Honey Establishment Inspection Manual

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Table of Contents

List of Acronyms

AFB
American Foulbrood
AIRS
Automated Import Reference System
AQL
Acceptable Quality Level
CAPA
Canada Agricultural Products Act
CBSA
Canada Border Services Agency
CFIA
Canadian Food Inspection Agency
CFIAA
Canadian Food Inspection Agency Act
CFIAFN
Canadian Food Inspection Agency Fees Notice
CIP
Cleaning in Place
CMS
Client Management System (Informatics system)
CPL(A/R)
Consumer Packaging and Labelling Act and Regulations
FD(A/R)
Food and Drug Act and Regulations
FIRM
Facility for Information Retrieval Management (CCRA Informatics System)
FSEP
Food Safety Enhancement Program
GFLA
Guide to Food Labelling and Advertising
GIP
Good Importing Practices
GMP
Good Manufacturing Practices
HACCP
Hazard Analysis Critical Control Point
HR
Honey Regulations
IMS
Issues Management System (Informatics system)
ICP
Import Control Policy
INCR
Inspector Non-Compliance Report
IPC
Import Primary Contact
IRS
Import Retrieval System
ISC
Import Service Centre
LSD
Laboratory Services Division
MCAP
Multi Commodity Activity Program (Informatics system)
MRL
Maximum Residue Limit
MSDS
Material Safety Data Sheets
OFSR
Office of Food Safety and Recall
PARS
Pre-Arrival Review System
PDP
Principal Display Panel
PDS
Principal Display Surface
PMRA
Pest Management Regulatory Agency
RMS
Resource Management System (Informatics system)

Glossary of Terms

Acid
A substance with a pH of less than 7.0.
Adulterated
According to section B.01.046 of the : food is adulterated if any of the following substances or classes of substances are present therein or have been added thereto:
  1. mineral oil, paraffin wax or petrolatum or any preparation thereof;
  2. coumarin, an extract of tonka beans, the seed of Dipteryx Odorata Willd. or Dipteryx oppositifolia Willd.;
  3. non-nutritive sweetening agents;
  4. cottonseed flour that contains more than four hundred and fifty parts per million of free gossypol;
  5. fatty acids and their salts containing chick-edema factor or other toxic factors;
  6. dihydrosafrole;
  7. isosafrole;
  8. oil of American sassafras from Sassafras albidum (Nutt). Nees;
  9. oil of Brazilian sassafras from Ocolea cymbarum H.B.K.;
  10. oil of camphor sassafrassy from Cinnamomum camphorum Sieb.;
  11. oil of micranthum from Cinnamomum micranthum Hayata;
  12. safrole, or
  13. oil, extract or root of calamus from Acorus calamus L.
  14. nut and nut products that contain more than fifteen parts per billion of aflatoxin;
  15. ethylene thiourea;
  16. chlorinated dibenzo-p-dioxins; or
  17. cinnamyl anthranilate.

In addition to this, Divison 15 of the Food and Drug Regulations
(http://laws.justice.gc.ca/en/F-27/
C.R.C.-c.870/index.html) further explains adulteration and provides maximum residue limits.

Alkali
A substance with a pH of more than 7.0.
American Foulbrood (AFB)
Contagious disease of bee larvae caused by Paenibacillus larvae. The antibiotic Oxytetracycline is used in both prevention and treating honey bee colonies.
Analysis Unit
The amount of a sampling unit taken by the laboratory to perform the analysis.
Antibiotic
A compound produced by a microorganism which interferes with the growth of another organism.
Antiseptic
A chemical substance used to interfere with or inhibit the growth of certain microorganisms.
Apiculture
The science and art of raising honey bees for economic benefit or personal enjoyment.
Bactericide
A chemical substance that will kill certain bacterial cells.
Bacteriostat
An agent that inhibits the growth of bacteria but does not necessarily kill them.
Beeswax
Beeswax is a true wax secreted by glands on the abdomen of worker bees. The wax is produced by the bees at the expense of honey production. It can take 6-8 kilograms of honey to produce 1 kilogram of wax. Beeswax is used in cosmetics, for cold creams, ointments, lotions, lipsticks, candle making and in the bee industry for the replacement of foundation that goes into frames for brood and honey production. It is also used in pharmaceuticals, waterproofing material, polishes, furniture wax, and light lubricants in manufacturing. Beeswax is processed by melting, straining, filtering, centrifuging, bleaching, and solidified in blocks of various sizes for shipping. Beeswax is considered safe for human consumption. (CFIA Animal Health Directive)
Botulism
Botulism is a rare but serious illness caused by a nerve toxin that is produced by the bacterium Clostridium botulinum. The spores of Clostridium botulinum are not harmful themselves, but in the absence of oxygen (anaerobic conditions), they germinate and the resultant bacteria produce a powerful poison. Botulism spores are hardy organisms that are found throughout the environment, particularly in soil. Scientists have found botulism spores in dust, raw vegetables, potato skin, corn syrup, and honey.

There are three main kinds of botulism:

  1. Foodborne botulism - caused by eating foods that contain the botulism toxin.
  2. Wound botulism - caused by toxin produced from a wound infected with Clostridium botulinum.
  3. Infant botulism - caused by consuming the spores of the botulinum bacteria, which then grow in the infant's intestine and release toxin.
    (Canadian Honey Council)

Brix Scale
A unit of measure used by refractometers to measure sugar concentrations in solution. Units are % sugar.
Brood
Immature or developing stages of bees: includes eggs, larvae, and pupae. (Beekeeping in Western Canada)
Carrier
An apparently healthy person who harbors in or on the body, pathogenic organisms, and who may spread those pathogens to susceptible people.
Clean
Free of visible soil or debris.
Cleaning
The physical removal of soil or debris from a surface or contaminated area.
Comb
The wax cellular structure that bees use for restraining their brood or as a storage for pollen and honey. Fine particles of comb in suspension are grade defects and contribute to lack of clarity in filtered style honey. (United States Standards for Grades of Extracted Honey May 23, 1985 - PDF (62 kb))
Comb Honey
Honey stored by bees in cells of freshly built broodless comb, which is sold in sealed whole comb or sections of comb. (Codex Standard 12-1981 Rev. 2 2001)
Compliance
The state of conformity with the law. (Canadian Food Inspection Agency Enforcement and Compliance Policy)
Compliance Action
A regulatory control measure to remove from the market or prevent the marketing of a product known to be in contravention of legislation. The compliance action is always directed at a specific source (e.g. the legally responsible party).
Compliance Sampling
The sampling approach as part of compliance testing is referred to as in-depth sampling and follows Codex Alimentarius specifications. Samples are given top priority with respect to testing and must be verified by prescribed confirmatory techniques prior to lot disposition. The establishment of a chain of custody of the sample is essential if legal proceedings are expected to ensue (CFIA Sampling Plans).
Contaminate
To add foreign and unwanted matter to an object or to the environment.
Contaminated
According to the Honey Regulations contains a chemical, drug, food additive, heavy metal, industrial pollutant, ingredient, medicine, microbe, pesticide, poison, toxin or any other substance not permitted by, or in excess of the limits prescribed under the Canadian Environmental Protection Act, the Food and Drugs Act, and the Pest Control Products Act.
Creamed Honey
As an alternative to liquid honey, techniques have been developed to guide the natural crystallization of honey towards completely crystallized, stable and homogeneous end product, which has a pleasant appearance, creamy consistency and is well received by most consumers. The "creaming" process relies on, and enhances, honey's natural tendency to crystallize. Utilizing this feature creates a product with a very small crystal size (less than 25 microns - 0.025mm), so small that the product appears smooth and silky. The interlocking nature of these crystals gives the product its smooth, thick, spreadable texture. (Value Added Products from Beekeeping by R. Krell, FAO AGRICULTURAL SERVICES BULLETIN No. 124.)
Cross-Contamination
The transfer of microorganisms, foreign material and any other unwanted material from one food to another through a non food surface such as equipment, utensils or human hands
Crystallized Honey
Honey that is granulated or crystallized, irrespective of whether candied, fondant, creamed or spread type. (United States Standards for Grades of Extracted Honey May 23, 1985 - PDF (62 kb))
Crystallization
Crystallization results from the formation of monohydrate glucose crystals, which vary in number, shape, dimension and quality with the honey composition and storage conditions. The lower the water and the higher the glucose content of honey, the faster the crystallization. Temperature is important, since above 25°C and below 5°C, virtually no crystallization occurs. The optimum temperature for fast crystallization is around 14°C. In addition, the presence of solid particles (e.g. pollen grains) and slow stirring will result in quicker crystallization. Usually, slow crystallization produces bigger and more irregular crystals. During crystallization water is released. Consequently, the water content of the liquid phase increases and with it the risk of fermentation. Thus, partially crystallized honey may present preservation problems, which is why controlled and complete crystallization is often induced deliberately. (Value Added Products from Beekeeping by R. Krell,
FAO AGRICULTURAL SERVICES BULLETIN No. 124.
)
Detergent
A chemical cleanser similar to soap but of differing chemical nature.
Diastase
An enzyme commonly found in honey. For further information see Enzymes and Gothe Scale.
Disease
A condition in which bodily health is impaired; sickness, illness.
Disinfect
To remove potentially pathogenic microorganisms from an object or environment.
Drained Honey
Honey which is obtained by draining decapped broodless combs.
Enforcement
The action taken by the Agency, through a prosecution or an administrative monetary penalty, where applicable, to obtain compliance.(Canadian Food Inspection Agency Enforcement and Compliance Policy)
Enforcement Action
Enforcement actions include: Warnings; Directions by Inspectors; Prosecutions; Administrative Monetary Penalties; Removal of Imports from Canada; Restrict or Prohibit the Movement of Products; Seizure and Detention of Products or Things; Issuance of Quarantine Notices; Forfeiture of Seized or Unclaimed Products or Things; Disposal of Products; Issuance of Recall Orders Pursuant to Section 19 of the CFIA Act; Application for Injunctions Pursuant to Section 18 of the CFIA Act, Refusal to Issue or Renew Licences, Registrations or Permits; Suspension, Revocation or Cancellation of Licences, Registrations or Permits.(Canadian Food Inspection Agency Enforcement and Compliance Policy)
Enzymes
Enzymes are protein in nature and catalyze or speed up reactions but do not normally become an integral part of the reaction itself. The major enzymes present in honey are invertase (that converts sucrose into glucose and fructose), amylase (diastase - hydrolyses starch to dextrins and/or sugars) and glucose oxidase (that produces gluconic acid and hydrogen peroxide from glucose in diluted honey). Others, including catalase (converts peroxide to water and oxygen) and acid phosphatase, may also be present. (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Epidemic
A larger than usual number of cases of a particular infectious disease in one locality.
Extracted Honey
Honey that has been obtained by centrifuging decapped broodless combs. (Codex Standard 12-1981 Rev. 2 2001)

Honey that has been separated from the comb by centrifugal force, gravity, straining or by other means. (United States Standards for Grades of Extracted  Honey May 23, 1985:
http://www.ams.usda.gov/standards/exhoney.pdf)

