Facilities Inspection Manual
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Bulletin 19 - Inspection and Certification of Fish Landed by Vessels of Canadian and Foreign Origin
To: All Holders of the Facilities Inspection Manual
Subject: Inspection and Certification of Fish Landed by Vessels of Canadian and Foreign Origin
Note: This bulletin supersedes and replaces Bulletin nos. 4 and 14. Please remove these Bulletins from your manual.
This bulletin is intended to guide inspectors in the inspection, product certification and use of the "Product of Canada" designation for fish landed in Canada by Canadian and foreign vessels.
1.1 All Canadian vessels used for fishing or for transporting fresh round or dressed unfrozen, frozen, salted or pickled fish intended for further processing at Canadian federally registered processing establishments and/or for export shall meet the requirements of Schedule III of the Fish Inspection Regulations (FIR).
1.2 Fishing vessels shall be inspected in accordance with the frequencies prescribed in the local workplan to ascertain compliance with the FIR.
1.3 In accordance with section 14(1.1) of the FIR, all shellfish and crustaceans, excluding live lobster and live crab, landed by fishers must be processed in Canadian federally registered processing establishments if destined for export. Federally registered establishments may include enclosed processing facilities onboard Canadian-flagged freezer-factory ships or shore-based processing facilities.
2. Landings of Live or Fresh Fish Meeting Requirements of Schedule III only
The following criteria apply to fresh round or dressed unfrozen fish, live shellfish and crustaceans, including landings of shucked scallops:
2.1 Canadian Vessels
Landings by a Canadian fishing vessel are:
- subject to inspection, may be exported directly, or may be destined for further processing in federally registered fish-processing establishments in accordance with Section 14 of the FIR;
- eligible for "Product of Canada" designation; and
- eligible for product certification.
2.2 Foreign Vessels
- Foreign vessels importing, processing or otherwise handling live molluscan shellfish must comply with the provisions of the National Shellfish Shippers Program and must appear on the approved list of establishments contained in the Interstate Certified Shellfish Shippers List (ICSSL).
- Landings by foreign vessels intended for further processing at registered fish-processing establishments or for direct sale to consumers are to be considered imports.
- Fish inspectors shall deal with these imports in accordance with FIR import requirements and charge appropriate fees.
- To be eligible for certification and designation as "Product of Canada", or "Made in Canada from imported ingredients" / "Made in Canada from domestic and imported ingredients", the lots of fish landed by foreign vessels must have undergone substantial transformation during processing in federally registered fish- processing establishments.
- Compliance and certification of lots for export is to be in accordance with QMP procedures.
3. Landings of Frozen Whole, Dressed or Headed and Gutted Fish or Salted or Pickled Fish
The following criteria apply to the harvesting of fish, other than shellfish or crustaceans, which is frozen-at-sea in a whole or dressed form, or is salted or pickled:
3.1 Canadian Vessels
- all landings requiring certification must be delivered to Canadian federally registered fish-processing establishments, and all fish must be treated as "Incoming Fish" under the establishment's QMP;
- compliance and certification of these lots of fish is to be evaluated in accordance with QMP procedures; and
- all fish is eligible for a "Product of Canada" designation.
3.2 Foreign Vessels
Foreign vessel landings of sea-frozen fish, salted fish or pickled fish shall be dealt in accordance with section 2.2 of this Bulletin.
4. Fish Including Cooked and Frozen Shrimp and Other Crustaceans or Shellfish Harvested and Processed by Canadian Registered Freezer-Factory Vessels
4.1 Canadian Vessels
The following criteria apply to processing on-board Canadian freezer-factory vessels, including all freezer-factory vessels which process raw material to final product form, without recourse to further processing in shore-based establishments:
- the vessel must be registered as per Section 15 of the FIR, have a QMP and pay applicable fees;
- certification of lots will only be considered when the lots are made readily available to the inspector and where suitable inspection facilities exist;
- owners and operators or captains of processing vessels shall permit CFIA to station designated fish inspectors onboard for such periods of time to adequately and properly conduct at-sea inspections of factory processes and products, and shall provide suitable officer level food and accommodations, unrestricted radio room access, and when reasonable, facilitate mid-sea transfers of Inspection personnel to inbound or outgoing vessels;
- certification of lots is to be conducted in accordance with QMP procedures, or upon a lot-by-lot inspection performed by a fish inspector, and where the fish is found to meet the requirements of the FIR; and
- all landings are eligible for a "Product of Canada" designation.
4.2 Foreign Vessels
4.2.1 Foreign vessel landings of fish including cooked, sea-frozen shrimp and other crustaceans or shellfish shall be dealt with in accordance with section 2.2 of this Bulletin.
