A guide for preparing a preventive control plan for domestic food businesses

Disclaimer

On January 15, 2019, the Safe Food for Canadians Act (SFCA) and the Safe Food for Canadians Regulations (SFCR) will come into effect.

Read the full disclaimer
  • Certain requirements for some foods or businesses will not apply on this date. Learn more about timelines.
  • If there are inconsistencies between the information found here and a related regulatory requirement, the requirement is what will apply to businesses. Please let us know if you find any such inconsistency by commenting on the resources.
  • Until January 15, 2019 current information and requirements (that will be replaced by the SFCA and SFCR) continue to apply.

Introduction

This guide is intended for domestic food businesses that are required to have a preventive control plan (PCP) under the Safe Food for Canadians Regulations (SFCR). You can consult the Would you need a preventive control plan? tool to determine if you need a preventive control.

A PCP is a written plan outlining how you ensure that food is safe and fit for consumption and conforms to consumer protection and animal welfare requirements, as applicable. Using preventive controls to prevent, eliminate or reduce to an acceptable (safe) level hazards associated with food products is an internationally accepted approach based on the CODEX Alimentarius General Principles of Food Hygiene CAC/RCP 1-1969 – PDF (179 kb).

Preventive control plans are not a new concept for many food businesses. For example, federal meat and fish processors already have in place food safety systems such as the Food Safety Enhancement Program (FSEP) and the Quality Management Program (QMP). These programs are examples of a PCP.

This document provides guidance for domestic food businesses on how to prepare the food safety and consumer protection components of a PCP. Information on the animal welfare component can be found in the Guidelines for the humane care and handling of food animals during slaughter activities. Businesses that import or export food can refer to the documents A Guide for Preparing a Preventive Control Plan – For Importers and Step by Step Guide to Food Export for guidance on how to prepare their PCP.

It's your choice

You may use other PCP approaches that have been developed by other food safety authorities, industry associations, international partners, or academia. Always ensure that the information in your PCP is tailored for your particular business, foods, and market requirements. You are responsible for ensuring that your written PCP meets the requirements of the SFCR.

A) Developing your preventive control plan

Under section 89(1)(c) of the SFCR, a written PCP includes the following:

  • a hazard analysis that describes the biological, chemical, and physical hazards that are reasonably expected to contaminate your food
  • descriptions of the control measures used to control those hazards, and the evidence showing they are effective
    Note: Please refer to the document Evidence showing a control measure is effective for further information.
  • descriptions of the critical control points (CCPs) in your process, including the related:
  • procedures to verify that the PCP has been implemented as written and is effective at preventing, eliminating or reducing to an acceptable level the hazards in the food
  • evidence that you have implemented your written PCP (for example, service contracts, processing records, and other day to day records)

In addition, the written PCP includes the following:

  • descriptions of the measures you have in place to meet the consumer protection requirements (such as labelling, packaging, grading, standards of identity and net quantity) referred to in section 89(1)(a) and (b) of the SFCR
  • the supporting documents referred to in section 89(1)(e) used to develop your PCP, such as the information you used to determine your hazards, the rationale for identifying your critical control points, and other data

Your written PCP may also need to include additional content related to food for import or export and for post-mortem programs referred to in sections 89(4), (5) and (6) of the SFCR.

Keep in mind!

The Would you need a preventive control plan? tool can help you determine if you need to prepare a written PCP.

The infographics on food hazards and preventive controls provides a basic overview of the key elements of a PCP.

The examples of templates available in the Preventive control plan templates – for domestic food businesses further illustrate what's in a PCP.

The following steps will guide you through the process of developing the food safety and consumer protection aspects of a written PCP for your domestic food operation.

Step 1: Assemble your team

Developing, implementing and maintaining an effective PCP depends on knowledgeable and experienced management and employees working together to identify food safety hazards and how to control them.

Include key people on your team to cover all aspects of your food operation for developing the PCP. Consider using people that:

  • understand the practical aspects of food operations, such as the process flow, and the technology and equipment used in your facility
  • are knowledgeable in the area of food safety, including the microbial, chemical and physical hazards related to the food being prepared

Some ways of enabling your team to develop your PCP are to:

  • provide the team with the necessary resources and time
  • train staff so they are qualified to carry out this work

Step 2: Ensure the establishment is operated and maintained as required

The first task is to make sure that how you operate and maintain your establishment meets the requirements applicable to your operation in sections 50 to 81 of the SFCR.

The requirements covered in sections 50 to 81 are the basic practices a food business must follow to reduce the risk of introducing hazards to the food through the processing environment.

