UPDATE: It was just announced that the Safe Food for Canadians Regulations will come into force on January 15, 2019. Are you up-to-date on the new Canadian Food Safety regulations? Implementation timetables for food manufacturers (including alcoholic beverages) and food importers can be found here.
Some businesses listed under “All Other Foods” (this category may include confectionary, snack foods, beverages, oils, dried herbs and spices, nuts and seeds, coffee and tea, processed grain-based foods such as baked goods, cereals and pasta) that earn over $100,000 in sales and/or have 4 employees on payroll will need to comply with specific SFCR requirements. Details can be accessed at this link: http://www.inspection.gc.ca/food/timelines/all-other-foods/eng/1527610633553/1527610633758.
One of the SFCR requirements is for certain food businesses including exporters and importers to develop a PCP. A PCP is a written document that demonstrates how food safety hazards are identified and controlled. Under the Canadian regulations, the PCP must include elements relating to packaging, labelling, grading, and standards of identity. In an effort to streamline the process, Sirocco Consulting team in Kelowna, BC, Canada has compiled a guide to develop your Preventive Control Plan.
Steps to developing a Preventive Control Plan
Step 1: Assemble your team
In keeping with HACCP, a cross-functional team is a favourable way to develop, implement and maintain the Preventive Control Plan (PCP). Team members must have knowledge and experience to identify food safety risks and decide how they will be controlled.
Step 2: Ensure you meet preventive control requirements
The PCP team must ensure that the processing environment is conducive to food safety. Food companies will need to refer to preventive controls covered in sections 48 to 78 of the SFCR to get familiar and compliant with fundamental food safety practices.
Step 3: Perform a hazard analysis and establish control procedures
Once food safety risks inherent to the facility are under control, the next step for the team is to perform a hazard analysis on the company’s food product(s) to determine and document control measures. There is a multi-step approach to this PCP activity.
Step 3.1: Conduct a hazard analysis
For each food product, list and describe all biological, chemical and physical hazards that are likely to affect the safety of the food. Ensure all inputs (ingredients, packaging materials, processing aids), processing steps, and traffic flows are assessed. The Reference Database for Hazard Identification (RDHI) is available to guide the hazard analysis.
Step 3.2: Establish control measures
Determine and describe the control measure(s) that are best suited to manage each hazard identified in the hazard analysis. Use a Standard Operating Procedure (SOP) format to describe the control steps and identify what is to be controlled, by whom, at what frequency and following what instructions.
For all hazards, justification that control measures are capable of controlling the hazards effectively must be documented. This process is called validation and is aligned with the CODEX Alimentarius Guidelines for the Validation of Food Safety Control Measures CAC/GL 69-2008.
Step 3.3: Critical control points
Once preventive controls are identified and controlled, the food safety team must tackle the critical control points in the food process. Critical control points (CCP) are defined by “the points in your process where a control measure is applied and is essential to prevent or eliminate the identified food safety hazard(s).”
For each CCP identified, if any, critical limits or “maximum or minimum set values that control a hazard at a critical control point” must be established and documented. For each CCP, the team will develop and implement monitoring procedures that ensure the critical limits are met, and corrective action procedures are documented when these limits are not reached.
Step 3.4: Verification of the PCP
Verification procedures are designed to demonstrate that the PCP and documented control measures are effective in ensuring food safety.
Step 4: Market fairness requirements
Document the measures the team has put in place to meet the market fairness requirements identified in section 87(1)(a) and (b) of the proposed SFCR and in sections 87(3) and (4). These requirements pertain to labeling, standards of identity and export, among others.
Step 5: Assemble your documents
A) The team then assembles the PCP:
- Hazard analysis
- Control measure SOPs, proven to be effective at controlling hazards likely to contaminate the food
- CCP documentation, including critical limits, and monitoring and corrective action procedures
- Verification procedures and supporting documents used to develop the PCP
- Market fairness requirements
B) Once the plan is established, validated and verified, the team must start the implementation phase which includes.
- Training of employees including supervisory personnel
- Ensuring that the training is effective and the plan is followed
- Maintaining records to show compliance to requirements
- Verifying the PCP
- Preparing for a CFIA inspection
C) The PCP must be reviewed at regular intervals. The Plan needs to be reassessed (through record reviews, inspections or audits) and updated when:
- Changes to product, manufacturing process or traffic flows impact food safety risks
- A food safety incident has occurred (customer complaints, audit or inspection deficiencies).
PCP documents must be maintained in French or English for three years after the product is shipped.
Want to learn more about the Safe Food for Canadians Regulations?
- Access the Handbook for food businesses
- Take the e-course offered by the Canadian Food Processors Institute and obtain your training certificate.
