Monitoring procedures for your preventive control plan
Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements are being phased in over the following 12 to 30 months. For more information, refer to the SFCR timelines.
Establishing monitoring procedures for Critical Control Points is an integral part of preparing an effective preventive control plan (PCP). It is also the fourth principle in the internationally recognized Hazard Analysis Critical Control Point (HACCP) approach to food safety.
The purpose of monitoring CCPs is to ensure that control measures are under control and that deviations from the critical limits are detected in time to regain control of the process and prevent the production of unsafe products.
Monitoring is defined by the Codex Alimentarius as the act of conducting a planned sequence of observations or measurements of control parameters to assess whether a control measure is under control.
The Canadian Food Inspection Agency (CFIA) created this document as guidance to help food business operators comply with the regulations set out in the Safe Food for Canadians Regulations.
You may use other guidance that has been developed by provincial governments, industry associations, international partners or academic bodies as long as they can achieve the same outcome. Always ensure that the guidance you choose is relevant for your particular business, product or products, and market requirements.
What is included
The document outlines:
- the key elements to consider in the development of monitoring procedures
- types of monitoring procedures
Refer to the Tell me more! section for additional sources of information that may help you establish monitoring procedures.
What is not included
The document does not provide information related to monitoring devices/equipment and the associated maintenance and calibration measures that should be considered.
The examples provided are not exhaustive. The monitoring activities will depend on the size and complexity of the food business and be unique for each business.
Roles and responsibilities
Food businesses are responsible for complying with the law. They demonstrate compliance by ensuring that the commodities and processes for which they are responsible meet regulatory requirements. If a written PCP is required, the food business develops a PCP with supporting documents, monitors and maintains evidence of its implementation, and verifies that all control measures are effective.
The CFIA verifies the compliance of a food business by conducting activities that include inspection, and surveillance. When non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.
You establish and document monitoring procedures for each CCP. These procedures specify any tests, measurements or observation used to assess whether:
- critical limits are met
- control measures are functioning as intended
Design your monitoring procedures so that they provide timely information about the acceptability of the product. Knowing sooner that there's a problem often means simpler corrective actions, less affected product and less distributed product to trace back
It is important that you include and identify the forms that will be used to record the results of the monitoring activities. These forms become records that can be used to demonstrate compliance and to verify the effectiveness of your control measures. An example of a record can be found in Appendix 1.
Considerations when writing the procedure
When writing monitoring procedures, you need to describe them in enough detail to ensure that they are carried out correctly and consistently.
Every monitoring procedure should answer the following questions.
- What: Provide a description of the activities you are doing to monitor the critical limits
- the tests performed
- measurements to be taken or observations to be made
- How: Provide a detailed description of how the activities are carried out
- test methods
- instructions on how to conduct the test, measurements or observations
- When: Establish a monitoring frequency that is appropriate to ensure hazards are controlled
- Set a frequency for carrying out the monitoring procedure
- Monitoring can be continuous or intermittent. If monitoring is intermittent, set a frequency that is sufficient to guarantee the CCP is in control
- Who: Identify the job title of the person responsible for conducting the different activities under your monitoring procedures and evaluating the results. Typically, monitoring activities are conducted by those responsible for applying the control measures
- Records: List the records used to document the results of your monitoring activities
Frequency of monitoring activities
Set a frequency that is:
- precise and measurable (for example, "as required" is not an appropriate frequency)
- time-based such as hourly, daily, or production-based such as each lot, each load, each shipment
- sufficient to ensure that the critical limits have been met for all products manufactured.
You may need to adjust the frequency of monitoring if something happens or changes. For example, you might increase the frequency of monitoring after a change in a critical limit, a change in the process, a deviation, or new validation data.
Monitoring activities at a CCP
Some types of monitoring activities at a CCP may include:
- physical measurements:
- belt speed
- chemical measurements:
- water activity
- microbiological testing:
- microbiological analysis of critical raw materials before their use in processing (for example, analytical results in dried milk used in chocolate products, or in starch used in canned foods)
- microbiological analysis of critical finished products before their release to highly sensitive consumers (for example, infant formulas)
You need to consider the time required to obtain results when deciding what monitoring procedures should be used in a CCP. Rapid tests are preferable for monitoring procedures taking place on dynamic processing lines.
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.
- Corrective actions
- Determining critical control points and their critical limits
- Step-by-step guide for domestic food businesses: Preparing a preventive control plan
- Codex Alimentarius Commission, Recommended International Code of Practice, General Principles of Food Hygiene - Annex: Hazard analysis and critical control point (HACCP) system and guidelines for its application, 2003
- International Commission on Microbiological Specifications for Foods (ICMSF). Microorganisms in Foods 4: Application of the Hazard Analysis Critical Control Point (HACCP) System to Ensure Microbiological Safety and Quality, Oxford: Blackwell Scientific Publications, 1988
Example of a CCP monitoring log
CCP # 1P - Metal detector checks – 7:00 am – 7:00 am
Date: January 15, 2022 Line: # 3 Day operator: ABC Night operator: XYZ
|Time||Stainless steel||Ferrous||Non ferrous||Alarm test||Initials||Actions / Comments|
|Time||SKU||Initials||Was metal found?
Yes or No
|4:40 am||3675487||XYZ||Yes||Small piece of shiny metal found within the package. Production supervisor immediately notified.
Package marked with an X, labelled with date and time, and then sent to internal lab for further investigation.
Supervisor verification signature Date: Time:
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