For more information on these requirements, refer to the Regulatory requirements: Preventive controls web page

Step 3: Perform a hazard analysis and establish procedures

The next step is to perform a hazard analysis on your food, determine control measures and document it all by applying the following process.

Step 3.1 Hazard analysis

For each food product, identify and describe any hazards (biological, chemical and physical) that may be reasonably expected to contaminate the food through:

  • the inputs (ingredients and packaging materials),
  • processing steps
  • traffic flows
Keep in mind!

You may choose to use the expertise of a trade or professional association or a consultant to help you analyze potential biological, chemical and physical hazards, and develop your PCP. The references listed at the end of this guide may also be useful.

The Reference Database for Hazard Identification (RDHI) is also available to help you identify potential hazards in food processing.

Step 3.2 Control measures

Identify and describe the control measure(s) that control each hazard in your hazard analysis. Include the following details in the description of your control measures:

  • What: a description of the tasks involved
  • How: details of how the task is carried out
  • When: the frequency of the task
  • Who: the person responsible for carrying out the task
  • Records: it is a good practice to list any forms you use for the day-to-day collection of information used to record the delivery of tasks and controls. More information about records is available in the document Record keeping procedures.

Document the evidence that shows that your control measures are capable of controlling the hazard. More information on how to demonstrate the effectiveness of your control measures can be found in the model system Evidence showing a control measure is effective.

Step 3.3 Critical control points

Determine if there are any critical control points in your process. Critical control points (CCP) are the steps in your process where a control measure is applied and is essential to prevent or eliminate a hazard or reduce it to an acceptable level.

Keep in mind!

If the identification of CCPs is new to you, the Preventive control plan templates – for domestic food businesses contains a series of questions that will guide you through the process.

If you identify any CCPs, describe the critical limits for each of them. Critical limits are the maximum and/or minimum set values that control a hazard at a critical control point.

  • For example, the time and temperature parameters used at a pasteurization or cooking step.

For every CCP, develop and document:

  • monitoring procedures that ensure the critical limits are met
  • corrective action procedures when critical limits are not met

Note: Refer to the documents Determining critical control points, Critical limits, Monitoring procedures, and Corrective actions for additional information.

Step 3.4 Verification

Establish verification procedures to demonstrate that the control measures in your PCP are implemented as written and are effective in preventing food safety hazards, resulting in compliance with the SFCR.

Note: Refer to the document Verification procedures for additional information.

Step 4: Establish measures for consumer protection requirements

Describe the measures you have in place to meet the applicable consumer protection provisions (such as labelling, packaging, grading, standards of identity and net quantity) referred to in sections 89(1)(a) and (b) of the SFCR.

Step 5: Assemble your documents

Compile your:

  • hazard analysis
  • written control measures for your food safety hazards, and the evidence that they are effective
  • CCP documentation, including critical limits, and monitoring and corrective action procedures
  • verification procedures
  • supporting documents that you used to develop your PCP
  • written measures describing how you meet the other requirements (e.g., consumer protection requirements, such as labelling, packaging, grading, standards of identity and net quantity)

You have now developed the food safety and consumer protection components of your written PCP.

B) Implementing your preventive control plan

Once you have developed your written PCP, you need to implement it into your day-to-day operations. This involves:

  • training your staff on the procedures
  • following the PCP as written
  • generating records that show you have implemented your PCP and retaining those records for at least 2 years (3 years for the thermal processing of low-acid food)
  • verifying that your PCP is implemented as written and is effective in preventing food safety hazards, resulting in compliance with the SFCR

Note: The Canadian Food Inspection Agency (CFIA) will verify during inspections that your PCP is complete, implemented and effective.

C) Maintaining your preventive control plan

Once you have developed and implemented your PCP, maintain it by reassessing it at a frequency appropriate to your food business, for example annually, and revising it as necessary.

The PCP also needs to be reassessed and revised when:

  • something is new or has changed
    • For example, with the regulatory requirements, food produced, growing or harvesting procedures, agronomic inputs, ingredients or incoming materials, product formulation, equipment, production flow, processing step or production volumes
  • a problem has been identified
    • For example, a deficiency or deviation observed during in-house monitoring or verification procedures, non-compliance identified by CFIA or third party auditors, customer complaints that reveal a problem with the PCP, food recalls or unsatisfactory laboratory results.

Reassessing your plan includes reviewing records and conducting on-site assessments of all preventive controls.

Keep in mind!

You also need to meet the investigation, notification, complaints, and recall requirements referred to in sections 82 to 85 of the SFCR.

Tell me more! Further reading

The following references contain information that helps explain food safety controls, demonstrates how to develop them, and provides examples. The CFIA is not responsible for the content of documents that are created by other government agencies or international sources.

CFIA references

Other references

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