Fermentation
Fermentation in honey is caused by osmophilic yeasts. It will not occur in honey that has a carbohydrate content greater than (>) 83%, a moisture content less than (<) 17.1%, a storage temperature less than (<) 11°C (52 °F) or that has been heat-treated. Properly extracted, treated and stored honey should not ferment. (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Filtered
Honey which has been filtered to the extent that all or most of the fine particles, pollen grains, air bubbles, or other materials normally found in suspension, have been removed. (United States Standards for Grades of Extracted Honey May 23, 1985: http://www.ams.usda.gov/standards/exhoney.pdf)
Floral Source
The flower from which the bees gather nectar to make honey (United States Standards for Grades of Extracted Honey May 23, 1985). Examples include clover, alfalfa, buckwheat, canola, sunflower etc. The color and flavor of honey may vary depending on the source of the nectar. (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Food
"Food" includes any article manufactured, sold or represented for use as for human beings, chewing gum, and any ingredient that may be mixed with food for any purpose whatever; As per section 2 (Interpretation) of the (Food and Drug Regulations)
Food Carrier
Any vehicle including trucks, tanks, tankers and totes used for the transportation of food.
Frame
Four assembled pieces of wood designed to hold comb. It consists of one top bar, one bottom bar and two end bars. (Beekeeping in Western Canada)
Germicide
A substance that kills germs and certain pathogenic organisms.
Gothe Scale
A scale used to measure the diastase level in honey. This enzyme is responsible for converting starch to dextrins and sugars and is introduced into honey by the bees. This number expresses the diastase activity as the number of ml of a 1 percent (%) starch solution hydrolysed by the enzyme in 1g of honey in 1 hour at 40°C. Diastase is heat sensitive the level in honey is used as an indicator of overheating. (Chemical Food Analysis - A Practical Manual -
University of Queensland Publication - 2003 - PDF (262 kb)
)
Granulation
The initial formation of crystals in honey. (United States Standards for Grades of Extracted Honey May 23, 1985 - PDF (62 kb))
Hazards
The potential to cause harm - Hazards can be biological, chemical or physical. (Food Safety Enhancement Program Manual - Glossary of Terms)
Heat Treatment / Pasteurization
Honey is heat treated to prevent unwanted fermentation by osmophilic yeasts and followed by rapid cooling to 54°C (130°F). Other effective treatments include heating honey to 60°C (140°F) for 30 minutes or 71°C (160°F) for one minute or some straight line gradient between those two temperatures. (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Honey
Honey is the natural sweet substance produced by honey bees from the nectar of plants or from secretions of living parts of plants or excretions of plant sucking insects on the living parts of plants, which the bees collect, transform by combining with specific substances of their own, deposit, dehydrate, store and leave in the honey comb to ripen and mature.

Honey is produced by the bees from nectar of a variety of plants. The bees collect the nectar into their honey stomach and take it back to the colony. In the process of collecting and taking it to the colony, some enzymes are added. The nectar is stored in cells in the combs and the bees work to evaporate the moisture until it is between 16-18%. At this stage it is honey and because of its very high sugar content (>80%) it keeps very well. (CFIA Animal Health Bulletin)

Honey Classifier
An instrument used to measure the hue or shade of colour of honey. The classifier approved for use by the President is the is the Lovibond 2000+ with standardized lighting unit and the colour disc - (Canadian Honey Colour (Pfund Equivalents) of 8-114)
Honeydew Honey
Honey which comes mainly from excretions of plant sucking insects (Hemiptera) on the living parts of plants or secretions of living parts of plants.
Host
A plant or animal harboring another as a parasite or as an infectious agent.
Hygiene
Practices necessary for establishing and maintaining good health and sanitation.
Hydroxymethylfurfural (HMF)
Hydroxymethylfurfural (5-hydroxymethyl-2 furalde-hyde), also called HMF, is a compound that results from the breakdown of simple sugars (such as glucose or fructose) at pH 5 or lower during storage or during heating. HMF occurs naturally in honey especially in warm climates. Its presence is considered the main indicator of honey deterioration and overheating. (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Infant Botulism
Infant botulism is caused by consuming the spores of the botulinum bacteria, which then grow in the infant's intestine and release toxin. In adults, the spores ingested from food are digested before they can form a toxin. However the intestine of an infant under one year of age is sometimes not mature enough to digest these spores. In rare cases the botulism spores can germinate in the infant's intestine and produce a toxin which can make the baby sick. For this reason it is recommend that infants under one year of age are not fed honey. Pasteurization of honey is not sufficient to kill the botulism spores. (Canadian Honey Council)
Infection
Illness that occurs as a result of consumption of food or water contaminated with pathogenic bacteria. The viable cells, even if present in small numbers, have the potential to establish and multiply in the digestive tract causing illness.
Infestation
Occupation or invasion by parasites other than bacteria.
Intoxication
Contamination of food with toxins produced by microorganisms growing in or on it.
Liquid Honey
Honey that is free from visible crystals. (United States Standards for Grades of Extracted Honey May 23, 1985: http://www.ams.usda.gov/standards/
exhoney.pdf)
Lot
A "lot" may be defined as a collection of agricultural food products of the same size, type and style that have been manufactured and packed in containers of the same size under essentially the same conditions and which is identified by the establishment/regulated party as a "lot" for the purposes of sampling.
Low Acid Food
A food, where any component of the food has a pH greater than 4.6 and a water activity greater than 0.85.
Mead
An alcoholic beverage made by fermenting honey and water. (National Honey Board - Making Mead: The Art and Science)
Mite
See Varroa and Tracheal mites
Monitoring
Data gathering to provide information about predefined sampling populations and to identify potential problems for surveillance activities.
Moulds
Moulds are filamentous fungi. They form a true mycelium composed of many filaments which may or may not have crossed walls. Asexual and sexual spores are produced, sometimes in specialized fruiting bodies. Non -xerophilic moulds are inhibited at 0.80 Aw and xerophilic moulds at 0.60 Aw. (Essentials of the Microbiology of Food)
Nucleus
A small colony of bees often used in queen rearing or mating or to increase colony numbers. (Beekeeping in Western Canada)
Oligosaccharides
Medium-sized carbohydrates that contain more than three simple sugar sub-units, often made of monosaccharides and disaccharides. Oligosaccharides are sometimes referred to as "higher sugars". (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Organism
An individual living thing.
Osmophilic Yeasts
Yeasts preferring a reduced water activity (Aw 0.65 to 0.60) for growth. Sugar tolerant yeasts. This type of yeast should not be found in heat treated honey. ( Agriculture Canada - A History of the Bacteriology Division)
Parasite
An organism that derives its nourishment from a living plant or animal host and does not contribute to the host's well-being but does not necessarily cause disease.
Pathogen
A microorganism capable of producing disease when it enters the human or animal body.
Pfund Honey Colour Grader
Is an instrument used to determine the colour classification of honey. The colour density of a sample of the product being tested is compared to the colour density of a standard amber wedge. The reading is then made on the millimetre scale which is calibrated in special divisions to indicate standard colour grades for honey. (Koehler Instrument Company)
pH
A logarithmic measurement of acidity and alkalinity due to hydrogen and hydroxyl ion concentration on a scale from 0 to 14, where 0 is most acid, 7 is neutral and 14 is most alkaline.
Pollen
Pollen is the male germ plasm of plants which contains proteins, fats, minerals and vitamins. It is collected by the bees from a variety of plants at different times of the year. It is the only protein source collected by bees for feeding their brood. Beekeepers collect the pollen every 2-3 days and freeze it or dry and clean before storage. Collected pollen is used for bee feeding, human consumption and pollination of plants. (CFIA Animal Health Bulletin)
Pollen Grains
The granular, dust-like microspores that bees gather from flowers. Pollen grains in suspension contribute to the lack of clarity in filtered style honey. (United States Standards for Grades of Extracted Honey May 23, 1985 - PDF (62 kb))
Pollution
The accumulation of foreign unwanted matter in an environment in which it becomes a nuisance or a danger to the health of the environment.
Potable
Suitable or safe for drinking.
Pressed Honey
Honey which is obtained from pressing broodless combs. (Codex Standard 12-1981 Rev. 2 2001)
Propolis
The gum that is gathered by bees from trees and other vegetation. It contains waxes, resins, balsams, oils and pollen. Bees use it to reduce the beehive entrance size and encase foreign material. It may vary in colour from light yellow to dark brown. It may cause staining of the comb or frame and may be found in extracted honey. It is used in alternate medicine because of its antimicrobial properties (ointments creams etc.). (CFIA Animal Health Bulletin) (United States Standards for Grades of Extracted Honey May 23, 1985 - PDF (62 kb))
Refractometer
An optical instrument used to measure substances dissolved in water. It works using the principal of light reflection through liquids. As light passes from air into water it slows down, creating the phenomenon which gives a bent look to objects partly submerged in water. The more dissolved solids in water the slower that light travels through it and more pronounced the bending effect on light. Refractometers measure the amount of dissolved solids by passing light through a sample and showing the refracted angle on a scale displayed within the refractometer's eyepiece. (Forestry Suppliers Inc.)
Refractometer-Honey
The operating principal is similar to a refractometer above but honey refractometers measure the percent (%) of moisture by passing light through a sample and showing the refracted angle on a scale displayed within the refractometer's eyepiece. The temperature compensation factor, as per gauge on the outside of the refractometer, must be taken into consideration for accurate moisture readings. (Atago Co. Ltd. Tokyo Japan)
Refractive Index
The moisture, or conversely the soluble solids in honey, is determined by measuring the refractive index of honey using a refractometer. Since the refractive index of honey is different from that of a sucrose solution at the same concentration, a special moisture chart must be used. This chart is found in AOAC Method 969.38 (Analytical Methods). Using the "Brix" or "Sucrose" scale will provide inaccurate values for honey. (Grading Chapter of the Product Inspection Manual for scale) (National Honey Board - Honey - A Reference Guide to Nature's Sweetener)
Regulated Party
A registered establishment or importer which falls under the scope of the Honey Regulations.
Ripe Honey
Honey from which bees have evaporated sufficient moisture so that it contains no more than 17.8% water. (Beekeeping in Western Canada:(Beekeeping in Western Canada)
Royal Jelly
Royal Jelly is secreted by glands in the heads of worker bees and is fed to queens throughout their larval and adult lives, to young workers and drone larvae. It is high in protein and is synthesized during the digestion of pollen. It can be collected and sealed in small vials or freeze dried. It is used as a health food for its therapeutic value. (CFIA Animal Health Bulletin)
Sample
Is represented by one sample number and may consist of one or more sample units or subsamples.
Sample Unit
A consumer size container of a product that usually consists of a minimum of 100g. It is often referred to as a sub-sample.
Sanitary
Free from disease causing microorganisms and other harmful substances.
Sanitation
The creation and maintenance of conditions favourable to good health and conditions free from disease.
Sanitize
Treatment by heat or chemicals to reduce the number of microorganisms present.
Seasonal Operator
Refers to those establishments who extract, prepare or package honey 4 months or less per calendar year.
Soap
A compound of fatty acids and alkalis that has cleaning properties.
Spore
An inactive, resistant, resting or reproductive body that can produce another vegetative individual under favourable conditions.
Strained
Honey that has been strained to the extent that most of the particles, including comb, propolis, or other defects normally found in honey, have been removed. Grains of pollen, small air bubbles, and very fine particles would not normally be removed. (United States Standards for Grades of Extracted Honey May 23, 1985 - PDF (62 kb))
Sterile
Free from all living microorganisms.
Sump
Temporary holding area for honey between extractor and tank.(Beekeeping in Western Canada)
Super
A hive box or hive body with or without frames. (Beekeeping in Western Canada)
Taint
To contaminate with undesirable microorganisms or chemical substances.
Toxin
A chemical produced by living organisms which is poisonous to humans and animals.
Tracheal Mite
(Acarapis woodi)
The tracheal mite is an internal parasite. It spends its entire life on adult honey bees and once well established, it moves into the main thoracic tracheae. Colonies affected by tracheal mites are weaker and generally have higher winter losses. Treatment is either formic acid, oxalic acid or menthol.
Varroa Mite
(Varroa destructor)
The varroa mite is an external parasite that infests both brood and adult honey bees. Colonies affected by varroa mites are weaker and generally have higher winter losses. Treatment is formic acid, oxalic acid, menthol or fluvalinate.
Virus
Ultramicroscopic infectious agent that replicates itself only within cells of living hosts. Many viruses are pathogenic.
Yeast
Belong to the kingdom of the Fungi and are usually unicellular organisms (10 - 20 microns in diameter). They usually multiply by producing budding cells that eventually break off, although they may form spores by a meiotic mechanism, within a very simple fruiting body - usually a single cell (Essentials of the Microbiology of Food).

