Honey Establishment Inspection Manual
Chapter 5 - Manufacturing Controls

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5.1 Manufacturing Controls

5.1.1 Product Formulation

5.1.1.1 Label Accuracy

5101 Task

Principle

The establishment ensures that the label information accurately represents the composition of the food.

Assessment Criteria

Procedures are in place to ensure that all labels accurately represent product formulation, composition and claims especially where allergens or ingredients which may cause sensitivities are used.

Allergens include milk, eggs, fish, crustaceans, shell fish, tree nuts, peanuts, soy, wheat, sulphites, sesame seed.

Ingredients which may cause sensitivities include lactose, monosodium glutamate (MSG).

The following are examples of such procedures:

  • New label review.
  • Incoming label review for accuracy and correctness.
  • Formulation changes and substitutions.

Rating Examples

I

  • Omission of allergens in list of ingredients with a known history of producing anaphylactic reaction in sensitive individuals.

II

  • Inadequate or no control of label accuracy and listed ingredients which may cause sensitivities are used in the establishment.

III

  • Use of labels with inaccurate ingredient listings but no listed allergens used in the plant.
  • Inadequate control of label accuracy (e.g. no new label review but no listed allergens used in the plant).

Reference

5.1.2 Incoming Material Control

5.1.2.1 Ingredients/Additives, Processing Aids and Bee Treatments

5301 Task ***REVISED JUNE 2009***

Principle

The establishment controls incoming honey, other ingredients, food additives, processing aids and bee treatments such that no biological, chemical or physical hazards result in the food.

Assessment Criteria

The establishment controls incoming honey, other ingredients, food additives, processing aids and bee treatments through a program consisting of:

  • Written specifications for incoming honey and containers in which it is packed, other ingredients, food additives, processing aids and bee treatments.
  • Specifications include a provision for compliance with the Food and Drugs Act and Regulations and Honey Regulations.
  • The requirement for a letter of guarantee from the supplier.
  • Monitoring and testing to verify adherence to specifications.

Honey (Producer-Graders)

Establishments extracting honey must ensure that:

  • Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).
  • Treatments used are in accordance with Canadian requirements.

Honey (Packers or Pasteurizers)

Establishments packing and/or pasteurizing honey must ensure that:

  • Written procedures are in place to ensure incoming honey and containers in which it is packed do not pose any biological, chemical or physical hazards; and meets compositional standards of honey.
  • A system is in place to inform suppliers of specifications/requirements for incoming honey, including the use of food grade liners when the drum history and/or interior coating type are not known to be suitable.
  • A mechanism is in place to communicate and follow up on non-compliant issues.

Rating Examples

I

  • Use of adulterated/contaminated honey, incoming ingredients, food additives or processing aids.
  • Medications used for treating bees are not in accordance with Canadian requirements.

II

  • Incoming honey is received and accepted in drums without a food grade plastic liner or food grade coating.
  • Acceptance of contaminated incoming honey, other ingredients, food additives or processing aids.
  • No letter of guarantee from suppliers for honey, other ingredients, food additives and processing aids to indicate regulatory compliance.
  • The establishment has specifications for incoming honey but does not do any verification or monitoring to demonstrate adherence.
  • No program or documentation to verify adherence to specifications for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).

III

  • No specifications for non-critical ingredients (e.g. mustard, flavours).

References

5.1.2.2 Empty Containers (Bulk and Retail)

5302 Task ***REVISED JUNE 2009***

Principle

The establishment controls empty containers and all other packaging materials (bulk/retail) such that no biological, chemical or physical hazards result in the food and to ensure compliance with Division 23 of the Food and Drug Regulations and the Honey Regulations.

Assessment Criteria

All food contact surfaces must be food grade and suitable for its application.

Suppliers of packaging materials should have their products listed in the "Reference Listing of Accepted Construction, Packaging Materials and Non-Food Chemical Agents" published by the CFIA or have a "Letter of No Objection" from Health Canada.

Documentation (e.g. purchasing specifications) is available to show that the purchased packaging materials comply with the Food and Drug Regulations and Honey Regulations (including standardized container size for honey sold in Canada).

All packaging material is adequately protected from contamination and damage upon arrival.

Packaging materials are evaluated at a set frequency to ensure that correct material is received and free from defects.

Containers to pack honey must be clean, sanitary, in sound condition and have a tightly fitting lid.

Prepackaged

  • Every container for prepackaged honey must be new.

Bulk Containers

  • The establishment has a written bulk container program that is effectively implemented with maintained records (see "A Guide to Developing a Bulk Container Program").
  • All bulk containers (e.g. drums/totes) are free from severe dents or buckling that break the inner coating, and are free from obvious signs of internal rusting.
  • All metal drums are either coated with a food grade coating, or lined with a food grade plastic liner, suitable for honey storage.
  • The exterior coating is non-toxic and durable (e.g. no excessive peeling which could contaminate the honey).
  • All plastic liners are new, food grade and have a letter of compliance from the supplier.
  • Gaskets and plastic seals are food grade and new, or a plastic liner is used.

New or Reconditioned Metal Drums (first time use after reconditioning)

  • A letter of compliance from the drum re-conditioner or supplier is available.

Used Metal Drums

  • Food grade liners are used when the historical use of the drums and/or the interior coating are not known.
  • They must be in good repair as indicated above.

Plastic Drums/Totes

  • New plastic drums and tote bladders should be used, and have a letter of compliance from the supplier.
  • Used plastic drums or tote bladders may be used if traceability is available and have been used only for honey storage and do not contaminate or impart any odours/flavours to the honey.

Rating Examples

I

  • N/A

II

  • Packaging material/empty bulk containers do not comply with Division 23 of the Food and Drug Regulations.
  • Plastic liners are not food grade.
  • Containers (e.g. metal drums) are not free from severe dents and buckling or obvious signs of internal rusting.

III

  • Containers or plastic liners are known to be food grade from a known supplier but no documentation is available.
  • Exterior coating has cracked peeling paint which may come in contact with honey.
  • Old labels are not removed.
  • The establishment does not have a written Bulk Container Program.

References

5.1.3 In-Process Package Control

5.1.3.1 Empty Container Handling (Bulk and Retail)

5401 Task ***REVISED JUNE 2009***

Principle

Empty container handling is controlled to minimize damage and to prevent the use of damaged, defective or contaminated containers.

Assessment Criteria

Containers are handled, transferred and cleaned (when necessary) in a manner that minimizes damage and contamination.

The establishment has an effective cleaning system in place.

The establishment has an effective system in place to prevent the use of damaged, defective or contaminated containers.

This can be accomplished by ensuring that:

  • Empty containers are visually or electronically examined to identify, remove and segregate non-compliant containers prior to use.
  • If applicable, there is a back-up system in place in case the electronic inspection system fails.
  • The establishment has controls in place to prevent contamination of clean containers. For example:
    • No containers and lids are left on the line at breaks, during clean-up or extended downtime unless adequate measures are in place to prevent contamination.
    • Containers are used only for their intended purposes.
    • Lids fit tightly.

Additional Criteria for Bulk Containers

All bulk containers (e.g. drums/totes) are free from severe dents or buckling that break the inner coating, and free from obvious signs of internal rusting.

  • New or reconditioned drums that are not washed prior to use must be clean.
  • All used drums must be washed before filling even when a food grade liner is used.
  • Washed drums are turned upside down and left to dry on a clean surface.

Rating Examples

I

  • Glass particles detected in open containers or in finished products.
  • Harmful extraneous material (> 2 mm) detected in open containers or in finished products.

II

  • Containers with evidence of contamination being used to pack honey.
  • Food grade liners are not used when drum history and/or coating type are not known.
  • Used metal drums are not washed or improperly washed prior to packaging honey.
  • Deficiencies in the container handling control program which may result in use of seriously damaged containers.
  • Washed ready-to-fill bulk containers are inverted directly on the floor.
  • Containers are not used for their intended purpose.

III

  • No continuous visual monitoring, however, other visual inspection of assessment criteria are satisfactory.

References

5.1.4 Product Preparation and Blending Controls

5.1.4.1 Honey Batching and Blending

5501 Task

Principle

Factors for each specific batch/lot are controlled during blending to ensure specified requirements in the Honey Regulations are met.

Assessment Criteria

The establishment has controls in place to ensure that the composition of the honey in each batch or lot has been accurately evaluated. Areas which require evaluation are:

  • Colour
  • Moisture
  • Absence of Foreign Material
  • Characteristic Flavour
  • Floral Source (if declared)
  • Lot numbers
  • Country of Origin

The establishment has signed verifications of all batch or lot evaluations.

The owner or operator of each registered establishment shall keep and make available to the CFIA at all times, an accurate, up-to-date record of his honey pack that shows:

  • The quantity of honey pooled or purchased and the persons from whom it was received or purchased.

Rating Examples

I

  • N/A

II

  • N/A

III

  • The establishment has no controls and documentation in place for batch or lot blending.
  • Evaluations performed but no signed verification.
  • Incomplete/inaccurate evaluations of each batch.

Reference

5.1.5 Filling Control

5.1.5.1 Filling of Containers

5601 Task

Principle

Controls are in place to prevent damage or contamination of containers, lids and product during the filling process.

