Food Safety Enhancement Program Manual
Section 6 - CFIA Verification of FSEP Voluntarily Recognized Establishments

This page is part of the Guidance Document Repository (GDR).

Looking for related documents?
Search for related documents in the Guidance Document Repository

This section describes the necessary information for industry about the CFIA verification of FSEP voluntarily recognized establishments. For establishments registered under the Meat Inspection Regulations, in which a HACCP system in accordance with the FSEP Manual requirements is mandatory, please refer to the Meat Hygiene Manual of Procedure - Chapter 18 (Compliance Verification System).

Note: FSEP voluntarily recognized establishments will continue to be inspected for compliance with requirements defined in applicable Acts and Regulations as per specific commodity inspection programs. The verification of compliance to FSEP requirements described in this section is in addition to the commodity inspection programs.

6.1 Objective

The objective of the verification by the CFIA is to confirm that the establishment's recognized HACCP system:

  • is up-to-date;
  • is designed to effectively control food safety hazards;
  • meets the FSEP requirements;
  • is implemented as described;
  • is supported by Senior Management.

6.2 Frequency of verification

The verification frequency is once every two years and whenever the following situations occur:

  • Submission of new HACCP plans.
  • Follow-up after a food safety recall.
  • When inspection results demonstrate that the establishment does not control the food safety related regulatory requirements.

6.3 Verification scope

The verification scope may include a review of:

  • the Senior management letter of commitment;
  • the HACCP system performance reporting process;
  • the HACCP plan(s);
  • the prerequisite programs;
  • the maintenance and reassessment procedures.

The scope selection will be based on CFIA inspection results and situations that have occurred at the establishment that should have resulted in an update and/or a reassessment of parts of the HACCP system by the establishment.

6.4 Opening meeting

The following information will be given and confirmed during the opening meeting with the establishment representatives:

  • CFIA staff titles and roles;
  • The objective and scope of the verification;
  • The verification schedule and procedures;
  • The date and time for the closing meeting.

6.5 Gathering objective evidence to determine compliance

The CFIA will gather objective evidence to confirm whether or not the HACCP system:

  • is up-to-date;
  • is designed to effectively control food safety hazards;
  • meets the FSEP requirements;
  • is implemented as described;
  • is supported by Senior Management.

The CFIA will gather objective evidence by:

  • reviewing documentation and records;
  • observing conditions at the establishments and procedures being implemented;
  • interviewing/questioning designated employees.

6.6 Communication of results and actions required

Results of the verification are communicated to the establishment through a verification report or a corrective action request (CAR) during the closing meeting.

A verification report will be issued to the operator when the overall compliance level is acceptable even if no minor deficiencies have been noted. The CFIA will follow up on the resolution of any minor deficiencies that are identified on the FSEP Verification Report.

A CAR is issued to an establishment whenever non-compliance is determined by the CFIA. The CAR identifies the non-compliance and requires the establishment to implement corrective measures by:

  • providing an acceptable action plan by a specified date;
  • effectively implementing the corrective and preventative measures as described in the action plan by a specified date.

6.7 Request for review of a CAR

An establishment may request a review of a CAR before the date specified for the submission of an action plan. The establishment must submit its reason for the request in writing, to the Area FSEP Coordinator. A written decision is forwarded back to the establishment.

The operator is required to correct any immediate food safety deficiencies described in the CAR while it is subject to the review process. When a request for review is submitted prior to the date for submission of an acceptable action plan, the operator will not be required to submit an action plan until the review results have been communicated to the operator and CFIA staff.

If the CAR is upheld, the establishment must submit an acceptable action plan and correct the non-compliance noted by the dates specified by the CFIA. If the CAR is overturned, the CAR will be cancelled.

6.8 Acceptable action plan

An acceptable action plan is to be submitted by the establishment to the CFIA on the date specified when the CAR was issued. The entire action plan must be implemented by the establishment by the specified date for completion of corrective measures stated on the CAR.

The following table describes each component of an acceptable action plan as well as the objectives of each component.

Component 1 - Description of the problem

The objective is to accurately describe the problem, which will assist to identify the:

  • Action to be taken on affected or potentially affected product.
  • Immediate measures necessary to restore control of the deviation.
  • Root cause(s).

Establishments must collect information to find out the exact problem. One situation of non-compliance is typically the result of multiple problems or causes.

  • What is the non-compliance?
  • Did the problem affect product?
  • Where is the problem located?
  • How widespread is this problem?
  • When did the problem occur?
  • Who is involved in this problem?
  • Is this the first time the problem occurred?

