Canadian food businesses that import, export, manufacture and store food are subject to the Safe Food for Canadians Act (SFCA) and Regulations (SFCR).
In order to obtain a Safe Food for Canadians importing license, the importer must have the following documented and implemented programs:
- Traceability
- Recall
- Customer Complaints
- Preventive Control Plan
Traceability programs are documented instructions to ensure the importer’s ability to track the movement of a food or a food commodity.
Traceability documents must:
- Identify the food with the Common Name, Name and address of the company, and a lot code to trace the food.
- Trace the food one step back to the person that provided you with the food, including the date on which the food was provided to you.
- Trace the food one step forward to the person you provided the food to, including the date on which you provided the food.
Recall programs are written procedures designed to be able to mitigate any risk to public health through the effective removal of the food from further sale at any point in the supply chain.
Typical recall reasons are:
- Incorrect labelling (undeclared allergens)
- Bacterial contamination (e.g. Listeria)
- Chemical contamination (e.g. Arsenic)
A documented recall program is required in order to have a SFC licence.
Customer complaint programs are also required. These are written procedures to ensure that all customer complaints are received, tracked, investigated, and resolved in a timely manner.
This will often include:
- An investigation into the complaint.
- A risk assessment.
- A root cause analysis – what caused this issue?
- Preventive actions to prevent the recurrence of the issue.
Customer complaint programs will also track food safety and quality issues to determine if there are any trends. If the investigation determines that the affected product presents a risk of injury to human health, a recall may be required, and CFIA must be notified.
An Import Preventive Control Plan (IPCP) is a written set of procedures to ensure that the food that is being imported meets all of the requirements of the Safe Foods for Canadians Act and Regulations.
This includes:
- Assessing foreign suppliers and their facilities.
- Assessing each food product to determine inherent hazards that type of product may have.
- Ensuring that there are control measures implemented for each hazard identified, and monitoring them.
- Verifying that the control measures are effective, and reassessing the IPCP as needed.
- Ensuring that the products being imported meet Canadian ingredient and labelling regulations.
Customer complaint programs will also track food safety and quality issues to determine if there are any trends. If the investigation determines that the affected product presents a risk of injury to human health, a recall may be required, and CFIA must be notified.
Each foreign supplier must be assessed to ensure that they meet the relevant requirements in the regulations.
Assessment takes place before the import of food and covers criteria such as:
- The interior and exterior of the building, equipment, sanitation and pest control.
- Chemicals, water, steam & ice.
- Employee practices, hygiene, housekeeping, and good manufacturing practices.
- Processes and procedures to ensure safe food.
These assessments are determined by risk; locations that have certification to a Global Food Safety Initiative (GFSI) benchmarked audit standard will typically meet all of these requirements and not require further assessment. Locations without GFSI certification may require 3rd party audits and/or customer audits.
