Export Certification Control Program Reference Standard

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Table of Contents

  • 1. Purpose
  • 2. Scope
  • 3. Definitions
  • 4. Reference Tools
  • 5. Elements of the Plan
    • 5.1 Management Roles and Responsibilities
      • 5.1.1 Person responsible
      • 5.1.2 Management Commitment
    • 5.2 Foreign Country Requirements
      • 5.2.1 Fish and Seafood for Export
      • 5.2.2 Foreign Certification Requirements
      • 5.2.3 Foreign Establishment Eligibility Requirements
    • 5.3 Product Compliance
      • 5.3.1 Product Standards
      • 5.3.2 Product Inspections to verify ECCP control measures
      • 5.3.3 Product Inspections to verify the compliance of fish or seafood for export
      • 5.3.4 Supplier Quality Assurance Program
    • 5.4 Certification
      • 5.4.1 Certificate Requests
      • 5.4.2 Replacement Certificates
    • 5.5 Traceability
      • 5.5.1 Lot accountability
      • 5.5.2 Health and Safety Verification and Notification
    • 5.6 Licensed Establishments of Live and/or Fresh fish and Seafood
      • 5.6.1 Conveyances and Equipment
      • 5.6.2 Establishment Requirements
      • 5.6.3 Sanitation and Personnel Hygiene
      • 5.6.4 Pest Control
      • 5.6.5 Hazard Analysis
    • 5.7 Consignment Storage and Transportation
    • 5.8 Verification & Maintenance of the ECCP Plan
      • 5.8.1 Ongoing Maintenance
      • 5.8.2 Annual Review
    • 5.9 Maintenance of Records and Documents
      • 5.9.1 Records relevant to the ECCP plan
      • 5.9.2 Amendments to the ECCP plan
  • Appendix A: Protocol for Partially Completed Certificates Guidelines

1. Purpose

This standard outlines the requirements for the documentation and application of a system-based export certification control program (ECCP) to ensure fish products for export comply with the Fish Inspection Regulations (FIR) and with additional foreign requirements which may apply.

2. Scope

This document applies:

  1. In full, to persons or companies applying for, or which already have, a fish export licence.
  2. In part, to registered establishments participating in a system based certification approach. Only elements 5.1, 5.2, 5.3, 5.4, 5.8 and 5.9 of this reference standard are required to be incorporated into the establishment's existing Quality Management Program (QMP).

Note: elements 5.5, 5.6, and 5.7 are already covered in the existing QMP plan but should be reviewed to ensure completeness.

3. Definitions

Broker
an individual or party that purchases fish or seafood for resale without any further transformation, including repackaging or labelling.
Certificate
is a paper or electronic document issued by the CFIA that describes and attests to attributes of consignments of fish destined for international trade.
Certification
the procedure by which official certification bodies or officially recognized certification bodies provide written or equivalent assurance that food or food control systems conform to requirements. Certification of food may be, as appropriate, based on a range of inspection activities which may include continuous on-line inspection, auditing of quality assurance systems, or product inspection.
Consignment
a specific quantity of fish or seafood imported or exported on a single transport carrier or vessel by one person.
Consignor

On an export certificate, the consignor is the owner or legally responsible party.

Note: If using partially completed certificates, only registered and licenced establishments requiring partially completed export certificates for Canadian live and/or fresh fish can be indicated as the consignor.

Control Measures
an action performed to maintain adherence to a standard or to eliminate a hazard or reduce it to an acceptable level.
Corrective Actions
the procedure that is to be followed whenever the results of monitoring activities show that there is a lack of compliance with the Fish Inspection Regulations.
Export Certification Control Program (ECCP) plan
the exporter's written description of the control measures and procedures implemented to ensure that exported fish products comply with the FIR and with additional foreign country requirements, if applicable.
Foreign country certification requirements
the conditions as outlined on a CFIA recognized certificate that must be met to satisfy a foreign country's import requirements.
Licensed Establishment
an establishment licensed by the CFIA under the FIR that only washes, ices or boxes live or fresh unfrozen fish or seafood, or stores finished fish products, for export.
Lot by Lot Certification
certification that is based on the inspection of a defined lot of product.
Monitoring
a planned observation or measurement of a parameter, at a specified point or time, which is compared to a standard or requirement.
Quality Management Program (QMP)
a fish inspection and control management system implemented by a registered establishment that includes procedures, inspections and records for the purpose of verifying and documenting the processing of fish and the safety and quality of fish processed in, exported from or imported into Canada (Section 2, FIR).
Registered Establishment
a freezer-factory vessel, barge, onshore plant, building or premise where fish are processed or stored for export that is registered by the CFIA under the FIR.
System Based Certification
certification based on the exporter's compliance with its export certification control program plan.

4. Reference Tools

Fish Inspection Regulations

Export Information By Jurisdiction

5. Elements of the Export Certificate Control Program (ECCP) Plan

Registered establishments may refer to their written Quality Management Program (QMP) for certain ECCP elements addressed and develop the remainder of their ECCP plan as a Standard Operating Procedure (SOP) or equivalent under the Regulatory Action Point (RAP) component Minimum Acceptable Fish Products Standards.

Non-registered (licensed) establishments must develop a written ECCP plan and submit it to CFIA for review prior to being issued an export license.

5.1 Management Roles and Responsibilities

Intent

Management must identify and support the person responsible for the design, implementation and maintenance of the ECCP.

Management must be committed to and supportive of the development, implementation and maintenance of the ECCP.

Requirements

5.1.1 Person responsible

The ECCP plan must identify the name(s) and/or position(s) of the person(s) or service provider who developed the program.

The ECCP plan must identify the name or title of the person responsible for the implementation and maintenance of the program, their business address, e-mail address and a telephone number where they can be reached in Canada.

5.1.2 Management Commitment

Management must ensure that the ECCP plan is designed, implemented and maintained by capable personnel. The ECCP must describe the monitoring procedures used to ensure that the control measures are being correctly and consistently carried out. The monitoring procedures must clearly specify what is being monitored, how it is being monitored, at what frequency, and by whom. The frequency identified for each monitoring activity must be sufficient to ensure that the standard is being met.

The ECCP plan must include an attestation from management acknowledging their responsibility for ensuring that the ECCP is designed and implemented in accordance to the reference standard and acknowledging their commitment to and support for the ECCP.

The ECCP must also be signed by a senior level manager or the owner of the business and, if different, the person responsible for the implementation and maintenance of the plan to acknowledge the commitment to and support for the plan.

5.2 Foreign Country Requirements

Intent

Foreign import requirements must be known in order to ensure the compliance of exports with these requirements.

Requirements

Exporters must know the foreign import requirements which apply to the fish and seafood they export.

5.2.1 Fish and Seafood for Export

The ECCP must describe the fish and/or seafood for export, and for which export certificates are required. This must include (as applicable):

  • The scientific name of each species.
  • The production method (wild or farmed).
  • The descriptive common name.
  • The attributes and characteristics that are important in ensuring the safety of the fish or seafood.
  • The ingredients.
  • The packaging.
  • The end use.
  • The shelf life.
  • The storage condition (refrigerated, frozen, shelf-stable).
  • The source of the fish or seafood.
  • The country of origin of the fish or seafood.
  • The name of the establishment where the fish or seafood was sourced from.
5.2.2 Certification Requirements

The ECCP must indicate, for each type of product for export:

  • The foreign countries of export.
  • Foreign certification requirements.Footnote 1
  • The certificate(s) required (recognized by the CFIA).

    Note: Though ECCP applies to certificates signed under the Fish Program only, exporters may also include reference to animal health certificates issued under the National Aquatic Animal Health Program (NAAHP), especially when those certificates are required in addition to certificates under the Fish Program.

5.2.3 Establishment Eligibility Requirements

The ECCP plan must indicate, for each country of export, that country's fish and seafood establishment eligibility requirements, as applicable. For example:

  • Sourcing of fish or seafood from a federally registered establishment or a licensed establishment that holds a fish export licence (brokers only).
  • The posting of the establishment on the list of establishments approved to export to the foreign country, as applicable.
  • Sourcing of imported fish or seafood from an establishment eligible to export to the foreign country, as applicable.

Control Measures

The ECCP plan must describe:

  • The person responsible to maintain accurate and up-to-date information on the products exported.
  • The person responsible to determine and maintain accurate and up-to-date information on the foreign import and certification requirements.
  • The measures taken to ensure the eligibility of the product for export (request for addition to a list of establishments approved to export, review of lists of establishments approved to export, etc.).

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the foreign country requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occurring.

5.3 Product Compliance

Intent

Exported fish and seafood comply with established Canadian and foreign standards.

Compliance with Canadian requirements is assured through the implementation, maintenance and verification of control measures for the processing, storage, handling and transportation of fish and seafood in accordance with the Fish Inspection Regulations.

Compliance with foreign certification requirements pertaining to fish or seafood standards that exceed Canadian standards, or for which there is no Canadian standard, is the responsibility of the exporter. A description of how the exporter will ensure product compliance must be included in the ECCP.

Requirements

The exporter must ensure that all fish and seafood exported comply with Canadian and foreign standards.

5.3.1 Product standardsFootnote 2

The ECCP plan must indicate the standards the fish or seafood must comply with:

  1. Chemical and Microbiological standards, as applicable.
  2. Labelling requirements.
  3. Sensory and Net Content standards.
5.3.2 Product Inspections to verify ECCP control measures

Fish and seafood are subject to inspection by the exporter in order to verify the implementation and effectiveness of the control measures in place to assure the compliance of fish and seafood with Canadian and foreign country requirements.

The inspection may be conducted in house when using procedures and methods accepted by the CFIA and records must be kept of all inspections for all lots certified for export.

5.3.3 Product Inspections to verify the compliance of fish or seafood for export

Fish and seafood must be sampled for inspection in accordance to the procedures outlined in the Fish Inspection Program Sampling Procedures or equivalent procedures.

Physical tests such as sensory evaluation, container integrity and net content determination must be conducted in accordance to the CFIA Fish Products Standards and Methods Manual and Fish Products Inspection Manual or equivalent procedures.

Fish and seafood may need to be sampled for laboratory analysis when:

  • There are foreign standards which exceed Canadian standards, or for which a Canadian standard does not exist;
  • The importing country has previously rejected product from the exporter

Microbiological and chemical analyses must be conducted by a laboratory accredited by the Standards Council of Canada (SCC) or by the Canadian Association for Laboratory Accreditation (CALA) for those analyses. Test results from SCC or CALA accredited laboratories are recognized by the CFIA as official results.

Note: As per the FIR, fish or seafood found to have in or upon it a poisonous or harmful substance cannot be re-inspected (the fish or seafood sample cannot be tested again nor can new samples from the lot be tested).

5.3.4 Supplier Quality Assurance Agreement

Brokers may develop and implement a Supplier Quality Assurance Program (SQA) agreement with each supplier (registered or licensed establishment) requiring them to conduct any required product testing to assure compliance of the fish or seafood with foreign standards.

The SQA must comply with the CFIA Criteria for an Acceptable Supplier Quality Assurance Agreement.

Control Measures

The ECCP plan must include:

  • The person responsible for product compliance.
  • The sampling and inspection procedures followed.
  • The test methods and laboratories (if applicable) used and standards applied.
  • A copy of all signed SQAs.
  • The frequency and process for audit of each SQA.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occurring.

5.4 Certification

Intent

Exporters must ensure the accuracy of information provided when requesting a certificate.

Requirements

Certificates must be requested prior to the product leaving Canada.

An eligible exporter may identify in their ECCP, and give written permission to, a third party (i.e. freight forwarder) to request certificates on their behalf.

Certificates requested must be approved by the country of export and recognized by the CFIA.

Certificates can only be issued when the fish or seafood are in compliance with all applicable requirements of the importing country and the FIR.

The certification information provided must be complete and describe the consignment accurately.

All lots identified in the consignment, for certification, must be available for inspection by the CFIA, if necessary.

5.4.1 Certificate Requests

It is the exporter's responsibility to accurately complete the correct certificate(s) for each consignment. Requests for certificates must be made by the consignor listed on the certificate (unless a third party has been identified).

Note: Mastering of product from one certificate to another by a broker will no longer be permitted. If the consignor is not a licensed exporter or a registered plant, then each lot submitted for certification will be 100% inspected under cost recovery.

The following mandatory information is required on each certificate:

  • total units and unit size of each lot in the consignment;
  • product description (size, grade, type);
  • scientific name of the fish or seafood;
  • consignee name and address;
  • consignor name and address;
  • product identification marks (production code);
  • mode of transportation.

The exporter must provide, in writing, the following details if they are not included or clearly identified on the certificate:

  • country of export;
  • recognized certificate type(s);
  • location of the consignment;
  • date the consignment is available for inspection;
  • date the certificate is required (date of departure);
  • who is to be charged for the certificate (unless otherwise stated, the consignor identified will be invoiced for the certificate).
5.4.2 Replacement Certificates

A replacement certificate can be requested when:

  • There is an administration error on a certificate.
  • A certificate is lost or damaged.
  • The consignee of the fish or seafood certified has changed.
  • There is a change in the quantity of product certified.

A replacement certificate can only be requested when the integrity of the consignment has been maintained.

If the product has been imported into the foreign country, a replacement certificate can only be issued if the information on the replacement certificate is identical to the original and the new certificate is intended to replace a lost original. The exporter must also provide a written explanation on why the replacement certificate is required and the actions taken to prevent a reoccurrence.

The original certificate is considered void and must be returned to the CFIA. A written explanation must be provided to the CFIA when a certificate cannot be returned.

A copy of the original certificate (or the original), the replacement certificate issued and a written explanation of the event must be kept on file at the local CFIA office responsible for issuing the replacement certificate.

Control Measures

The ECCP plan must describe:

  • The person responsible for requesting or cancelling certificates.
  • The person responsible for ensuring certificate requests are valid, complete, and represent accurately the consignment.
  • The person responsible for tracking export certificates received, cancelled, replaced and the fish or seafood certified.
  • The process and controls to ensure that the correct certificate is completed and submitted for signature; the information provided is true and accurate and all certificates are tracked.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occurring.

5.5 Traceability

This element is covered in the QMP plans for registered establishments.

Intent

The CFIA must be notified when an exporter receives information that exported fish or seafood is determined to constitute a hazard to the public.

Information on the distribution of fish and seafood must be readily available to allow for the rapid recall of fish or seafood determined to constitute a hazard to the public.

5.5.1 Lot Accountability
Requirements

Exporters must be able to identify all the certificates issued to them by the CFIA, the fish or seafood certified by each certificate, and the status of the lots certified (in inventory or exported). The distribution of the exported fish and seafood must be traceable to the first shipping destination to allow for the rapid recall of fish or seafood determined to constitute a hazard to the public.

For this purpose, a copy of each certificate issued by the CFIA, or the following information must be maintained for each consignment certified by the CFIA:

  • the country of export;
  • the certificate type(s) received;
  • the certificate number(s);
  • description of the lots;
  • the scientific and common names of the fish or seafood;
  • the method of production (wild caught or farmed)
  • the name and registration/licence number of the establishment from which the fish was sourced, if applicable;
  • processing/packing date(s)/codes;
  • the net weight of each unit;
  • the total net weight of the lots
  • the storage conditions of the product;
  • the name and address of each person/company (consignee) receiving the fish or seafood;
  • the date the CFIA signed the certificate;
  • the date the consignment was exported;
  • the mode of transportation and container number (e.g. by air, by ship).

Replacement certificates received from the CFIA must be linked to the original certificate which was cancelled.

5.5.2 Health and Safety Verification and Notification
Requirement

When information or a complaint is received that questions the safety of fish or seafood exported, the validity of the information must be verified to determine whether the fish or seafood constitutes a hazard to the public.

When the verification indicates that the fish or seafood constitutes a hazard to the public, the CFIA must be notified within 24 hours.

The following information must be kept on file and provided to the CFIA when the fish or seafood is determined to constitute a hazard to the public:

  • the date and time the information was received;
  • the name, address and telephone number of the person who provided the information;
  • the date and time the information was determined to be valid or not;
  • the date and time the CFIA was notified about valid information;
  • a description of the investigation conducted;
  • a description of the results of the investigation;
  • the actions taken by the exporter in response to a confirmed health and safety issue.

Control Measures

The ECCP plan must describe:

  • The person responsible to investigate the information received that questions the safety of fish or seafood exported.
  • The person responsible to notify the CFIA within 24 hours when the investigation indicates that the fish or seafood constitutes a hazard to the public.
  • The record-keeping process for the information received, the investigation and CFIA notification.
  • A description of the recall process – including the investigation, communication and recall procedures.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occurring.

5.6 Licensed Establishments of Live and/or Fresh fish and SeafoodFootnote 3

This element is covered in the QMP plans for registered establishments.

Intent

Establishments must protect from contamination and preserve the quality and safety of the fish and seafood they export.

Requirements

The fish or seafood must be protected from contamination and cross-contamination from the equipment, water, air, personnel and any other sources of contamination, including insect and animal pests. The quality and safety of the fish or seafood must also be preserved.

5.6.1 Conveyances and Equipment

Conveyances and equipment used to unload and handle live or fresh fish must be constructed and maintained in such a way that it will not become a potential source of contaminations. Equipment must be made of materials that are non-corrosive and non-porous to allow it to be cleaned and disinfected and meet the following requirements:

  • The equipment and handling practices used during the unloading and handling of fresh or live fish or seafood must be smooth with no sharp corners or projections that could pierce, tear or otherwise damage or contaminate the edible portions.
  • Fish handling equipment or containers and surfaces which come in contact with fresh or live fish or seafood must be of smooth, non-absorbent, non-corrodible material free from cracks and crevices that can be easily cleaned and maintained in a sound condition for ease of cleaning and disinfection.
5.6.2 Establishment Requirements

The establishment must be constructed in a manner that:

  • Permits adequate cleaning and disinfection (where applicable) of all areas.
  • Prevents the accumulation of dirt, contact of the fish or seafood with toxic materials and floor surfaces, the shedding of foreign particles into fish and the formation of condensation or mould on surfaces.
  • Prevents contamination from the equipment, water, air or personnel and any other sources of contamination, including insect and animal pests.
  • Provides, if necessary, suitable temperature conditions for the handling and storage of fish and seafood.
  • Provide for the orderly and rapid movement of fish and seafood into and out of the establishment.

The construction and packaging materials and non-food chemical products used in the construction and operation of establishments and their equipment must be suitable for their intended use. All non-food chemicals must be clearly labeled, stored in an appropriate location and only used by a person trained to use or apply it in a manner that prevents contamination of fish or contact surfaces.

The enclosed establishment must meet the following construction and equipment requirements:

  • Floors: Must be constructed of smooth, impervious, non-absorbent and non-toxic materials, be sloped for drainage and maintained in a sound condition for ease of cleaning and disinfection.
  • Drains: Must allow effluent and water to pass though quickly without accumulation, be covered with non-corrodible covers or grates constructed in a manner that prevents the entry of pests (insects and animals).
  • Walls and ceilings: of processing and package storage areas must be constructed of smooth, non-absorbent, non-toxic washable materials and have sealed joints. They must be maintained in a sound condition for ease of cleaning and sanitation.
    Note: walls and ceilings in a dedicated tank room are exempt from these requirements.
  • Overhead fixtures: Must not be a source of contamination.
  • Tables and other surfaces which come in contact with the fish or seafood: Must be made of an approved material, resistant to corrosion, smooth and easily cleaned.
  • Facilities: Must have tightfitting doors and windows and be constructed so as to prevent the entrance of rodents.
  • Windows that are capable of being opened, and any other openings to the outside: Must be constructed so as to prevent the accumulation of dirt and be fitted with non-corrodible insect-proof and animal-proof screens or other similar devices.
  • Condensation, in rooms other than live tank rooms: Must be controlled to prevent contamination of walls, equipment and products from ceilings and overhead fixtures.
  • Toilet facilities: Must be available in the establishment adjacent to the fish or seafood handling area in the establishment, maintained in good operating order and be properly equipped with toilet tissue.
  • Hand-washing facilities: Must be located adjacent to the toilet facilities, and must be equipped with hot and cold running water, soap and single-service towels.
  • Water: an adequate supply of fresh water and/or sea water from an acceptable source must be available for employee hygiene and establishment clean-up.
  • Water used for unloading, washing, storing or transporting fresh fish: Must be from an acceptable source.
  • Ice: Must be made with acceptable water, handled and transported, both inside and outside the establishment, in a manner that prevents its contamination.
  • Offal Receptacles: Must be clearly identified as "For Offal Only", and be constructed of an approved material.
  • Lighting: Adequate lighting must be available in the processing areas. Lighting fixtures must have covers to prevent breakage and be designed to be easily cleaned and disinfected to prevent contamination of work surfaces and products.
  • Coolers must maintain fish and seafood at a temperature from 4°C to -1°C.

The construction and equipment requirements are applicable to all new licensed establishments (excluding LLCP holders).

Note: for existing facilities that only hold live fish (e.g. lobster and crab).

  • Wood floors, open wall studding and wood tables will be tolerated provided they are in good repair and can be kept clean.
  • Toilets do not have to be in the establishment but must be readily available.
  • Hand wash facilities must be available (hot water and pressurized water is recommended), maintained in good operating order, and properly equipped with single service towels.

Even though these conditions will be tolerated for existing live fish facilities, as equipment is replaced or facility repairs and renovations are made, compliant materials and construction must be used to bring the establishment into compliance with the FIR.

5.6.3 Sanitation and Personnel Hygiene

Establishments must develop and implement a sanitation and hygiene program to ensure that the employees of the establishment or the users of the conveyance or equipment use proper sanitation and hygiene practices, and that the establishment, grounds, equipment or conveyances are maintained in a clean and sanitary condition and free from serious contamination and insect and animal pests.

Cleaning/disinfecting equipment and supplies must be available to ensure that the sanitation program can be carried out as written. Chemical products for use in cleaning and disinfecting must not be allowed to contaminate the live animals or food products.

No person who is a known carrier of a disease that is likely to be transmitted through food or who is afflicted with an infected wound, skin infection, sore, diarrhea or any communicable disease, can work in the handling areas if there is a possibility of contaminating fish with pathogenic organisms.

The sanitation and hygiene program must describe:

  • The person(s) or positions responsible for the program.
  • The frequencies of cleaning and sanitizing.
  • The disassembly/reassembly of equipment required for cleaning, disinfecting, lubrication, if applicable.
  • The procedures for cleaning, disinfecting, and rinsing.
  • The lubricants used if applicable.
  • The cleaning/disinfecting equipment and chemicals used (must be suitable for their intended use).
  • The instructions for the use and application of cleaning/disinfecting chemicals (concentrations, temperature of use, duration of application in accordance with the manufacturer's instructions).
5.6.4 Pest Control

The establishment must be free of pests:

  • The grounds in proximity to the establishment must be kept clean, free from debris and unnecessary material and be maintained to minimize harborages for insect and animal pests.
  • It is recommended that the surrounding area be surfaced and adequately sloped to prevent accumulated pools of water.
  • Areas where fish is loaded, unloaded or handled and other high traffic areas should be paved with asphalt, covered with concrete or other impervious material and equipped with appropriate drains.
  • The establishment and the immediate vicinity must be monitored for the presence of pests, including insects and rodents. The monitoring procedures and persons responsible to monitor for pest activity must be documented.
  • Pesticides or any other animal control products must be applied in a manner that prevents the contamination of the consignment.
  • Pest control procedures must be implemented when pests are detected.
  • Where a pest management program is contracted to a third party, documentation provided by the pest control company as to the activities conducted and types of pest control used including a map of rodent traps, bait stations, and other control devices, must be maintained.
  • Documentation related to the approval and application of insecticides must be maintained.
5.6.5 Hazard Analysis

A hazard analysis of each process step, from the time the fish or seafood is caught or received to the time it is transported for export must be conducted. A Hazard Analysis Worksheet, or equivalent, must be used to document the hazard analysis.

All potential hazards (biological, chemical, physical) which may be present or introduced must be identified for each step and the significance of the hazard determined (i.e. consideration of its severity, the likelihood of its occurrence or increase to an unacceptable level). Justification must be provided when a hazard is identified but determined to not be significant.

Where a hazard has been identified to be of significance, a Hazard Analysis Critical Control Plan (HACCP) must be developed and documented identifying each hazard determined to be of significance and the process step where it was identified as a Critical Control Point (CCP). For each CCP:

  • Preventive measures must be implemented to prevent or eliminate the hazard or reduce it to an acceptable level.
  • Critical limits must be established (i.e. the maximum or minimum value to which a hazard must be controlled). The critical limits must be validated to demonstrate that they are effective and the validation documented.
  • Monitoring procedures must be implemented to verify the application and effectiveness of preventative measures.

Verification procedures such as the review of records or additional testing must be established to verify the implementation of the HACCP plan.

Records of the CCP monitoring activities, corrective actions and verifications completed must be maintained. These records must be initialed or signed and dated by the person responsible for them.

Corrective Action Requirements

Corrective action procedures must be established to address deviations, from the critical limits, identified during the monitoring of a CCP. The corrective actions must identify and correct the deficiency that resulted in the deviation, identify and segregate any product affected and prevent or reduce the likelihood that the deficiency will reoccur.

5.7 Consignment Storage and Transportation

This element is covered in the QMP plans for registered establishments.

Intent

Consignments must be protected from contamination and their quality and safety preserved during storage and transportation.

Consignments must be stored and transported under secure conditions to prevent product loss or substitution.

Requirements

Consignments must be stored and transported under conditions that comply with the Fish Inspection Regulations.

The walls, floors and ceilings of storage and transport facilities, where appropriate, must be of a suitable corrosion-resistant material with smooth non-absorbent surfaces that can be adequately drained and cleaned.

Consignments must be protected from contamination, exposure to extreme temperatures, the sun and wind.

Live fish are to be stored and transported at temperatures appropriate for the species.

Fresh fish and seafood must be maintained chilled at a temperature at or below 4°C.

Frozen fish must be kept frozen to at least -18 °C and protected to ensure that the temperature of the fish does not increase by more than 5.5°C during loading, transport and unloading.

Control Measures

The ECCP plan must describe the process and the person responsible for ensuring the integrity, quality and safety of the fish or seafood is maintained during loading, storage and transportation.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occurring.

5.8 Verification & Maintenance of the ECCP Plan

Intent

The ECCP plan must be maintained up-to-date and be effective in ensuring the compliance of the fish or seafood exported and the export certificates issued.

Requirement

The ECCP plan must be verified to ensure the controls are up-to-date, comply with the requirements and are effective in ensuring the integrity of the certification of fish or seafood.

5.8.1 Ongoing Maintenance

The plan must be updated when:

  • There is a change to the ECCP reference standard or the export profile (e.g. foreign markets, foreign requirements, export certificates, fish or seafood for export).
  • There is a change in the control measures or monitoring procedures.
5.8.2 Annual Review

All the elements of the ECCP plan must be reviewed annually to verify that the plan continues to comply with the requirements and is effective in ensuring the compliance of the fish or seafood exported and the export certificates issued.

Control Measures

The ECCP plan must describe the process and the person responsible for the ongoing maintenance of the plan.

The ECCP plan must describe the process and person responsible for the annual review of the plan to ensure that it is up-to-date, complies with the requirements and is effective.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address situations where there is a failure to comply with the requirements. The system must include corrective actions taken to get back into compliance with the requirements and to prevent the situation from re-occurring.

5.9 Maintenance of Records and Documents

Intent

Records must be maintained to demonstrate that the ECCP plan is effective, implemented as designed, can identify issues, and is up-to-date.

5.9.1 Records relevant to the ECCP plan
Requirements

Records relevant to the implementation, monitoring and verification of the ECCP plan must be maintained.

Records must be up-to-date, legible, comprehensible, easily accessible, and stored in one location in a manner which protects their integrity.

The record maintained should provide evidence that the ECCP plan is effective, implemented as designed, can identify issues and is up-to-date.

When electronic records are used, specific controls must be developed for the creation and maintenance of electronic signatures that meet the requirements of CFIA's Guidelines for the Use of Electronic Records and Signatures.

Records must be retained for at least three years.

5.9.2 Amendments to the ECCP plan
Requirements

A log of all amendments to the ECCP Plan must be maintained to ensure that documents are up-to-date and accurate.

Note: Amendments to an acceptable ECCP do not have to be submitted to the CFIA prior to implementation.

The amendment log must identify any changes for the last three years.

Control Measures

The ECCP plan must describe the process and person responsible for amending and recording amendments to the plan.

The ECCP plan must identify the address in Canada where all records and documents relevant to the ECCP plan are maintained.

Appendix A: Protocol for Partially Completed Certificates Guidelines

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