4.2.2 Notwithstanding section 4.2.1 above, CFIA may register foreign factory-freezer vessels as Canadian fish processing establishments provided that they meet all requirements of section 4.1 of this Bulletin.
Fish, Seafood and Production Division
Bulletin 24 - Changes to Compliance Verification Policy
To: All Holders of the Facilities Inspection Manual
Subject: Changes to Compliance Verification Policy
This Bulletin supersedes and replaces Bulletin numbers 21 and 23. Please remove these Bulletins from your manual.
This Bulletin is intended to guide inspectors and managers in the scheduling and planning of compliance verifications. The Compliance Verification Policy is adjusted, as indicated within this bulletin, to increase the frequency of CFIA contact with industry, to emphasise the significance of the QMP Reference Standard, and to support improved planning and delivery of the CFIA's Quality Management Program.
The following policy directives are in effect:
The compliance verification (CV) is the primary tool for verification of regulatory compliance at federally registered establishments. The CV assesses the QMP Plan implementation and effectiveness against the requirements set out in the QMP Reference Standard, and by association, the Fish Inspection Regulations.
Compliance verifications are conducted during an establishment's operating season according to the following schedule:
Newly Registered Establishments
For an establishment with a new certificate of registration, a CV should be scheduled directly following the issuance of the registration certificate. For new registrations, the scope of a CV should address all seven elements of the QMP Reference Standard.
Previously Registered Establishments
For an establishment with a pre-existing certificate of registration, the scope of a CV normally will address less than seven elements of the QMP Reference Standard. Exceptions to this may include a CV conducted at an establishment in a remote location or with a very short operating season, a CV conducted in response to a food safety emergency, and/or when a wide-scale loss of QMP controls is suspect.
QMP with a HACCP Plan
For establishments with a HACCP Plan, a CV should be conducted at least once every four months of operation. For establishments operating less than four months per year, a CV should be conducted at least once per year. A 2-year planning cycle should be used and during this period all seven elements of the QMP Reference Standard must be verified at least once.
QMP without a HACCP Plan
For establishments without a HACCP Plan, a CV should be conducted at least once every six months of operation. For establishments operating less than six months per year, a CV should be conducted at least once per year. A 3-year planning cycle should be used and during this period all seven elements of the QMP Reference Standard must be verified at least once.
The CV team will develop the CV scope in consideration of all of the following objectives:
- to assess each of the seven elements of the QMP Reference Standard at least once over the appropriate two- or three-year cycles;
- to assess health and safety controls with priority;
- to verify the implementation and effectiveness of corrective action plans developed during previous compliance verifications;
- to assess an area of a suspect non-compliance based on establishment history or an emerging issue.
To assist the CV team in developing the scope of the CV, the Inspection Manager (or designate) should establish a target for total direct time to conduct a CV. The CV team should allocate approximately 30% of direct time to planning and preparation, 60% to execution, and 10% to meetings with industry and CAP assessment.
Closing the CV
The CV is closed when the corrective action plan (CAP) has been accepted by the CV team. The development and submission of an acceptable CAP should be a priority for the registered establishment personnel.
Normally, CFIA personnel will verify the implementation and effectiveness of the CAP at a subsequent CV. Objective evidence pertaining to CAP implementation and effectiveness can be gathered at any time following the acceptance of the CAP. However, if health, safety or product compliance is at issue, the CFIA personnel should schedule the CAP to be verified promptly after implementation. The objective evidence collected is applied to a subsequent CV.
Advance planning for CV scheduling, CV team assignments, and the development of a CV checklist is advantageous and appropriate.
- It is not necessary to perform a compliance verification over a continuous period of time; the CV may be planned to be performed in stages and in many cases this is recommended. For example, this would apply in the case of establishments which operate for pulse fisheries, with short operating seasons, or for those whose export certification requests require CFIA contact. For such cases and where possible, the CV scope and checklist should be prepared well in advance so that inspection personnel are ready to conduct CV activities whenever an opportunity arises.
- Efforts should be made to consolidate regulatory verification activities whenever possible. For example, CVs for establishments which require ICSSL certification inspections should be scheduled to be conducted within 120 days of the ICSSL expiry date. This would enable the CV results to be applied to the ICSSL facility inspection requirements.
The size of the CV team may be related to the plant size and/or complexity of the QMP Plan. In general, better results may be obtained using a team size of two persons. However, a 1-person execution of the on-site component of the audit, is acceptable when a 2nd team member (such as a supervisor) participates through deliberations and /or discussion during the planning, execution and CAP assessment phases. As in larger teams, one member of the team should be a "team leader". Rotation of inspection staff auditing individual establishments is encouraged
Fish, Seafood and Production Division
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