Assessment Criteria

The establishment has controls in place to prevent hazards associated with product filling.

The establishment has controls in place to prevent contamination of clean containers and product, for example:

  • Filled containers without lids are not left on the line at breaks, during clean-up or extended downtime unless adequate measures are in place to prevent contamination.

Rating Examples

I

  • N/A

II

  • Filled containers left on the line during breaks, clean-up, downtime where there is a high risk of contamination.
  • The establishment does not have adequate controls in place to prevent hazards associated with product filling (glass).

III

  • Filled containers left on the line at breaks and downtime where there is a low to moderate risk of contamination.
  • The damaged container control or visual monitoring program is absent or deficient such that defective containers may be used.
  • The establishment does not have adequate controls in place to prevent hazards associated with product filling.

Reference

5.1.6 Container Closure Control

5.1.6.1 Container Closure

5701 Task

Principle

Container closure controls are in place to prevent contamination of the food.

Assessment Criteria

The establishment controls the closing equipment to ensure the integrity of the container by:

  • Protecting the cap or lid hopper from contamination.
  • Adjusting closing equipment to avoid damage to containers.
  • Adequate container closure.

Rating Examples

I

  • N/A

II

  • Harmful extraneous material found in capping hopper or capper.

III

  • Capping area not inspected regularly for potential contamination.
  • Inadequate container closure.

Référence

5.1.7 Process Control

5.1.7.1 Control of Filling and Labelling

5801 Task

Principle

The establishment has controls in place to prevent mislabelling and improper filling.

Assessment Criteria

The establishment has controls in place to prevent mislabelling and improper filling of containers.

Typical controls should be:

  • Container size for product to be sold in Canada.
  • Effective separation of products during changeovers with records.
  • At the labeller different product labels are effectively separated and the number of product label types are kept to a minimum.
  • Tops and bottoms of label bundles are visually checked for mixed labels prior to use.
  • Prevention of mixing of individual or bundles of labels during storage (e.g. storage in separate boxes, no loose labels, and ensuring that unused labels are returned to the correct boxes.)
  • Effective weight control system to ensure proper filling at the declared weight.
  • Effective grading system to ensure correct grade evaluations.

Rating Examples

I

  • N/A

II

  • N/A

III

  • Use of incorrect labels or inadequate control of label application.
  • No effective weight verification system in place.
  • No effective grade evaluation system in place.

Reference

Appendix 1 - Incoming Honey and Ingredients Program

The establishment controls incoming honey and ingredients (food additives and processing aids) through a program consisting of:

  • Written specifications for honey, incoming ingredients (food additives and processing aids). Specifications include a provision for compliance with the Food and Drugs Act and Regulations.
  • The requirements for a letter of guarantee from the supplier.
  • Monitoring and testing to verify adherence to specifications.

The establishment that extracts honey must ensure that:

  • Medications used have been approved for use for treating bees.
  • The recommended preparation and dosage level of the medications have been followed.
  • The withdrawal time for the medication has been followed before the honey is harvested.
  • Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).

Reference

Assessment Criteria Check if Complete Comments if incomplete or N/A
What The establishment controls incoming honey and ingredients (food additives and processing aids). checkbox
How 1. Written specifications for honey and incoming ingredients (food additives and processing aids). checkbox
How 2. Specifications are in compliance with the Food and Drugs Act and Regulations (e.g. contaminants and adulterants). checkbox
How 3. A letter of guarantee from the supplier,
Monitoring and testing to verify adherence to specifications.
checkbox
How The establishment that extracts honey must ensure that:

1. Medications used have been approved for use for treating bees.

checkbox
How

2. The recommended preparation and dosage level of the medications have been followed.

checkbox
How

3. The withdrawal time for the medication has been followed before the honey is harvested.

checkbox
How

4. Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control.)

checkbox
Frequency Per shipment or per colony checkbox
Who Establishment contact (Manager, Owner) checkbox

Date: space

Signature: space

Appendix 2 - A Guide to Developing a Bulk Container Program

***Revised June 2009***

Objective

This document is intended to provide guidance on developing a written bulk container program. The program will provide details on how the establishment will control biological, chemical and physical hazards which can be associated with bulk containers (capacity of more than 5 kg).

Regulatory Requirements

  • Honey Regulations:
    • 16(b), 32 - Containers are suitable for use
    • 25(d) - Containers are maintained in clean and sanitary condition
    • 30 - Prescribed container sizes
    • 33 - Boxes are suitable and not defaced by old markings
  • Food and Drug Regulations: Division 23, Section 4 and 7

References

Written Program Components

Objective (why)

State the objectives of your bulk container program.