Written Action Plan

  • Describe the problem as it relates to the non-compliance noted on the CAR.

Component 2 - Person(s) responsible for measures

The objective is to determine the people who have the knowledge, time, authority and competence to correct the non-compliance.

Written Action Plan

  • Identify the name or title of person(s) responsible for the immediate/short term and preventative measures.

Component 3 - Description of Immediate /short term measures

The objectives are to:

  • Control affected product or other thing(s).
  • Take immediate measures to restore control over the deviation so that food products are produced within the legislative requirements.

Written Action Plan

  • Describe the measures taken on affected or potentially affected product.
  • Describe the results of the assessment completed to determine if other products were implicated.
  • Describe the food safety assessment performed or to be performed on the affected or potentially affected product including any disposition of product.
  • Describe the immediate / short term measures taken to restore control over the deviation until permanent/preventative measures are planned and implemented.
  • Describe the procedure to verify the effectiveness of immediate/short term measures taken.
  • List records used to document the actions taken.

Note: Depending on the non-compliance, immediate measures may not be required.

Component 4 - Identification of root cause(s)

The objective is to identify the root cause(s) so establishments can form appropriate and comprehensive corrective measures that will prevent the recurrence of the deviation.

Start with the problem description:

  • Why has the CFIA found the deviation and not the establishment?
  • Identify all potential causes (Environment, Equipment, Personnel, Training, Written Programs, etc.).
  • Some causes have already been corrected by immediate measures.
  • Identify the root cause(s).

Written Action Plan

  • Describe root cause(s).

Component 5 - Description of Preventative measures

The objective is to identify and implement measures to eliminate the root cause(s) and prevent recurrence of the deviation.

Written Action Plan

  • Describe the preventative measures.
  • Establish a date for completion of each planned preventative measures.
  • List records used to document the preventative measures taken.

Component 6 - Description of activities planned to verify the effectiveness of preventative measures

The objective is to provide feedback as to whether or not further adjustment is necessary.

The assessment is the application of temporary procedures, tests or other evaluations to determine the effectiveness of the measures taken to correct the problem.

Examples:

  • On-site assessment of measures taken.
  • Ensuring that staff is adhering to new procedures/instructions by observing and interviewing them.
  • Temporarily increasing sampling.
  • Temporarily increasing monitoring procedures.

If the problem is not resolved:

  • Additional corrective measures are required.

Written Action Plan

  • Describe the activities planned to verify the effectiveness of preventative measures.
  • Establish a date for completion.
  • List records used to document the verification activities.

6.9 Action plan extension

The CFIA may grant an extension to the date for completion of corrective measures (the corrective actions and preventive measures outlined in the operator's action plan) under the following circumstances:

  • Food safety is not compromised;
  • The establishment will not meet the specified date for completion of corrective actions due to reasons beyond its control;
  • The establishment submits a written request for an extension before the specified date for completion of the action plan;
  • The written request includes the reason for the extension request and the proposed new completion date.

The establishment must submit its reasons, in writing, to the CFIA responsible inspector.

Note: All criteria must be met in order to qualify for an extension to the completion date.

6.10 CFIA follow-up

After the date for completion of corrective measures has passed, the CFIA follows up at the establishment to ensure that the corrective measures have been completed as described and are effective. If the corrective measures have been implemented effectively, the CAR is closed. If the corrective measures have not been effectively implemented, the CAR remains open and the CFIA takes the following actions:

  • A Final Notice of Non-Compliance is sent to the establishment's management.
    • The Final Notice of Non-Compliance informs the establishment that a failure to implement effective corrective measures by the date specified in the Notice will result in the loss of HACCP recognition.
  • A follow-up evaluation of corrective measures is conducted after the date specified in the Final Notice of Non-Compliance.
  • If the corrective measures have been implemented effectively, the CAR is closed.
  • If the corrective measures have not been implemented effectively, the establishment will lose HACCP recognition.

6.11 Loss of recognition

Loss of recognition will render the establishment ineligible for FSEP verifications. In this case, the establishment will no longer be eligible to use any labels or advertising associated with HACCP or make claims regarding HACCP recognition.

When an establishment loses recognition, the CFIA Area FSEP Coordinator sends a letter to the establishment's management informing them that the establishment is no longer recognized under FSEP. This letter voids the original recognition letter.

Following loss of recognition, if an establishment wishes to re-apply for recognition, they shall investigate to determine the root cause(s) of the failure of their HACCP system and implement corrective measures. The results of the investigation and the corrective measures taken shall be documented in the new letter requesting recognition by the CFIA.

Date modified: