims are accurate and not misleading. This includes, but is not limited to mandatory information, quality and compositional claims, net quantity declaration, coding, nutrition facts, health claims, and standards. There are specific labelling requirements for unpasteurized cheese i.e. any cheese that is not made from pasteurized source. See FDR sections:

B.08.042 (marked with the date of the beginning of manufacturing),
B.08.043 (storage and labelling of cut cheese portions),
B.08.046 (whole cheese stamped with the date of beginning of manufacturing),

Net Quantity:
The importer has procedures in place to verify that the net quantity is correct. See the document on Dairy Net Quantity Verification procedures for more information.

Can Integrity:
The presence of serious container defects in low acid foods in hermetically sealed containers may result in a loss of container integrity or microbial contamination. A trained person at the facility performs can integrity checks on incoming lots of canned products to ensure cans meet Canadian requirements. The frequency is based on historical data and country of origin status. For more information as to how these inspections are performed see Low-Acid and Acidified Low-Acid Foods in Hermetically Sealed Containers - Visual Inspection Protocol.

Records of container integrity checks are available for the inspector to review.

To evaluate this task the inspector reviews records and discusses with the importer how labels, net quantity and can integrity are verified. If the importer has no procedures in place and no verification is being performed, this task will be rated as Non-satisfactory.

A.8 Pest Control:

The importer takes effective measures to prevent entry, to detect and eliminate pests and to prevent the contamination of food. All animals, birds and insects are excluded from facility.

To evaluate this task, the inspector will discuss the pest control program with the importer. At cheese importers who cut, shred, repackage etc., the inspector evaluates the written pest control program. The final determination is based on observations made during the on-site of this inspection (See B.5 below). This task is assessed Non-satisfactory if no procedures are in place or when the on-site is done and the procedures are deemed ineffective.

A.9 Complaint Handling:

The importer has an effective system to handle and investigate product complaints. Complaints are accurately categorized according to food safety, composition, quality and other regulatory concerns. Potentially serious food safety complaints are forwarded immediately to appropriate personnel, including the CFIA, for action. The importer maintains detailed records of consumer complaints received, investigation findings and corrective actions taken.

To evaluate this task the inspector reviews the importer's complaint file. This task is assessed Non-satisfactory if no procedures are in place and when complaints are not filed or investigated adequately.

A.10* Recall Procedures:

The importer has a written recall procedure to ensure an effective recall of any lot of dairy product from the market. The written procedure includes:

  • the person or persons responsible, e.g. recall coordinator(s),
  • the roles and responsibilities for coordination and implementation of a recall,
  • methods to identify, locate and control recalled product,
  • a requirement to investigate other products that may be affected by the hazard and that should be included in the recall,
  • procedures for monitoring the effectiveness of the recall, e.g. effectiveness check to the appropriate level of distribution specified in the recall notice,
  • immediate notification of the Canadian Food Inspection Agency Area Recall Coordinator in the area or region where the importer is located.

Recall procedures are tested periodically to verify the capability to rapidly identify and remove product from the market. This can be done by internal simulations on a code lot and by reconciling the amount of product imported, in inventory and in distribution. Any deficiencies in the recall procedures are identified and corrected.

For information on creating a Recall Plan see CFIA website.

Additional guidelines on food emergencies can be found in the Canadian Food Inspection Agency - Food Investigation Response Manual

To evaluate this task, the inspector reviews the importer's written recall procedure and documentation related to mock recall. If a recall has recently occurred, the inspector also reviews the documentation related to the recall. This task will be rated Non-satisfactory when the importer has no written recall procedure or no mock recalls have been done, or the recall procedures have been found to be ineffective.

A.11* Water Quality (establishments preparing dairy products)

Importers preparing (cutting, shredding, repackaging) dairy products have controls in place to ensure they are continuously using safe/potable water in the preparation and processing of food. Source of water is documented (well or city). There must be a safe, sanitary and adequate supply of water for use in the establishment at all times. The water supply source must meet the requirements of Health Canada's "Guidelines for Canadian Drinking Water Quality". Water is analyzed by the importer or the municipality at a frequency adequate to confirm its potability.

To evaluate this task, the inspector reviews records confirming the source and the microbiological quality of the water. This task is rated as non-satisfactory when no water records are available or if unsatisfactory results have not been followed up.

A.12* Sanitation Program (establishments preparing dairy products)

Importers preparing (cutting, shredding, repackaging) dairy products have controls in place to ensure that the facility and equipment are clean and sanitary. Each importer has a documented cleaning and sanitation program which specifies the cleaning policy (what is done), type and frequency of cleaning (when it is done or how often), procedures used (how it is done), responsible personnel (who is doing it), cleaning verification (both on-site and record review), records to be kept and results of monitoring and action taken for deviant situations. The program specifies the parameters of acceptability/unacceptability (tolerances). Special sanitation and housekeeping procedures required during production are specified (e.g. removal of product residues during breaks). This program is updated as required when changes occur.

Importers of Ready-to-Eat (RTE) dairy products that are further prepared need to verify that their sanitation and Listeria controls are effective and in accordance with HC's Policy on Listeria monocytogenes in RTE foods.

Adequate environmental and end product sampling and testing are performed (refer to HC's Compendium of Analytical Methods). Sampling of Food Contact Surfaces (FCS) during production and non-FCS is required to assess adherence to good manufacturing practices (GMPs).

Timely and appropriate follow up action is required for non-compliant findings and is to be taken into account for trend analysis and changes to frequency of monitoring.

Sampling frequencies for finished product are based on risk assessment taking into consideration product characteristics, history of compliance, further processing (i.e. cutting, shredding, and grating) etc. All positive results for L. monocytogenes or persistent ones for Listeria spp on a FCS are communicated to CFIA with a corrective action plan.

To evaluate this task, the inspector reviews the sanitation program and records including controls for Listeria in the environment and end product. This task is rated as non-satisfactory if the sanitation program is absent, incomplete or ineffective or if records are not available.

1.6.3.2 Completing the Importer Verification Worksheet (Appendix 12) Section B.0 On-site practices

At the importer's storage facility, the inspector will observe operations, including the employees at work, paying particular attention to their personal hygiene practices, food handling practices and movement within the establishment (cross contamination).

B.1 Sanitary Handling and Preparation (establishments preparing dairy products)

This task applies where persons are handling unprotected food products specifically in cutting, shredding and repackaging facilities.

Sanitary Handling:
Hands free hand washing facilities are made available to employees in production areas of the facility. Hands are washed before starting work, after breaks, after using toilet facilities and after handling contaminated materials such as skids. Where necessary to minimize microbiological contamination, employees use disinfectant hand dips.

Protective clothing, hair covering, footwear and/or gloves, appropriate to the operation in which the employee is engaged are worn and maintained in a sanitary manner. Any behaviour which could result in contamination of food, such as eating, use of tobacco, chewing gum, or unhygienic practices such as spitting are prohibited in food handling areas. All persons entering unprotected-food handling areas remove jewellery and other objects which may fall into or otherwise contaminate food. Jewellery which cannot be removed, including wedding bands and medical alerts, is covered. Access of personnel and visitors is controlled to prevent contamination. To reduce the risk of contamination in food handling areas the movement of personnel between areas is well controlled.

Cutting, Shredding, Repackaging, etc. of Product (Preparation - not including storage):
In these facilities, food additives used are controlled to meet the requirements of the FDA/R. Inadequate control of food additives could result in chemical or biological hazards. All food additives used are permitted for use in the particular food and meet the requirements of the FDR. The specifications for all food additives are on file. Calculations demonstrate that food additives used are within the maximum level specified.

To evaluate this task, the inspector watches employee practices and makes an evaluation of potential product contamination due to poor handling practices. This task will be rated as non-satisfactory when the inspector determines that there is potential contamination of the product due to poor handling procedures.

B.2 Product Coding and Information:

Every prepackaged dairy product imported, or imported and repackaged, is labelled on any surface of the container with a batch number, code number or lot number identifying an appropriate, meaningful sized unit of production. This information must be permanent and legible. All prepackaged and bulk dairy products with a durable life of ninety days or less must have a durable life date and instructions for proper storage. The code marks used and the exact meaning of the code must be available. Case codes (where used) must be legible and represent the container code within.

For cheese which is not made from a pasteurized source, see Section A.7 Product Control Procedures above.

To evaluate this task, the inspector selects at least one label, and checks for lot/batch coding, best before date and instructions for proper storage as applicable. This task will be rated as non-satisfactory when the product label is not properly coded.

B.3* Suitable Storage Conditions (temperature and relative humidity):

Imported dairy products are stored under conditions to prevent damage, deterioration and contamination.

  • the products requiring refrigeration are stored at 4°C (39°F) or less and are monitored and recorded,
  • frozen products are stored at temperatures that do not permit thawing and are monitored and should be recorded,
  • the products are handled and stored in a manner to prevent damage and/or contamination e.g. microbial spoilage, rusting or corrosion, protection of susceptible product to the effects of light, and forklift damage,
  • products sensitive to humidity are stored under appropriate conditions to prevent deterioration,
  • any other acceptable manufacturer instructions for specific products should be followed.

To evaluate this task, the inspector visits the storage facility and verifies that temperatures, humidity and appropriate storage conditions are met (e.g. canned products are not corroding due to excessive humidity or dry milk powder bags do not show visible deterioration). This task will be rated non-satisfactory when the product is stored under inappropriate conditions or temperatures are not being monitored.

B.4 Receiving and Shipping Conditions:

  • carriers are inspected by the importer upon receipt and prior to loading to ensure they are free from contamination and suitable for the transportation of food,
  • carriers are loaded, arranged and unloaded in a manner that prevents damage and contamination of the food,
  • products are transported under conditions to minimize microbiological, physical and chemical deterioration,
  • products requiring refrigeration are transported at 4°C (39°F) or less and are appropriately monitored (no records required),
  • frozen products are transported at temperatures that do not permit thawing.

If the inspector observes the receiving and shipping of product, he/she evaluates if the requirements are met. This task is rated non-satisfactory when the product is transported under inappropriate conditions or temperatures are not being monitored.

B.5 Absence of Cross-contamination:

  1. Pests:
    • poisonous rodenticides are not used in food, packaging or storage areas
    • birds, insects and animals are excluded from the facility

    To evaluate this, the inspector inspects the facility, looking at the pest control devices in use, as well as observing for presence of pest activity.

  2. Returned products:
    • returned defective or suspect products are clearly identified and isolated in a designated area for appropriate disposition/sorting

    To evaluate this, the inspector inspects the storage areas and observes storage practices and segregation of any returned, defective or suspect product.

  3. Garbage:
    • adequate containers and equipment are provided and maintained for the storage of waste and inedible material prior to removal from the establishment,
    • containers are designed to prevent contamination,
    • containers used for waste are clearly identified, leak proof and where appropriate are covered,
    • waste is removed and containers are cleaned and sanitized at an appropriate frequency to minimize potential contamination.

    To evaluate this, the inspector inspects garbage containers. No excessive garbage build up should exist in the facility.

  4. Structure:
    • building interiors and structures are designed, constructed and maintained in a manner to prevent conditions which may result in the contamination of food.

    To evaluate this, the inspector observes the general conditions of floors, walls, ceilings and overhead structures. The inspector determines if there is the possibility of cross contamination if food is exposed.

  5. Non-Food Chemicals:
    • non-food chemicals are stored in designated areas such that there is no possibility for cross contamination of food or food contact surfaces,
    • chemicals are dispensed and handled only by authorized and properly trained personnel.
    • in areas where there is exposed food, the chemicals used for sanitation purposes are:
      1. suitable for use in food processing operations, and used in accordance with the written sanitation program
      2. listed in "CFIA Reference listing of accepted construction, packaging materials and non-food chemical products" or the manufacturer has a "letter of no objection" from Health Canada.

    To evaluate this, the inspector observes storage and handling practices of chemicals in the facility and reviews the chemicals used.

  6. Glass Breakage Policy:

    The importer has a documented glass breakage policy to control the risk of glass or glass substitute contamination should breakage occur. In areas where there is exposed food, if glass is used it is recommended that it be shatterproof.

    In case of breakage:

    1. the effected processing area is shut down
    2. broken glass containers and fragments are removed from the area
    3. clean up procedures are outlined (so not to spread the contamination)
    4. area is inspected to ensure that the clean up was adequate
    5. the breakage and type (thermal shock, impact etc.) is recorded
    6. food in the area of the breakage is segregated and examined for contamination

    Records are maintained with date, time and location.

    To evaluate this, the inspector reviews the importer's glass breakage policy, on-site conditions and records.

    Overall task rating: This task (not each sub-task) is rated as Non-satisfactory if there are inadequate controls to prevent potential cross contamination or if any sub-task(s) poses a contamination risk

B.6 Sanitary Conditions (establishments preparing dairy products)

  • equipment coming into contact with product is clean and sanitary
  • floors, walls and ceiling of the facility are clean and sanitary to prevent contamination of exposed product

To evaluate this task the inspector observes the facility and equipment for cleanliness. This task is evaluated as non-satisfactory when poor sanitation is observed.

1.6.3.3 Tasks to perform at every visit

At every visit to the importer's facility, the CFIA inspector assesses, where applicable, the four first tasks of the Importer Verification Worksheet (Appendix 12 - Tasks A.1-A.4). These tasks refer to appropriate documentation related to the product being imported and to the control procedures that the importer has in place to confirm its conformity. Although no overall score is given for these inspections, the importer is expected to correct any tasks rated as non-satisfactory.

1.6.4 Overall Inspection Assessment - Importer Verification

The overall inspection is rated as non-satisfactory under the following conditions:

  1. When one or more inspection tasks identified with an asterisk (* - tasks with higher risk relative to health and safety) is/are rated non-satisfactory i.e. A.2, A.4, A.10, A.11, A.12 and B.3; or,
  2. When four or more tasks not identified with an asterisk are rated non-satisfactory

Otherwise, the overall inspection is rated as satisfactory.

The overall assessment is noted on the CFIA/ACIA 950. Actions to be taken depend on the overall assessment and are outlined below.

1.6.4.1 Satisfactory Inspections

Even if the overall inspection is assessed as satisfactory, any non-satisfactory tasks are noted on the CFIA/ACIA 950 form.

The inspector may request (e.g. in case of unsanitary handling of product, cross-contamination) that the importer respond in a letter outlining their intended plan of action. This action plan should be received by the CFIA office no later than 3 weeks from the inspection date.

The corrective action(s) is verified on a subsequent inspection.

1.6.4.2 Non Satisfactory Inspections

The overall results are discussed with the importer. It is important that the importer understands the results of the inspection, why the tasks are non satisfactory and that these tasks must be corrected. A written corrective action plan must be received by the CFIA office no later than 3 weeks from the inspection date. A covering letter may accompany the inspection report. An example of a covering letter can be found in Appendix 13.

Actions to be taken for non-satisfactory inspections are based on the severity of the findings and/or level of responsibility taken by the importer. The impact of the deficiency is evaluated to determine if product safety has been compromised and what actions, if any, the importer has taken to determine that the product is safe. The corrective actions are verified on a subsequent follow up inspection. For the following two scenarios, it is important that the inspector inform the appropriate Dairy Specialist in order to jointly determine the action to be taken:

a) Health & Safety implications:

This could be due to the non-satisfactory evaluation of any task with an asterisk (*) on the Importer Verification Worksheet or the occurrence of direct product contamination. If any of these tasks are non-satisfactory, immediate action is taken to isolate affected product.

If the importer has not demonstrated to the inspector that the product is under control or safe, it is detained as per the Detention and Release Procedures. Microbiological, chemical or physical analysis of the affected lots may be done to determine the product's safety.

If the inspector suspects there may be contamination due to environmental conditions, particularly in an importer's facility which is cutting or repackaging products, the inspector may choose to take an environmental sample. Environmental sampling of an importer's facilities is conducted according to procedures outlined in Environmental and Finished Dairy Product Sampling Monitoring for Listeria monocytogenes. If positive results are received, the inspector must refer the issue to non-satisfactory inspection procedures outlined in the above document.

If product has been distributed, the inspector immediately contacts the appropriate Area Recall Coordinator / Specialist with the relevant details to determine if a product recall is necessary as per the recall protocol.

In addition to controlling the affected product, the importer also takes the appropriate measures (e.g. training, reviewing written procedures) to prevent the problem from re-occurring,

b) Lack of importer responsibility:

This is indicated by repetitive inaction by the importer either to formulate an action plan or to carry out any corrective actions.

A meeting is set up with the appropriate responsible management to thoroughly explain the deficiencies and why they must be corrected. The meeting should end with developing a mutually agreed upon action plan and a commitment for its implementation.

If subsequent inspections do not indicate satisfactory corrective action and it is felt that compliance will not be forthcoming, some of the mechanisms that can be applied include targeting the product through border lookouts, product detentions, increased sampling, suspension or cancellation of cheese import licence, etc.

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