Example:

Bulk containers used in packing honey are received/unloaded, handled, filled, emptied and stored such that no biological, physical or chemical hazard results in the food and to ensure regulatory compliance:

  • are clean
  • are sanitary
  • are of sound condition, durable and non-toxic
  • have tightly fitting lids
  • are free of severe dents or buckling
  • have no obvious signs of internal rusting
  • all food-contact surfaces are food grade and suitable for the application

Criteria

A written bulk container program explains:

  • Where bulk containers are sourced (e.g. suppliers)
  • Type of bulk containers sourced and their specifications (e.g. suitable for storing honey)
  • How bulk containers will be evaluated to ensure that specifications are met (e.g. that they meet the requirements of the Honey Regulations, Division 23 of the Food and Drug Regulations and the Honey Industry Bulk Container Standard).

For example, bulk containers are:

  • coated with or lined with a food grade coating
  • clean, sanitary and in sound condition
  • have tight fitting lids
  • free from severe dents or buckling
  • free from obvious signs of internal rusting
  • how containers will be cleaned and maintained to prevent contamination and damage
  • if liners are used, where are they sourced and their specifications (e.g. proof that they are food grade)records are available and demonstrate that controls are in place and that the bulk containers meet regulatory requirements.

Procedures/Tasks (what/how)

Describe the type of bulk containers sourced and where.

What documentation will be obtained to show that the bulk containers are made of food grade materials?

  • Explain how empty bulk containers will be received and evaluated to ensure that requirements are met.
  • Explain where empty bulk containers will be stored to minimize contamination.
  • Explain how bulk containers will be cleaned and inspected prior to filling with honey.

Position Responsible (who)

  • State the position/name responsible for the bulk container program.
  • State the position/name responsible for each procedure or task.

Frequency (when/how often)

  • State the frequency each procedure or task will be done (e.g. daily, weekly, monthly).

Records

  • What records will be kept to show that the bulk container program has been implemented and is effective.
  • Records should include bulk container sources, documentation to show that the bulk containers are made of food grade materials, (e.g. letter of compliance from suppliers.)
  • Records to show that bulk containers were evaluated prior to filling and include findings, actions taken to correct an identified problem and to prevent recurrence.

Additional records for bulk container distributors:

  • Records indicating client name and contact information, bulk container description, shipping date, number of bulk containers shipped.

Corrective Action

Indicate what corrective action will be taken when a bulk container does not meet the required specifications.

Verification

Who will verify that all elements of the program are implemented and effective:

  • The procedures are followed.
  • The corrective actions have been implemented.
  • The bulk containers meet the specifications.
  • The bulk container program is effective again.
  • What, how and when will this be done and what records will be kept.
  • Approved by (signature):
  • Print name:
  • Approved date:
  • Revision date:

Checklist to assess the bulk container written program

Name of Establishment and Registration Number:

  Evaluation criteria Check if complete Comments if incomplete
What The establishment has established controls for biological, chemical or physical hazards and complies with regulatory requirements. checkbox
How The establishment has effective written procedures to:

1. Purchase acceptable bulk containers

checkbox
How 2. Evaluate that empty containers meet regulatory requirements at receiving (e.g. free from severe dents, buckling, rust, are sound, clean, sanitary and have tightly fitting lids, food grade as appropriate.) checkbox
How 3. Carry out the cleaning, handling and storage of the bulk containers. checkbox
How 4. Ensure old labels are removed. checkbox
How 5. Inspect bulk containers prior to filling. checkbox
Who An establishment contact (e.g. owner/operator)has been identified to be responsible for the program. A position/person is identified to be responsible for carrying out each procedure. checkbox
Who A position/person is identified to be responsible for carrying out each procedure. checkbox
Frequency Procedures are set at a frequency adequate to address risks. checkbox
Records The establishment has records for:
1. Where bulk containers were sourced.
checkbox
Records 2. Type of bulk containers sourced. checkbox
Records 3. Letter of compliance from drum reconditioner/supplier (for new or reconditioned drums) checkbox
Records 4. Documentation to show plastic liners, gaskets and plastic seals are food grade. checkbox
Records 5. Records to show that the procedure(s) have been completed and followed. checkbox
Records 6. Documentation to show corrective action taken. checkbox
Records 7. Documentation to show that the corrective action was verified and the corrective action taken corrected the problem effectively and will not result in recurrence. checkbox
Records 8. If drums were distributed, records indicating; date shipped, description of the drum(s), product lot code, quantity, client name and contact information. checkbox
Corrective action The establishment has written procedures to determine root cause when deviations have occurred. This includes evaluation of risk to the product. checkbox
Verification A person is identified to verify that all elements of the program are implemented and effective.
What and how will this be done and what records will be kept.
checkbox

Date: space

Name of Inspector: space

Date modified: