As per Safe Food for Canadians Regulations [SFCR], it is the responsibility of the SFC license applicants to develop, implement, and maintain Preventive Controls (PC’s), Preventive Control Plan (PCP), and Traceability Procedure (when applicable to operations and their products), complaints procedures etc. prior to be eligible for obtaining the License. CFIA makes this requirement very clear during the online application process for applicants to declare whether they have a “Written Preventive Control Plan” in place; and only by answering “Yes” to this question, the application can be submitted.
While applicants may not be subjected to inspection immediately after obtaining a license, SFC license holders are still obligated to have certain procedures in place in the event of a document request from CFIA. In some instances, CFIA may seek to review certain documents prior to issuing a SFC License; however, this will often depend on the risk category of food products that the business will handle under that license.
It is important to be aware that it is a violation to provide a false declaration to CFIA during the license application process. CFIA will conduct inspections to verify food license holders’ compliance to Safe Food for Canadians Act (SCFA), the Food and Drugs Act (FDA) and their respective regulations. As such, most times, CFIA inspectors will request documents that are predominantly related to Import Controls/PCP [Section 86 (1) of SFCR], Traceability and Control [Section 90 (1) of SFCR] and Complaints [Section 83 (1) of SFCR]. Failure to provide such documents in a timely manner may result into issuance of a non-compliance notice with deadlines to fix the observed non-compliances or a license suspension. The CFIA inspectors’ decision will be based on the risk involved with the food.
Developing and implementing an efficient PCP and related procedures is a time-consuming process and applicants need to factor that in as they work through licensing process. It involves considerable verification measures both within Canada (for Importers or Manufacturers) and outside of Canada (for foreign manufacturers and exportation destination countries). We recommend that companies undertake development of their food safety program well in advance to avoid stressful inspections and interruption to their business.
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The experts at MCS associates can support your compliance requirements by working with you to review or create your Preventive Control Plan. If you require testing, Canadian Analytical Laboratories provides analysis for food products and raw materials to detect, identify and quantify contaminants.