Introduction

1.0 Background

The Government of Canada has consolidated all federally-mandated food inspection and quarantine services into a single federal food inspection agency - the Canadian Food Inspection Agency (CFIA). The consolidation into a single agency integrates the delivery of inspection and quarantine services previously provided by Agriculture and Agri-Food Canada, Health Canada, and Fisheries and Oceans Canada. All inspection services related to food safety, economic fraud, trade-related requirements, and animal and plant health programs, are provided by CFIA. Health and safety standards for CFIA are set by Health Canada.

The Honey Program is one of fourteen programs within CFIA. The Honey Program has two manuals of procedures - the Honey Product Inspection Manual which outlines procedures for product inspections and this manual, the Honey Establishment Inspection Manual.

The CFIA has also established procedures and various manuals for the Food Safety Enhancement Program (FSEP). FSEP is currently a voluntary program for registered honey establishments who wish to be recognized by CFIA since they have developed and applied a HACCP system. The four chapters of the FSEP manual can be found at: http://www.inspection.gc.ca/eng/1299855874288/1299859914238. Once a registered honey establishment achieves FSEP recognition by CFIA, it will no longer receive inspection services as described in the Honey Establishment Inspection Manual; instead, audit principles as described in Chapter 4 of the FSEP manual will be utilized.

The Honey Establishment Inspection Manual outlines procedures for: the registration of establishments, inspection of the establishments, follow-ups, and enforcement and compliance actions in cases of non-compliance. The manual establishes clear national standards and procedures, which will be of assistance in training as well as in maintaining program uniformity. Peculiarities and issues that are not covered by this manual are to be brought to the attention of the Program Network Specialist.

This manual is intended for use by CFIA inspection staff and registered honey establishments. The inspection tasks are divided among prerequisite programs, manufacturing controls and records. It is expected that the registered honey establishment demonstrates control over programs for premises, transportation and storage, equipment, personnel, sanitation and pest control, recall and manufacturing to meet requirements in order to produce safe, wholesome, properly represented and high quality honey products.

The Honey Establishment Inspection Manual has been incorporated into CFIA's electronic inspection database called the "Multi Commodity Activities Program (MCAP)". All information relevant to registered honey establishments has been entered and stored in the database. Inspection worksheets, compliance rating and corrective action reports are generated from the MCAP database.

This edition of the manual has been revised from the Honey Inspection Manual issued in 1989. Amendments will be issued on an as-needed basis for each chapter. Requests for changes or modifications should be directed to the Chief, Honey Program or National Manager, Dairy, Eggs and Honey, in Ottawa.

2.0 Legal Authority

The Honey Establishment Inspection Manual is based on the authority and requirements of the Canada Agricultural Products Act, the Honey Regulations, the Food and Drugs Act and its Regulations, the Consumer Packaging and Labelling Regulations and Part 7 of the Canadian Food Inspection Agency Fees Notice. This manual has no precedence over any federal regulations.

3.0 Objectives

  1. To ensure that honey which is traded interprovincially and/or internationally or carries the Canada grade mark, is manufactured in registered establishments
  2. To ensure that registered honey establishments are in compliance with federal Canadian legislation.
  3. To ensure that registered establishments are inspected in accordance with the Honey Establishment Inspection Manual.

4.0 Responsibilities

4.1 Industry

Industry is responsible for compliance with appropriate government regulations regarding:

  • safety (biological, chemical and physical hazards)
  • representation (fraud, labelling and substitution)
  • quality (grade, standards and composition)

The establishment inspection program measures the attainment of these responsibilities. Industry is encouraged to actively participate with the inspection team during the establishment inspection. Industry is further encouraged to develop and implement a quality management system and self monitor their performance on an ongoing basis. A quality management system may include, On Farm Food Safety (OFFS), ISO certification or HACCP Recognition.

In order to facilitate an accurate and thorough evaluation of tasks, establishment management is responsible for:

  • accompanying the inspection team;
  • providing for the dismantling of equipment, when required;
  • assisting in record and program reviews.

4.2 CFIA

The Canadian Food Inspection Agency (CFIA) is responsible for the delivery of the inspection program as designed and adhering to the following safe work practices.

4.2.1 Occupational Safe Work Practices

All inspection staff must be aware of the hazards that are inherent in their working environment. Pre-occupational checks of the work area are essential to identify unsafe conditions or situations. These must be corrected before inspection is started. Work should not proceed on third party premises until unsafe conditions and situations are corrected.

Following safe work practices combined with on the job training will help reduce the chance of injury to an inspector. The following safe work practices are to be observed when performing inspection tasks outlined in this manual.

(a) Manual Material Handling

Plan and notify the regulated party of your visit. Have a regulated party representative assigned to you at all times. If required, use proper lifting techniques:

  • keep feet at least a foot apart to provide a stable base;
  • with a straight back, bend the knees to lift;
  • lift as close to your body as possible;
  • turn by pivoting at the feet, not twisting at the waist;
  • ask for assistance when necessary

When conducting an inspection at a workstation, ensure that table height is adequate to perform the inspection and lighting is at least 540 lux.

(b) Moving Vehicles

Be aware of all moving vehicles (forklifts, trucks, etc.) while travelling around and within the regulated party's workplace. Use designated walkways when possible. Do not assume that the pedestrian has the right of way and try to remain visible to any vehicle operators. Be aware of the dangers associated with exhaust fumes from vehicles.

(c) Personal Protective Equipment

Ensure you wear and are trained in the use, care and maintenance of the personal protective equipment as per your scales of entitlement.

Personal protective equipment requirements and safety measures are recommended, and are often listed on products or substances encountered in the workplace. The Workplace Hazardous Material Information System (WHMIS) is a nationwide system intended to provide information on hazardous materials used in the workplace. There are three key elements to WHMIS: Labels, Material Safety Data Sheets (MSDS) and Worker Education. The WHMIS label and, in its absence, the product label are sources of information on the relative toxicity (flammability, corrosivity, etc.) of a substance, the first-aid measures that should be taken if and when exposure does occur, recommended personal protective equipment that should be worn and a statement to refer to the MSDS. A system of symbols and risk phrases indicates the toxicity of the substance.

The MSDS has more specific information about the product or substance and it should be consulted if it is available at the site. Personal protective equipment may include but is not limited to:

  • coveralls/lab coat/hair net;
  • CSA approved head protection;
  • CSA approved non-slip footwear;
  • CSA approved eye protection;
  • CSA approved hearing protection;
  • nuisance dust mask;
  • protective bee equipment (veils).

(d) Slip and Fall Prevention

Reduce the risk of slip, trip and fall accidents by:

  • wearing CSA approved protective footwear;
  • keeping footwear in good condition - replace at 30% wear;
  • practising good housekeeping;
  • keeping work area and walkway free from debris;
  • following safe work practices.

(e) Third Party Premises

Be aware of environmental conditions (e.g. presence of excessive number of bees) and any structural concerns. Inform plant management of the occupational health and safety hazard.

(f) Climbing

Inspectors must not climb any skids, equipment or materials. Inspectors must not stand on the forks of a lift truck or stand on any platform being hoisted by a lift truck. Ask the regulated party for assistance when necessary.

(g) Emergency Procedures

Inspectors must be familiar with the emergency procedures in the establishment they are working in. The inspector must also :

  • know the emergency plan of the work site he is in;
  • if such a plan does not exist, you must ensure you have your own plan of escape if an emergency occurs;
  • you must be aware of the emergency exits in your immediate work area, these exits must remain unlocked and unobstructed;
  • refer to the appropriate MSDS when dealing with chemical hazards.

(h) Right to Refuse

Inspectors always have the right to refuse to perform an inspection for occupational safety and health reasons. If you have doubts about your safety, or a co-worker's safety, notify your supervisor and identify the safety issue. The safety issue will be addressed and resolved before you begin work.

5.0 Honey Establishment Inspection Activity Frequencies

Inspection frequencies in the work plans are established based on the previous compliance history of the various activities and their risks. Annually activities are prioritized by Programs and Operations at the national level.

The frequencies outlined in the table below should be considered as a guideline. Each registered honey establishment has a unique situation (e.g. seasonal considerations, number of products produced or imported, previous compliance history, etc.) which the inspector needs to take into consideration to determine the actual level of inspection, either more or less than indicated in the table, required for a particular establishment.

In those instances where it may not be possible to complete the activities outlined by the work plan, this information should be communicated to the Inspection Manager and/or Program Specialist with the reason(s) why they could not be delivered. Only program activities related to establishment inspection are listed in the following chart. Product inspection frequencies are listed in the Honey Product Inspection Manual.

Activity Domestic Frequency
FSEP/ HACCP Recognized
Domestic Frequency
Others
Import Frequency
Establishment In-depth Inspection N/A 1/yr N/A
Directed Inspections (as per Chapter 2 of this manual) N/A   N/A
- Pasteurizers N/A 4 x year N/A
- Packers N/A 1/quarter when operating N/A
- Producer Graders N/A N/A N/A
Establishment - FSEP audit 1/yr N/A N/A

6.0 Honey Inspection Activity - Time Standards

Most of the honey inspection time standards are a calculated average of how much time is needed to complete the activity. They include all the time required for preparation, inspection, and documentation, including any clerical support time. Activities do not include travel time. Where there is no time standard and real time is tracked, the inspector should keep a log of all the time taken in the office and/or at the establishment/importer site to the nearest quarter hour (15 minutes). The RMS Help Manual can be found at: O:\programs\RMS

Establishment Registration
ACTIVITY/ SUB-ACTIVITY OUTPUT TIME STD. (min.)
Registration less then (<) 20 hours CFIA 3043 - Application for Registration
CFIA 3382 - Descriptive Profile
CFIA 5138 - Certificate of Registration
990
Registration greater then (>) 20 hours CFIA 3043 - Application for Registration
CFIA 3382 - Descriptive Profile
CFIA 5138 - Certificate of Registration  
1950
Registration - Renewal CFIA 3043 - Application for Registration
CFIA 3382 - Descriptive Profile
CFIA 5138 - Certificate of Registration
30 
Establishment Inspection
ACTIVITY/ SUB-ACTIVITY OUTPUT TIME STD. (min.)
Food Safety Enhancement Program - FSEP Training Training records Real Time
Food Safety Enhancement Program - FSEP Recognition Process FSEP Forms - Appendix 1, 2 and 4 Real Time
Food Safety Enhancement Program - FSEP Regulatory Partial Audit FSEP Forms - Appendix 6 Real Time
Food Safety Enhancement Program - Follow-up FSEP Regulatory Partial Audits FSEP Forms - Appendix 6 Real Time
Food Safety Enhancement Program - FSEP Regulatory Full System Audit FSEP Forms - Appendix 6 Real Time
In-depth Inspection - Pasteurizer /Packer MCAP
Establishment Inspection Worksheet
480
In-depth plant Inspection - # of follow-up inspections of Pasteurizer/Packers completed   MCAP
Establishment Inspection Worksheet
240
In-depth plant Inspection - # of directed inspection of Pasteurizer/Packer   MCAP
Establishment Inspection Worksheet
CFIA 0992 - Inspection Report
180
In-depth Inspection -Producer/Grader MCAP
Establishment Inspection worksheet
180
In-depth plant Inspection - # of follow-up inspections of honey producer/graders completed MCAP
Establishment Inspection worksheet
60

7.0 Honey Inspection Activity - Fees and Fee Schedule

The various fees for activities carried out in the Honey Program can be found in Part 7 of the Canadian Food Inspection Agency Fees Notice at: http://www.inspection.gc.ca/eng/1306471896637/1307341580313

The fee schedule including financial coding may be found at: http://merlin.cfia-acia.inspection.gc.ca/english/comcon/arcd/fee_schedule/schee.aspx

More information on the procedures involved in cost recovery can be found in the Registration of Establishment Chapter of this manual and the Cost Recovery Procedures Chapter of the Honey Product Inspection Manual.

Chapter 1 - Registration of Establishment

1.1 Regulatory Requirements

1.1.1 Registration Requirements

Registration is required under the Honey Regulations (HR) of the Canada Agricultural Products Act to enable an establishment preparing honey to:

  1. engage in international trade (either under his own label or that of a buyer or first dealer)
  2. engage in interprovincial trade (either under his own label or that of a buyer or first dealer); Exemption: Honey may be moved interprovincially from a non-registered establishment if the honey is packed in bulk containers and the honey is being conveyed to a registered establishment for the purpose of classification, grading, repacking or reprocessing.
  3. apply a Canadian grade mark to the applicable product.

The following terms are defined in Section 2(1) of the Honey Regulations:

(A) "registered establishment" means an establishment that is registered in accordance with Section 10;

(B)"packing establishment" means a building in which the preparation of honey, including its colour classification, takes place, but does not include a pasteurizing establishment or a producer-grader establishment;

(C) "pasteurizing establishment" means a building in which the preparation of honey, including its pasteurization and colour classification, takes place;

(D) "producer-grader establishment" means a building in which a producer grader carries out the preparation, including colour classification, of the producer's honey;

(E) "first dealer" means any person who acquires for sale under his own label honey packed by another person;

Sections 9 and 10 under Part I.1 of the HR outlines the procedures and requirements under which an establishment will be registered.

Sections 11 and 16 to 27 under Part I.1 of the HR outline the conditions that an establishment must meet in order to become and remain registered.

Section 13 of the CAP Act outlines the conditions of registration and operation of an establishment as a registered establishment under this Act, as well as the fact that all agricultural products in the establishment are subject to this Act and Regulations. All honey produced in a registered establishment must meet the requirements of grade names and standard containers, even if it is to be distributed within the province of manufacture only.

Note: In addition all local and provincial ordinances, codes and regulations must be observed.

1.1.2 Products Regulated Under the Honey Regulations

Only "Honey" as defined in the Food and Drug Regulations Section B.18.025, B.18.026, B.18.027 and in the Honey Regulations, Section 8, may require registration (Section 1.1.1 above).

1.1.3 Products Regulated Under Other Regulations

A separate registration with CFIA may be required for an establishment producing and/or trading in other commodities such as fish, maple products, shell eggs, processed eggs, processed fruit and vegetable products, dairy products, meat or poultry products. Please refer to your local CFIA inspection office to obtain more information.

Products not standardized by agricultural products regulations (e.g. flavoured honey, honey straws, apple cider, bakery products, peanut butter) are regulated under the Food and Drugs Act and Regulations, the Consumer, Packaging and Labelling Act and Regulations, and other relevant legislation. There are no registration requirements for establishments producing these products at this time, however, they may still be subject to CFIA assessment.

1.2 Suggested References

1.2.1 Acts and Regulations

Canada Agricultural Products Act

Honey Regulations

CFIA Agency Fees Notice - Part 7 Honey Fees Order

Food and Drug Regulations

1.2.2 CFIA Reference Listing Accepted Materials

Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food Chemical Products, CFIA
http://www.inspection.gc.ca/active/scripts/fssa/reference/refsearec.asp?lang=e&c=1

This is a current list of materials and non-food chemicals which have been found by Health Canada and CFIA to be acceptable for use in establishments registered with CFIA. The primary purpose of this publication is to provide a reference for both inspection personnel and representatives of the managerial staff of establishments, to indicate acceptance status for products intended for use in their establishments. The inclusion of the name of a product in this list is not to be construed as an endorsement for that product by the CFIA.

Information on how to obtain acceptance for the use of materials and agents in establishments, can be found at:
http://www.inspection.gc.ca/active/scripts/fssa/reference/refsearec.asp?lang=e&c=1

or by contacting:

Technical Program Officer
Food Safety Division, Ottawa Laboratory (Fallowfield)
Food Safety Risk Analysis Unit
Canadian Food Inspection Agency
1400 Merivale Road
Ottawa, Ontario K1A 0Y9

Telephone: 613-773-5840 Fax: 613-773-5642

1.2.3 General References

Other useful information (e.g. Food Safety Enhancement Program [FSEP] and HACCP) can be found on the CFIA Website at: http://www.inspection.gc.ca/eng/1299855874288/1299859914238

1.3 Procedures for Registration and Industries' Responsibilities

1.3.1 Application Submission

A complete registration package must include the following:

  1. Letter of Request for Registration - signed and dated by the management/owner/legal agent to confirm commitment to meet the registration requirements of the Honey Program
  2. Application for Registration of an Establishment (CFIA/ACIA 3043)
  3. Descriptive Profile of Applicant Establishment for Processed Products (CFIA/ACIA 3382)
  4. Letters of Incorporation (if applicable, photocopies are permitted)
  5. Registration Fees (Section 1.4.2)
  6. Copy of Sanitation and Pest Control Programs

The application package should be forwarded to the local CFIA inspection office and arrangements must be made for a pre-registration establishment inspection.

1.3.2 Application Forms

The following two forms may be found at the end of this chapter; at or may be obtained by contacting the local CFIA inspection office.

  1. Application for Registration of an Establishment (CFIA/ACIA 3043)
  2. Descriptive Profile of Applicant Establishment for Processed Products, Maple and Honey (CFIA/ACIA 3382)

These forms must be completed and submitted to the local CFIA inspection office along with the complete registration package.

Following are instructions on completing the forms.

(a) Application for Registration of an Establishment (CFIA/ACIA 3043)

  1. Type of Application

    Check the appropriate box.
    New: For a new establishment;
    Renewal: For the annual renewal of the registration (based on the anniversary date of the original registration);
    Revision: For any changes made to the legal name of the establishment or the mailing address of the establishment.

  2. Preferred Language of Correspondence

    Check the appropriate box.

  3. Existing Registration Number (if applicable)

    For renewal or revision, indicate the registration number assigned to the establishment.

  4. Legal Status of Business

    Check the appropriate box.

    • Corporation or Limited Company: This consists of a legally registered or incorporated entity. The business name usually includes Ltd. or Inc. in the title. The business incorporation documents may be federally or provincially registered. Copies of official articles of incorporation or other registration documents are required. Example: Honey Inc.

    • Partnership: When two or more individuals operate a business, they may form a partnership. This partnership must be registered. Example: Mike Smith and Sons.

    • Individual: This condition applies when an individual operates a business on their own without a business registration or documentation as long as the person's first name and surname are used in the name. Example: John White's Honey. An individual can operate a business without using their own name in the business name but if that is the case then the name should be officially registered. If the business name is not registered then the individual must provide proof of identification by submitting a copy of their birth certificate or their driver's licence.

    • Co-operative: This is a business such as a farmers' co-operative which has been created under the Co-operative Act. This business must provide legal documents establishing the co-operative. Example: Honey Packers Co-operative.

  5. Legal Name of Business As Registered

    Please ensure that the company name recorded on the form is exactly the same as is indicated on the partnership documents or the letters of incorporation.

    In cases where an operating name is not registered, the complete name of the individual requesting registration must be used in establishing the legal status of the business. The operating name should be added as an additional information under "Also Doing Business As".

    Under the "Also Doing Business As" heading, the applicant should indicate each commercial name used.

  6. Street Address or Legal Description of Location of Establishment

    Urban Areas

    The street number, street name, town and province are acceptable as the legal address to be indicated in this box.

    Rural Areas

    The street number, street name, town and province are acceptable as the legal address to be indicated in this box. However, where street numbers and names are not available, the legal address in use in the province must be identified. The Ontario format is as follows: Lot, Concession, Township, County, Municipality and Province. In the Atlantic provinces, some places are still only identified by a registered survey number.

    Please note that there is a separate box to indicate the mailing address. When a P.O. Box number is being used for mailing purposes, it must be shown in the box assigned for the mailing address.

  7. Mailing Address Including Postal Code

    Please indicate the mailing address which may not be the same as the legal address of the establishment. When a P.O. Box Number is being used for mailing purposes it must be shown in this box.

  8. Telephone and Facsimile

    Provide the telephone # and facsimile # of the establishment or the operator. It is requested that a 24 hour emergency number also be provided. This number will only be used in case of food recall emergencies.

  9. Name, Mailing Address and Postal Code of Applicant

    If this is exactly the same as in the above fields, indicate same as above. This may be the establishment or personal address for the smaller businesses. For larger corporations, this may be the establishment address or address of the head office.

  10. Telephone and Facsimile

    Provide the telephone and facsimile number if different from the establishment's numbers.

  11. Partnership/Individual Ownership

    This only needs to be completed for partnerships or individual ownerships to show the names, titles, and addresses of all parties involved in the business. This can be attached on another page if more room is required for this information.

  12. Signature, Official Title and Date

    The person who signs the application form must be a responsible person within the company (e.g. a director or shareholder). In addition to the signature, please print the name, date of request and identify the title or official capacity of the person within the company.

  13. Agency Use Only

    This area is reserved for the responsible inspector to sign, date, and make any necessary comments after reviewing the application.

  14. Reverse Side of Application

    Please check the appropriate box indicating the Act and Regulations that apply to the operation.

(b) Descriptive Profile of Applicant Establishment for Processed Products (CFIA/ACIA 3382)

The descriptive profile should always accompany the application for registration form. It is important to complete this form properly. The information provided from this profile is required to identify the type of establishment and the products packed. This information is required to plan the inspection activities that will be taking place in the establishment.

  1. Name and Location of the Establishment

    The name of the establishment must correspond with the name on the "Application for Registration of an Establishment" form. Also, the location of the processing establishment must be provided.

  2. Type of Establishment

    The types of establishments operating under the Honey Regulations include a Honey Packing Plant, Honey Pasteurization Plant or a Honey Producer Grader (Section 1.1.1). Check the appropriate box. Fees are based on the Honey Fees Order that can be found on the CFIA Website at: http://www.inspection.gc.ca/eng/1306471896637/1307341580313 (Section 1.4).

  3. Commodities Packed

    At least one product must be indicated (e.g. Honey)

  4. Direction (Map) to Location of Establishment

    Please make a schematic drawing of the location of the establishment.

  5. For Internal Use

    This section is to be completed, signed and dated by the Area Program Network Specialist.

1.3.3 Construction and Equipment Requirements

Building exterior, interior and surrounding areas must be designed, constructed and maintained in a manner to prevent conditions which may result in the contamination of food.

More details on construction and equipment requirements can be obtained through your local CFIA inspection office. Refer to Chapter 4 of this manual and at: Reference Listing of Accepted Construction Materials, Packaging Materials and Non-food Chemical Products (http://www.inspection.gc.ca/active/scripts/fssa/reference/refsearec.asp?lang=e&c=1).

1.3.4 Documentation of Written Programs

Prior to obtaining registration there is a legal requirement for establishments to have developed, documented and implemented a sanitation and pest control program. These programs must be reviewed and assessed by the inspector before proceeding with approval of the establishment registration.

In addition to sanitation and pest control programs, registered establishments are encouraged to develop, document and implement other prerequisite programs.

Prerequisite programs are universal steps or procedures that control the operational conditions within a food establishment allowing for environmental conditions that are favourable to the production of safe food. The prerequisite programs listed below will be reviewed and assessed by the inspector during the initial establishment inspection in accordance with Chapters 4 and 5 of this manual The inspector may require some changes to the programs if they are incomplete or if some improvements are needed.

The written programs are:

  • I - Premises
  • II - Transportation and Storage
  • III - Equipment.
  • IV - Personnel
  • V - Sanitation and Pest Control (Mandatory)
  • VI - Complaints and Recall

1.4 Fees

1.4.1 Purpose of Inspection Fees

Fees are based on the Honey Fees Order that can be found on the CFIA Website at: http://www.inspection.gc.ca/eng/1306471896637/1307341580313. This order states that a fee is payable for the registration of an establishment or the renewal of an existing registration on a annual basis. The purpose of the fee is to cover part of the costs associated with inspection activities. Fees are payable to the "Receiver General for Canada" only by cheque, money order or credit card. CFIA/ACIA 0527 may be used as receipt of payment.

1.4.2 Establishment Registration Fees

(a) Duration of Registration

All establishment registrations will be valid for one year, from the date of registration. The expiry date will be indicated on the Certificate of Registration.

(b) Registration Fees by Type of Operation

The annual fees payable for the registration of a honey establishment are as follows:

REGISTRATION FEES
Type of Establishment Fee
Honey Producer Grader Establishment

$100

Honey Packing Establishment

$200

Honey Pasteurizing Establishment

$400

Note: Taxes are not applicable.

1.4.2.1 Types of Establishments

  1. Honey Producer Grader Establishment

    An establishment that extracts, grades, classifies by colour and packs only the honey produced in their own apiaries.

  2. Honey Packing Establishment

    An establishment that prepares, grades, classifies by colour and packs honey.

  3. Honey Pasteurizing Establishment

    An establishment which pasteurizes honey in addition to preparing, grading, colour classification and packing honey. Pasteurization is defined as treated in a registered pasteurizing plant by the controlled application of heat so that the honey is free of viable sugar-tolerant yeasts.

1.5 CFIA Responsibilities

1.5.1 Registration Package Review

The registration package, as described in Section 1.3.1, will be reviewed by the inspector and any missing information will be requested from the establishment. Once it has been verified that the registration fee has been received by CFIA, the inspector should make the necessary arrangements with the operator of the establishment to carry out a pre-registration inspection.

1.5.2 Pre-Registration Establishment Inspection

The establishment will be inspected for compliance with Sections 16 to 27 of the Honey Regulations. If the establishment is in full operation, an in-depth inspection will be undertaken. If the establishment is not in full operation, a partial inspection can be undertaken to recommend registration and when this establishment is registered and in full operation, a full in-depth inspection must be scheduled. In both cases, the requirements stated in Chapters 4 and 5 of this manual will be observed and assessed for compliance.

Inspectors will discuss results with establishment management. An establishment inspection report will be left with the applicant. An action plan will be requested for the correction of identified infractions. At this stage, the inspector and applicant will review the application package and complete or correct it, if needed.

1.5.3 Recommendation to Register

When the required documents and the inspection report are reviewed and they indicate that the establishment meets all the registration requirements, the package should be sent to the Area Program Network Specialist along with proof that registration fees have been paid.

A registration number may be reserved for the establishment, in advance, to allow for preparation of labels and printing of cartons. However, the establishment must be informed that no production using these packaging materials is allowed prior to official issuance of certificate of registration. The reserved number may be obtained from the Area Program Network Specialist.

The Area Program Network Specialist will input the legal name and/or operating name, mailing address of the establishment and legal description of location of establishment into the registration list, which is maintained in the Client Management System (CMS). The CMS will serve as a national registration list for all registered honey establishments.

1.5.4 Certificate of Registration (CFIA/ACIA 5138)

The formal acknowledgement of the honey establishment's registration is confirmed through the issuance of a Certificate of Registration. The Certificate of Registration must contain the legal name and/or operating name and legal description of location of establishment. This certificate along with a letter (Appendix 3) explaining the meaning and conditions of registration is sent to the establishment. A copy is sent to the appropriate regional contact. For the establishment registration to remain valid, it must be renewed annually and appropriate fees submitted to CFIA.

1.5.5 Registration Renewal Procedure

CFIA Area Program Network Offices will initiate the registration renewal procedure before the registration expires. Registrations will be renewed providing that registration requirements are met, the establishment is properly maintained as documented by in-depth inspections and appropriate corrective action plans and the following documents (or equivalent) are submitted and verified:

  1. Application for registration is received on a fully completed Application for Registration (CFIA/ACIA 3043) and Descriptive Profile of Applicant Establishment for Processed Products (CFIA/ACIA 3382) forms.
  2. Sanitation and Pest Control Program, if different from the previous year.
  3. Letters of Incorporation, if different from the previous year.
  4. Registration fees.

Eight weeks before the expiry date of the registration the Area Program Network Specialist is responsible to ensure that a "Notice of Pending Expiry of Processing Establishment Registration", (Letter #4 in Appendix 6), an "Application for Registration of an Establishment " (CFIA/ACIA 3043), a "Descriptive Profile of Applicant Establishment for Processed Products" (CFIA/ACIA 3382) and an invoice (CFIA/ACIA 0527) for the appropriate fee is sent to the establishment. A copy of the invoice may also go to Accounts Receivable. A copy of the "Notice of Pending Expiry of Processing Establishment Registration" is sent to the appropriate Operations contact in the Region.

The establishment must return the completed application forms and payment to CFIA. If Accounts Receivable receives the application they must forward the application to the Area Program Network Specialist with confirmation of payment. If the Area Program Network Specialist receives the application, the funds are forwarded to Accounts Receivable and the Specialist will process the renewal after confirmation from Accounts Receivable that the funds have cleared. The Area Program Network Specialist will then update CMS, prepare the Registration Certificate and issue a renewal letter (Letter #5 in Appendix 7). The Registration Certificate is sent to the establishment with copies to the appropriate Operations contact in the Region.

Based on a legal opinion, despite the fact that an establishment is not producing for a period of 12 months or more, the Certificate of Registration cannot be cancelled if the establishment was in compliance at the time of operation. Management of the establishment must be made aware that they are to advise CFIA, in advance, of any production so that an inspection can be scheduled. Furthermore, as long as the application is complete and the registration fee is paid annually, CFIA cannot refuse the renewal of the registration.

See Chapter 3 for the procedure regarding cancellation of registration if fees are not paid.

1.5.6 Revision Procedures

Establishment Changes Implications/ Concerns for CFIA Policy Direction/ Registration Requirements
1. Ownership changes Misuse of registration number
  • Certificate of Registration must be retrieved
  • Letter of Cancellation is sent by Area Network Program Specialist
  • Update CMS
  • Letters of Incorporation/proof of business name included with CFIA/ACIA 3043, if required
  • New registration is required
2. Moving of the establishment to different legal address Misuse of registration number
  • Certificate of Registration must be retrieved
  • Letter of Cancellation is sent by Area Network Program Specialist
  • Update CMS
  • Letters of Incorporation/proof of business name included with CFIA/ACIA 3043, if required
  • New registration is required
3. Company name change To reflect legal identity on CMS
  • Certificate of Registration must be retrieved
  • No fee charged
  • Update CMS
  • Letters of Incorporation/proof of business name included with CFIA/ACIA 3043, if required
  • Revision on CFIA/ACIA 3043
  • Issuance of new Certificate of Registration with no change to expiry date
  • Appendix 4
4. Major process changes (Change in establishment profile, manufacture of new products or lines i.e. flavoured honeys, important process line changes)
  • Potential contamination of food during construction changes
  • Do changes meet requirements of regulations
  • Do the changes reflect a change in type of establishment (Descriptive Profile - CFIA/ACIA 3382)
  • Establishment should supply updated schematics/blueprints
  • Inspection as required for regulatory and contamination concerns
  • Update MCAP inspection task list
  • Change in registration documents to reflect profile changes: revision on CFIA/ACIA 3043; revision of Descriptive Profile CFIA/ACIA 3382; fee change and issuance of new Certificate of Registration with a change in expiry date
  • Appendix 4
  • Certificate of Registration must be retrieved
5. Major construction on existing legal location of establishment (i.e. new building)
With no change to establishment profile (Producer-Grader/ Packer/Pasteurizer)
Does new building meet requirements of regulations
  • Establishment should supply updated schematics/blueprints
  • Inspection is mandatory prior to production
  • Update MCAP inspection task list
  • No change in registration documents
6. Construction changes within existing establishment (expansion, renovation).

With no change to establishment profile (Producer-Grader/ Packer/Pasteurizer)

  • Potential contamination of food during construction changes
  • Do changes meet requirements of regulations
  • Establishment should supply updated blueprints
  • Inspection as required for regulatory and contamination concerns
  • Update MCAP inspection task list
  • No change in registration documents
7. Closing of the establishment Misuse of registration number
  • Certificate of Registration must be retrieved
  • Letter of Cancellation is sent by Area Network Program Specialist
  • Update CMS

1.6 Ongoing Responsibilities of Registered Establishments

1.6.1 Responsibilities

After the establishment becomes registered, the operator is responsible for compliance with the regulations as well as the following:

(a) Operational Changes

As soon as possible, the operator must inform the local inspector of the intention to change the items below:

  • Construction changes (expansion, renovation, important process line changes)
  • Major process changes or addition (Manufacture of new products or lines, i.e. flavoured honeys)
  • Closing of the establishment
  • Ownership or company name changes
  • Moving of the establishment or part of the establishment

The local inspector will indicate to the operator if new documents or forms must be submitted and if a new certificate will be issued. An inspection of the new installation/establishment may be required.

(b) Maintenance and Operation

The establishment must be maintained and operated in accordance with the Honey Regulations. [HR sections 16 to 19 and 25]

(c) Certificate of Registration

The Certificate of Registration must be kept posted in a conspicuous place in the establishment, for the period during which it remains in force. This certificate cannot be transferred to another establishment [HR section 11(1) and (2)]. If the certificate is ever lost or misplaced it is the establishment's responsibility to request a replacement certificate from CFIA.

(d) Establishment Registration Number

The registration number assigned to the establishment or the establishment's name and address must be marked on the label as per the requirements of the Honey Regulations. [HR section 35 (1)(b) and 36 (1)(c)]

(e) Approved Label File

Each registered establishment must maintain an up to date file including each label that is used in that establishment. [HR section 21(1)(b)]

(f) Assistance to Inspectors

During an inspection, investigation or sampling activity, the operator of the establishment must provide the inspectors with reasonable assistance to enable them to carry out their inspection duties as well as provide any information requested as stated in Sections 21, 26 and 38 of the Honey Regulations.

(g) Sampling

The operator must supply, without charge, samples as requested by the inspector for grading and analysis as stated in Section 21(1)(b) of the CAPA.

(h) Establishment Registration Fees

The registration fees must be paid prior to the expiry date of the registration.

Appendix 1

The Application for Registration of an Establishment (CFIA/ACIA 3043)

Appendix 2

The Descriptive Profile of Applicant Establishment for Processed Products, Maple and Honey (CFIA/ACIA 3382)

Appendix 3

Date of Letter

Applicant
Applicant Address

2920-1/reg #

Dear

Subject: Registration Of A New Honey Establishment

We are pleased to advise you that your establishment is now registered pursuant to the Honey Regulations and enclosed is the Certificate of Registration No.space . This certificate must be posted in a conspicuous place in the establishment.

To maintain registration you will be required to comply with the Canada Agricultural Products Act, Honey Regulations and conditions outlined in the Honey Establishment Inspection Manual. A copy of the Canada Agricultural Products Act and the Honey Regulations is available at our website at http://www.inspection.gc.ca or upon request.

Your registration will expire on space and to maintain your registration you will be required to submit a renewal application package prior to this date.

If you require further information please contact the undersigned or a representative at the local Canadian Food Inspection Agency office.

Yours truly,

Area Program Network Specialist

Attachments

c.c. :
Inspector
Operations Officer

Appendix 4

Date of Letter

Applicant
Applicant Address

2920-1/reg #

Dear

Subject: Revision To An Existing Honey Establishment Registration

As per your request, please find enclosed a new Certificate of Registration for establishment No.space reflecting changes made to your registered honey establishment. This certificate must be posted in a conspicuous place in the establishment.

To maintain registration you will be required to comply with the Canada Agricultural Products Act, Honey Regulations and conditions outlined in the Honey Establishment Inspection Manual. A copy of the Canada Agricultural Products Act and the Honey Regulations is available at our website at http://www.inspection.gc.ca or upon request.

Your registration will expire on space and to maintain your registration you will be required to submit a renewal application package prior to this date.

If you have not already done so, please return your old certificate of registration to the nearest Canadian Food Inspection Agency office.

If you require further information please contact the undersigned or a representative at your local Canadian Food Inspection Agency office.

Yours truly,

Area Program Network Specialist

Attachments

c.c. :
Inspector
Operations Officer

Appendix 5

Date of Letter

Applicant
Applicant Address

2920-1/reg #

Dear

Subject: Replacement Certificate For A Registered Honey Establishment

As per your request, enclosed please find a replacement for Certificate of Registration space for your registered honey establishment.

To maintain registration you will be required to comply with the Canada Agricultural Products Act, Honey Regulations and conditions outlined in the Honey Establishment Inspection Manual. A copy of the Canada Agricultural Products Act and the Honey Regulations is available at our website at http://www.inspection.gc.ca or upon request.

Your registration will expire on space and to maintain your registration you will be required to submit a renewal application package prior to this date.

If you require further information please contact the undersigned or a representative at the local Canadian Food Inspection Agency office.

Yours truly,

Area Program Network Specialist

Attachments

c.c.:
Inspector
Operations Officer

Appendix 6

Date of Letter

Applicant
Applicant Address

2920-1/reg #

Dear Operator:

Subject: Notice Of Pending Expiry Of Honey Establishment Registration - Date

Please be advised that the registration for your federally registered establishment to operate under the Honey Regulations (HR) expires on DATE. Federal registration is required for all establishments that prepare honey as defined under the HR and trade internationally and/or interprovincial or are marked with a Canadian grade mark. Establishments that allow their registration to lapse, will lose their registration, subsequent trade and grading privileges.

A renewal package which includes the necessary application forms and an invoice is enclosed with this letter. Please include any changes to your business on these application forms. A change in the registered business name should be supported by copies of the necessary legal documents.

The completed application forms for renewal along with the fee payment (cheque or money order payable to the Receiver-General) must be returned to the following address of the Canadian Food Inspection Agency Office (CFIA) before DATE:

Address
Telephone Number

Establishments no longer requiring federal registration should also notify the CFIA Office at this time.

If you have any questions, please do not hesitate to contact the undersigned or your local CFIA representative for more information.

Yours truly,

Area Program Network Specialist

Attachments

c.c.:
Inspector
Operations Officer

Appendix 7

Date of Letter

Applicant
Applicant Address

2920-1/reg #

Dear

Subject: Renewal Of Honey Establishment Registration

We wish to inform you that your request for renewal of registration for your honey establishment has been accepted. Attached please find your new Certificate of Registration for establishment No.space . This certificate must be posted in a conspicuous place in your establishment.

To maintain registration you will be required to comply with the Canada Agricultural Products Act, Honey Regulations and conditions outlined in the Honey Establishment Inspection Manual. A copy of the Canada Agricultural Products Act and the Honey Regulations is available at our website at http://www.inspection.gc.ca or upon request.

Your registration will expire on space and to maintain your registration you will be required to submit a renewal application package prior to this date.

If you require further information please contact the undersigned or a representative at the local Canadian Food Inspection Agency office.

Yours truly,

Area Program Network Specialist

Attachments

c.c. :
Inspector
Operations Officer

Chapter 2 - Establishment Inspection Procedures

2.1 Establishment Inspection Guidelines

There are three types of inspections conducted: an in-depth, a follow-up inspection and a directed/GMP inspection (Good Manufacturing Practices).

An in-depth inspection includes inspecting all aspects of the establishment. This means that all inspection tasks from Chapter 4 and Chapter 5 are assessed.

A follow-up inspection (for additional details, see section 2.5.1) is conducted only for establishments which do not achieve the minimum compliance level during an in-depth inspection. The purpose is to evaluate the establishment's corrective actions and to determine if the establishment has met the minimum compliance level.

A directed/GMP inspection (for additional details, see section 2.6) is conducted at all packing and pasteurizing establishments which have achieved the minimum compliance level during an establishment inspection. The GMP incorporates selective tasks from the Honey Establishment Inspection Program (Chapters 4 and 5 of this manual) along with infractions noted during the previous in-depth inspection.

2.1.1 Background for Chapters 4 & 5

The inspection assessment criteria tasks are found in Chapters 4 and 5 of this manual and in the CFIA MCAP database.

Chapter 4 includes generic inspection standards which may be applied to all honey establishments and consists of seven sections: Premises, Transportation and Storage, Equipment, Personnel, Sanitation and Pest Control, Complaints and Recall, and General Records.

Chapter 5 contains the Manufacturing Controls related to processing and packaging honey.

Chapters 4 and 5 are laid out in table format. The tables outline the general tasks in an establishment to be inspected. The tables are broken down as follows:

X.1 SECTION

X.1.1 SUB-SECTION

X.1.1.1 Task Code

XXXX Task number

PRINCIPLE

Assessment Criteria 

Rating Examples

  • I -
  • II -
  • III -

Reference

Each Principle Statement outlines the outcome for the task. The Assessment Criteria identify factors which determine if the situation being assessed is in compliance with the principle statement. The assessment criteria are accompanied by Rating Examples for each of the three health and safety classification categories which can be assigned against the principle statement. The rating examples are intended only as a reference to indicate potential situations within each Category. The rating examples may or may not be a reflection of the actual situation in the establishment.

Further explanation on the use of the inspection assessment criteria and the establishment rating system follows.

2.1.2 Principle Statement

Principle statements are generic, broad, outcome based statements (objectives) which are similar in style to the Codex Alimentarius Commission General Principles of Food Hygiene and the International Organization for Standardization (ISO) standards. These statements imply that the manufacturer controls all factors that may impact on health and safety. Principle statements are absolute and do not allow for variance.

Under each task number, principle statements express the intent of the Canada Agricultural Products Act (CAP), Honey Regulations (HR), Food and Drug Act and Regulations (FDA&R) and Consumer Packaging and Labelling Act and Regulations (CP&L) and are written to permit flexibility with respect to the introduction of new technologies and/or new food commodities. A principle statement may have more than one set of assessment criteria, depending on the type of process, however, a task can only be assessed once.

2.1.3 Assessment Criteria

Assessment criteria list most of the factors that will be evaluated by an inspector to determine if a manufacturer is in compliance with the principle statement of each sub-section. Where appropriate, examples are used to clarify assessment criteria. Assessment criteria provide transparency to the food industry with respect to the specific factors required and assessed by the CFIA.

As new technologies and/or new food commodities become available, evaluation of additional criteria may become necessary. For this reason, assessment criteria provided in this standard should not be regarded as exhaustive..

2.1.4 Rating Examples

Rating examples provide benchmarks to inspectors and promote uniformity and transparency in the assessment of non-satisfactory conditions and operations in the registered establishment. The examples illustrate a range of categories (I, II, III) for all deficiencies. The examples do not cover all possible deficiencies or concerns. All deficiencies are evaluated against the Health Risk Assessment Model (refer to 2.1.4.1) and the appropriate risk is assigned based on likelihood of occurrence and severity of consequences.

Category I, Category II, Category III are defined as:

  • Category I - Deficiencies relating to the principle statement of the standard which would result in a risk with a high likelihood and serious health consequences.
  • Category II - Deficiencies relating to the principle statement of the standard which could result in a moderate health risk or a direct source of contamination or adulteration.
  • Category III - Deficiencies relating to the principle statement of the standard which could result in a low health risk or an indirect source of contamination or adulteration.

2.1.4.1 Risk Assessment Model

The Health Risk Assessment Model (Figure I) has been developed using the risk assessment principles outlined in the October 1, 1993, Health Protection Branch document entitled "Health Issues: Risk Assessment". It is the basis for assessment of all health and safety risks in this standard.

The model uses likelihood of occurrence and severity of consequences to determine the rating for all deficiencies which impact on health and safety. The severity of consequences for a particular concern is fixed (e.g. subclinical, temporary disability or permanent disability/death) whereas the likelihood of occurrence varies with the degree of control exercised by the manufacturer. Population at risk and level of risk were not included in the Model because they had little impact at the sub-section level except where sensitive populations are involved. Sensitive populations include infants, the elderly, immunocompromised individuals and those individuals who consume products as a sole source of nutrition.

The rating examples and the discussion in this section (2.1.4.1) are intended to be a source of guidance for inspectors in assessing risk. The Health Risk Assessment Model may be used by the inspector when additional consideration is required.

Health Risk Assessment Model
Health Risk Assessment Model

This graphic is a table showing the Health Risk Assessment Model (Figure 1).

The side axis shows the likelihood of occurrence, and there are four categories from top to bottom: High, Medium, Low, and Remote.

The bottom axis shows the severity of consequences, and there are three categories from left to right: Low, Medium, and High.

The first row shows a high likelihood of occurrence. The first column shows a Satisfactory rating. The second column shows that a low severity of consequences results in a Category III deficiency. The third column shows that a medium severity of consequences results in a Category II deficiency. The fourth column shows that a high severity of consequences results in a Category I deficiency.

The second row shows a medium likelihood of occurrence. The first column shows A Satisfactory rating. The second column shows that a low severity of consequences results in a Category III deficiency. The third column shows that a medium severity of consequences results in a Category II deficiency. The fourth column shows that a high severity of consequences results in a Category II deficiency.

The third row shows a low likelihood of occurrence. The first column shows A Satisfactory rating. The second column shows that a low severity of consequences results in a Category III deficiency. The third column shows that a medium severity of consequences results in a Category III deficiency. The fourth column shows that a high severity of consequences results in a Category III deficiency.

The fourth row shows a remote likelihood of occurrence. The first column shows A Satisfactory rating. The second column shows that a low severity of consequences results in A Satisfactory rating deficiency. The third column shows that a medium severity of consequences results in A Satisfactory rating deficiency. The fourth column shows that a high severity of consequences results in A Satisfactory rating deficiency.

"Likelihood of occurrence" relates to the level of control the establishment exercises to eliminate the hazard that would exist if the principle statement were not adhered to. For example:

  • Remote - Where the operator has well established control measures.
  • Low - Where the operator has established good control measures, but minor infractions can be found.
  • Medium - Where the operator has established some control measures, but gaps or  inconsistencies exist. Minor infractions and major infractions can be found.
  • High - Where the operator has little or no control. Where major and critical infractions can be found.

"Severity of Consequences" relates to the type of hazard that would result if a particular principle statement were not adhered to. The hazard could be physical, chemical, or microbiological contamination resulting in health problems or serious illness, which would constitute a high severity of consequences, or it could be physical, chemical, or microbiological contamination resulting in very minor or no consequences.

Biological Hazard

Biological hazards are hazards that are caused by pathogenic micro organisms and could be assessed as low, medium or high depending on the severity of consequences of the hazard. Clostridium botulinum is known to occur in honey and is not currently controlled by processes in the establishment. It is an uncontrolled hazard and control is limited to public education which recommends not feeding honey to infants or immunologically compromised persons. However, biological hazards associated with under processing (e.g. honey products and unstandardized products manufactured in the registered establishment) are given a high severity of consequences and are again assessed as Category I, II or III depending on the likelihood of occurrence.

Chemical Hazard

Chemical hazards could be assessed as Category I, Category II or Category III depending on the severity of consequences (nature of the hazard) and likelihood of occurrence (quantity).

Allergens, additives (non-permitted or improperly used) and nutrients (insufficient or improperly used) are related to a chemical hazard. For more information on allergens please see: http://www.inspection.gc.ca/eng/1332442914456/1332442980290

(i) A chemical hazard related to an adverse reaction

Chemical hazards related to a known history of producing anaphylactic reaction in sensitive individuals such as allergens may have a medium or high severity of consequences, depending on the nature of the allergen. A non declared ingredient or additive can have severe consequences to an individual who may be allergic to that substance. This is primarily applicable to honey products and non standardized products produced in a registered establishment.

Honey contaminated with products not approved for use (e.g. non approved veterinarian drugs or agricultural chemicals) may have a high severity of consequences depending on the nature of the product.

(ii)  A chemical hazard related to food additives

Where the food additive is not permitted for use or has not been approved for use with a certain food as defined in the Food and Drugs Act and Regulations, the severity of consequences could be low, medium or high depending on the quantity, nature and the type of deficiency. Where there is no health risk involved, deficiencies will be rated as a Category III. This is primarily applicable to honey products and non standardized products produced in a registered establishment.

(iii) A chemical hazard related to nutrition

Where a nutrient has not been added (underage or overage) in prescribed amounts as permitted by the Food and Drugs Act and Regulations or where the additive is not present in the declared amount at the end of the expected shelf life of the product, the severity of consequences could be low, medium or high depending on the quantity, nature and the type of deficiency. Where there is no health risk involved, deficiencies will be rated as a Category III. This is primarily applicable to honey products and non standardized products produced in a registered establishment.

Physical Hazard

Physical contamination refers to the introduction or occurrence of objectionable material in a food or food environment of a non-health nature. Physical contamination risks are assigned as Category I, Category II or Category III, depending on the likelihood of occurrence and severity of consequences. Physical contamination risks impacting on health and safety are rated as health risks; a physical hazard, such as contamination with glass, could be a Category I, Category II or Category III health risk, depending on the severity or nature of the hazard and likelihood of occurrence.

Non-hazardous Regulatory Violations

Non-hazardous regulatory violations include deficiencies that contravene the legislation but are not necessarily associated with a health or contamination risk (e.g. improper use of approved food additives). They are rated Category III.

2.1.5 Reference

The reference refers to the legal authority and guidelines that the principle statement is based on.

2.2 Preparation for an In-Depth Establishment Inspection

To properly prepare for an in-depth inspection the inspector needs to:

  • assess the frequencies of the establishment;
  • determine the members of the inspection team;
  • determine when to carry out the inspection of the establishment;
  • carry out a review of the establishment file;
  • and gather the required inspection tools.

2.2.1 Assessment of Frequencies

Each federally registered establishment will be subject to an in-depth establishment inspection at least once a year, as per national program requirements.

2.2.2 Determination of Inspection Team

The inspection will be done by at least one qualified honey inspector. Depending on the complexity of the manufacturing processes, the size of the establishment and the time frame in which the in-depth inspection is conducted, decisions can be made at the area or regional level as to whether one or more qualified honey inspectors are required.

2.2.3 Determination of When to Carry Out the Inspection

The inspector should not notify the management of the establishment of the date of the in-depth inspection. In order to conduct effective inspections, the inspector needs to determine when the establishment is operating. This may be accomplished by contacting the provincial apiarist or other local producers.

2.2.4 Review of Establishment File

The inspector should review the establishment file in order to:

  • Identify establishment manager and key personnel by name.
  • Review previous in-depth inspection reports, action plans and follow-up actions.
  • Review directed inspection summaries, consumer complaints, recalls, lab reports, etc.
  • Have an understanding of the size and age of the establishment as well as products packed or processed.
  • Review the flow diagram showing the general movement of raw, in process and finished product within the establishment, if available.
  • Take note of any unique features of establishment (e.g. equipment, processing schedules, size, product lines).
  • Decide where the inspection will begin, identify when a major clean up can be observed and find out when a second shift (if applicable) can be observed, if possible.

2.2.5 Gathering of Inspection Tools

Each inspector must have the following equipment which will be used and/or worn in appropriate situations while conducting an establishment inspection (please refer to the Occupational Safe Work Practices Section in the Introduction):

(a) Identification

  • inspector's identification card
  • business cards

(b) Clothing

  • a clean white safety hat (if applicable)
  • hairnet and beardnet (if applicable)
  • ear and eye protection (if applicable)
  • a clean, white, lab coat/coveralls with snap or velcro fasteners, no pockets above waist
  • sanitary gloves for covering of unremovable plain wedding bands
  • sanitized rubber safety boots (if applicable)
  • appropriate clean footwear
  • nuisance dusk mask (if applicable)
  • bee veil/netting (if applicable)

(c) Equipment

  • laptop computer and portable printer
  • a flashlight in good working order
  • a light metre - calibrated
  • an accurate thermometer with steel shaft - calibrated
  • an appropriate writing tool and clip board, that can be easily sanitized

(d) Forms and References

  • inspection worksheet (Honey Facility)
  • detention and release forms
  • an up-to-date copy of the Honey Regulations
  • an up-to-date copy of the Honey Establishment Inspection Manual

2.2.6 Professionalism

A tidy, neatly-dressed, well prepared inspector exemplifies the professionalism expected from the Agency. The inspector is an official representative of CFIA and must exhibit a professional image when dealing with establishment officials. This includes respect for establishment policies and good interpersonal skills. All information discussed and obtained from a specific company must remain confidential.

2.3 Inspection

2.3.1 Arrival at Establishment and Introductions

The inspector should park in an appropriate area and ensure that their clothing (Section 2.2.5(b)) and behaviour is appropriate (no jewellery, watch, gum chewing, etc.).

To demonstrate courtesy and professionalism, the inspector should:

  • Ask for the establishment manager or person in charge
  • Present identification card or business card
  • Explain what will be done and agree on an inspection time frame
  • Inform management that the results will be discussed once the inspection has been completed and arrange for a tentative time to meet and discuss the results
  • Request to be accompanied by a representative of the establishment
  • Ask for any special protective equipment requirements and safety measures specific for that
  • particular plant

2.3.2 Establishment Representative

Some establishment managers will insist on accompanying the inspector or have a foreman or quality assurance person with the inspector at all times. This situation is preferable to being left alone because questions can be asked on the spot and serious infractions can be pointed out as observed; this way immediate action can be undertaken. Some help is also needed to assist in record and program reviews. Some guidance may be needed if the facility is a new establishment. As well, establishment personnel are encouraged to carry out their own independent in-depth inspection alongside the CFIA inspector. Inspectors must be careful not to allow plant personnel who may accompany them to rush the inspection or lead them away from infractions.

2.3.2.1 Scheduling

The inspector must determine what the establishment working schedule will be during the course of inspection (e.g. shift work, hours of work, etc.). To facilitate the best order of inspection, the inspector and establishment management should formulate an inspection schedule. Every effort must be made to assess inspection tasks while the plant is operating.

2.3.2.2 Order

Where applicable, every effort must be made by the inspector to minimize the risk of cross-contamination. The inspector should commence the inspection in the microbiologically cleanest area and finish in an unclean area of the establishment (e.g. start at packaging and end in raw receiving or establishment exterior). As well, the inspector must utilize hand washing/sanitizing facilities as frequently as required.

2.3.3 General Inspection Considerations

The following is a set of suggested rules for use during inspection:

(a) All team members are to write up their own worksheet and ratings.

(b) Where an establishment representative is present during an inspection, infractions are pointed out to the representative as the inspection is conducted through the establishment. These infractions are documented and assessed even if they are taken care of immediately, however, it is also noted that the infraction has been corrected.

(c) Ask establishment management questions rather than the workers. An exception may be when you might want to determine if a worker understands what he/she is doing or what procedures he/she has been directed to follow during regular production or when there is a problem or deviation.

(d) Follow establishment policies when applicable (e.g. when a wash basin is present in an inspection area, wash your hands).

(e) The inspector(s) should observe the general cleanliness of the equipment/facility before start-up and if necessary, observe a major clean-up before start-up (pre-operation) or after shut-down (post-operation).

(f) If more than one shift is operating, then try to observe the change-over conditions between shifts. Monitor the change-over routine between as many shifts as possible.

(g) In the storage, mixing and blending areas, take note of all ingredients, additives and processing aids, so that they can be verified with the Honey Regulations and the Food and Drug Regulations.

(h) In the labelling area(s), obtain a sample label of the product currently being processed and packed. Review the required label declarations while in the establishment. Attach the label to a worksheet so it can be reviewed more closely back at the office.

(i) While in the establishment, locate the area where non-food chemicals (e.g. cleaning chemicals, boiler water additives, etc.) are used and stored. Make note of these chemicals and their manufacturer so they can be reviewed against the establishment sanitation program and also against the CFIA's Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products (refer to CFIA Internet site: http://www.inspection.gc.ca/active/scripts/fssa/reference/refsearec.asp?lang=e&c=1). These chemicals should be stored centrally, away from the main traffic areas of the establishment, where there can be no contact with incoming raw materials, ingredients and packaging materials. Other poisonous chemicals such as pesticides must be stored in a separate area (preferably restricted) away from all cleaning chemicals and food products.

2.3.4 Rating of Tasks

The inspector should note conditions as they are found in the comments/observations/infraction column of the Inspection Worksheet (Honey Facility). The inspector should evaluate the task and record the rating on this worksheet as per Chapter 4 and Chapter 5 using the assessment criteria and the rating examples. All tasks can be rated only once and for non-satisfactory conditions, the inspector shall assign one rating per task based on the most severe risk category.

Each task will be rated as one of the following:

Satisfactory 

Satisfactory conditions - no deficiencies were noted which would result in a health risk or risk of contamination or adulteration.

Category I

Non-satisfactory conditions (deficiencies) relating to the principle statement of the standard which would result in a risk with a high likelihood and serious health consequences.

Note: Category I infractions must be immediately brought to the attention of the establishment management for corrective action. (Refer to 2.5.1.1 for immediate actions to be taken).

Category II

Non-satisfactory conditions (deficiencies) relating to the principle statement of the standard which could result in a moderate health risk or a direct source of contamination or adulteration.

Category III

Non-satisfactory conditions (deficiencies) relating to the principle statement of the standard which could result in a low health risk or an indirect source of contamination or adulteration.

Not Applicable

The task is not evaluated because it is not relevant to the establishment (e.g. heat treatment equipment in a producer grader establishment). The lack of assessment of the task in this case will not apply against the overall establishment rating.

Not Rated

The task is relevant to the establishment but not evaluated at the time of inspection (e.g. extracting equipment not being used - packing is the only operation at the time of inspection). The lack of assessment of the task in this case will not apply against the overall establishment rating.

2.4 Post Inspection

2.4.1 Reporting Inspection Results

The MCAP database is the computerized system which stores all data that is entered from the Inspection Worksheet (Honey Facility). The system will generate specific establishment reports:

  • Inspection Worksheet
  • Non-Compliance Report
  • Non-Compliance Summary Report
  • Outstanding Task List

The inspection results are entered into the Inspection Worksheet (Honey Facility) in the MCAP database. This is the worksheet where the rating for each inspection task is recorded along with a description of the deficiencies found during the in-depth inspection.

The Non-Compliance Report summarizes the infractions into Categories I, II, and III.

The Non-Compliance Summary Report provides an overall compliance percentage rating per category.

2.4.2 Overall Establishment Rating (Non-Compliance Summary Report)

An in-depth inspection is considered to be satisfactory if a minimum compliance is achieved as follows:

  • Category I 100%
  • Category II ≥ 75% (greater than or equal to)
  • Category III ≥ 65% (greater than or equal to)

In Table I, the Category rating classifies an establishment according to risk and provides a basis for risk management, program planning and resource allocation. The minimum Compliance rating is based on health risk and compliance with the regulations and it reflects the percentage of the principle statements that are found to comply during the inspection. The Action Plan Submission column defines the maximum timeframe (from the date of receipt of inspection results) for the establishment to submit their written correction action plan. The Corrective Action column defines the maximum timeframe an establishment should take to be in compliance. Procedures defined in Section 2.5 should be followed for non satisfactory inspections.

Table I  - Category Compliance and Required Actions

Category Compliance Action Plan Submission Corrective Action Completed CFIA Activity
I

100%

None required

None required

  • Directed/GMP Inspection
I

Less than 100%

Non- satisfactory

Immediate

Immediate

  • Review Action Plan
  • Follow-up Inspection ASAP
II

75% to 100%

Less than two weeksTable Note *

Less than one monthTable Note *

  • Review Action Plan
  • Directed/GMP Inspection
II

Less than 75%

Non- satisfactory

Less than two weeksTable Note *

Less than one monthTable Note *

  • Review Action Plan
  • Follow-up Inspection within 30 days of receipt of an action plan
III

65% to 100%

Less than one monthTable Note *

Less than one yearTable Note *

Table Note **

  • Review Action Plan
  • Directed/GMP Inspection
III

Less than 65%

Non- satisfactory

Less than one monthTable Note *

 

Less than one yearTable Note *

Table Note **

  • Review Action Plan
  • Follow-up Inspection within 60 days of receipt of an action plan

Note: All time frames start from the date of the exit meeting with the establishment.

Table Notes

Table Note *

For seasonal operators action plan submissions will be less than 6 months and corrective actions prior to next season's operations.

Return to table note * referrer

Table Note **

For structural items which have no immediate impact on food safety, Long Term Action Plans (longer than one year) will be reviewed and may be accepted by inspection staff.

Return to table note ** referrer

2.4.3 Exit Meeting with Management

Immediately after the establishment inspection, the inspector must meet with the appropriate member(s) of the establishment management team to review the inspection, highlight the unsatisfactory conditions and to discuss and decide on a time period or a date for correction. The time and location of the meeting should be carefully chosen in order to facilitate an effective meeting. Ample time should be made available to discuss unsatisfactory conditions with the plant management. A quiet area, preferably within the plant, would be an acceptable environment to discuss the inspection results.

At the meeting the inspector should explain the purpose of the inspection in a positive manner and provide a third party view of the status of the establishment and its operations from a regulatory perspective. The overall inspection will be reviewed, all unsatisfactory tasks will be discussed highlighting the Category I, II and III infractions in that order.

A verbal commitment from the establishment's management will be obtained as to how and when corrective action will be taken. The inspector must then indicate the requirement for submission of a written action plan with expected correction time frames (refer to Table I). Corrective action should always identify the problem to prevent its recurrence.

2.4.3.1 Commitment/Responsibility of Establishment

The establishment is responsible to correct all non-compliance tasks and achieve minimum compliance in all categories. Once minimum compliance, in all categories, has been achieved the goal of the establishment should be to continue to initiate corrective actions for all deficiencies above the minimum standard. Lack of plant responsibility is indicated by inaction by the plant either to formulate any action plans or to carry out any corrective actions (see section 2.4.4.1).

2.4.4 Final Report and Covering letter

If not presented during the exit meeting, the inspector must forward a printed copy of the Non-Compliance Report and the results of the Non-Compliance Summary Report. For those establishments which meet minimum compliance levels, the reports and covering letter (Appendix 1) must be sent within 4 to 6 weeks of the inspection. For those establishments which do not meet minimum compliance levels, the reports and covering letter must be sent out within one week of the inspection. A signed copy of the covering letter and all output reports must be kept in the inspector's file.

2.4.4.1 Written Action Plan

The signed written action plan submitted by the establishment must address all infractions reported in the Non-Compliance Report according to the time frames outlined in Table I. All action plans will be reviewed by the inspector and incomplete or unacceptable plans will be returned to the establishment for correction (e.g. critical infractions not addressed, time frames unacceptable). If the action plan is not submitted within the appropriate time frame, the inspector should contact the establishment as a reminder. Further action, in consultation with the regional office, should be taken if the establishment management is uncooperative (Chapter 3).

2.5 Non Satisfactory In-Depth Inspections

Minimum compliance level for each risk category is outlined in Table I of Section 2.4.2. For all non-satisfactory in-depth inspections, it is important that the inspector informs the Supervisor, the Inspection Manager, the Regional Program Officer and the Area Program Network Specialist. Joint consultation should take place to determine the action to be taken.

2.5.1 Follow-up Inspections

A follow-up inspection is a continuation of a non-satisfactory in-depth inspection to target identified deficiencies. The objective of the follow-up inspection is to verify that the establishment meets minimum standards of 100% for Category I, 75% and above for Category II and/or 65% and above for Category III. If upon follow-up inspection the establishment does not meet minimum requirements, refer to Chapter 3.

2.5.1.1 Category I Deficiencies

The compliance level required is 100%. Any establishment that does not meet this requirement must take corrective measures immediately or as soon as possible, depending on the situation. When a Category I deficiency is found while doing the inspection:

  • Appropriate corrective actions must be determined and implemented immediately, if required.
  • All potentially unsafe product should be placed on voluntary hold or be detained for further investigation.
  • The potential cause of the infraction must be determined to evaluate product safety.
  • If the cause of the infraction cannot be determined immediately and product safety cannot be evaluated, production should be halted until satisfactory corrective measures have been established and implemented.
  • If additional corrective actions are not required immediately, the company must submit an action plan in writing within 24 hours and corrective actions must be implemented to the satisfaction of the inspector.

A follow-up inspection will then be carried out to ensure any deficiencies or related product irregularities are corrected. Procedures indicated in program guidelines must be used for follow-ups on detained and recalled products. If the establishment does not adequately follow their corrective action plan, please proceed to Chapter 3.

2.5.1.2 Category II Deficiencies

The minimum compliance level required is 75%.

Any establishment that does not meet this requirement must:

  • Determine the potential cause of the infraction and evaluate product safety.
  • All potentially unsafe product should be placed on voluntary hold or will be detained for further investigation.
  • Implement appropriate corrective actions.
  • Submit an action plan, in writing, within 2 weeks of the exit meeting and corrective actions. must be implemented within 30 days (as outlined in Table I) of the inspection date or to the satisfaction of the inspector.

A follow-up inspection must be performed within 30 days after the receipt of the action plan for all Category II non-conformities to ensure deficiencies or related product irregularities are corrected. Procedures indicated in program guidelines must be used for follow-ups on detained and recalled products. If the establishment does not adequately follow their corrective action plan, please refer to Chapter 3.

2.5.1.3 Category III Deficiencies

The minimum compliance level required is 65%.

Any establishment that does not meet this requirement must:

  • Determine the potential cause of the infraction and evaluate product safety.
  • All potentially unsafe product should be placed on voluntary hold or will be detained for further investigation.
  • Implement appropriate corrective actions.
  • Submit an action plan, in writing, within 1 month of the exit meeting and corrective actions must be implemented within 1 year (as outlined in Table I) of the inspection date or to the satisfaction of the inspector.

A follow-up inspection must be performed within 60 days after the receipt of the action plan for all Category III non-conformities to ensure deficiencies or related product irregularities are corrected. Procedures indicated in program guidelines must be used for follow-ups on detained and recalled products. If the establishment does not adequately follow their corrective action plan, please proceed to Chapter 3.

2.5.1.4 Multiple Category Deficiencies

If the plant fails multiple categories (less than 100% for Category I and/or, less than 75% for Category II and/or less than 65% for Category III) complete action plans must be submitted and follow-up inspections performed as per Table I.

2.6 Directed/GMP Establishment Inspection

A Directed/GMP establishment inspection is a partial inspection of all packing and pasteurizing establishments which have achieved the minimum compliance level during an in-depth establishment inspection. The Directed/GMP inspection incorporates selective tasks from Chapters 4 and 5 along with infractions noted during the previous in-depth inspection.

This is an unannounced activity conducted by CFIA inspectors to evaluate the establishment's action plan, review the corrective actions taken by the establishment to correct Category II and III infractions, and to assess good manufacturing practices at registered honey establishments under actual processing conditions. Product inspection as outlined in work plan requirements, such as taking lab samples, grade verification, net quantity, label and ingredient verification may also be conducted.

Prior to the arrival at the establishment, the inspector should review the establishment file to determine the outstanding tasks and evaluate the establishment's action plan. Before beginning the inspection, inspectors are encouraged to spend ten or fifteen minutes observing the employees at work (their personal hygiene practices, food handling practices and movement throughout plant) to better evaluate inspection items described in Chapter 4, section 4.4.2.

The inspector should observe and record infractions as they are found. The Directed/GMP Inspection will be recorded on the Directed/GMP Inspection Worksheet (CFIA/ACIA 0992, see appendix 2) and will be recorded within MCAP when available. Infractions of a serious nature must be immediately brought to the attention of the establishment management and corrective action should be implemented. Prior to leaving the establishment the inspector must review the inspection with management and obtain verbal commitment for corrective actions (corrective actions noted on Directed/GMP worksheet).

i) Category I Infractions - This could be due to the occurrence of direct product contamination (e.g. glass).

  • If any of these items are non-satisfactory, immediate action must be taken to isolate affected product manufactured during the occurrence of the problem.
  • If the establishment has not demonstrated to the inspector that the product is under control or safe, it should be detained (see Chapter 3, section 3.6.3).
  • If product has been distributed, the inspector should immediately contact the appropriate Area Program Specialist and Recall Co-ordinator with the relevant details to determine if a product recall is necessary as per the recall protocol.
  • In addition to controlling the affected product, the establishment must also take the appropriate measures to prevent a recurrence of the problem.

ii) Category II and III Infractions - These must be noted on the worksheet, with an agreed upon completion date, and on the CFIA/ACIA form 0992.

iii) Lack of Establishment Responsibility/Commitment - Once it is evident that there is a lack of establishment commitment to formulate and implement any action plans with dates from in-depth or directed/GMP inspections, a Regional/Area meeting should be set up with the appropriate responsible plant management to thoroughly explain the deficiencies and why they must be corrected. The meeting should end with a mutually agreed upon action plan being developed and commitment for its implementation. See Chapter 3 if no establishment commitment can be obtained.

Appendix 1 - Covering Letter - Example

Canadian Food Inspection Agency
Address of Office
Date

Mr. Honey
Manager
Honey Products Ltd.
123 Anywhere Street
Somewhere, Canada

Subject: Establishment Inspection Results

Mr. Product:

Please find enclosed the Non Compliance Report as generated from your in-depth inspection of date. The Honey Establishment Inspection Manual was used to assess your establishment during this inspection. The inspection was completed by myself. During the exit interview all deficient items were discussed with you or your staff.

Deficient items in Health and Safety Categories have resulted in a plant rating of  space% in Category I, space% in Category II and space% in Category III. You are reminded that you may be in contravention of the Honey Regulations under the Canada Agricultural Products Act (note: critical deficiencies should be identified and reference made to the appropriate section of the regulations).

The Non Compliance Report may be used to indicate corrective actions and dates for those items found un-satisfactory. Please forward your written and signed action plan to this office no later than date (see Table 1 for dates)

We would like to thank you and your staff for the cooperation shown to us during this inspection. Please do not hesitate to contact me if you have any questions.

Yours truly,

Honey Inspector

Attachment

c.c: Area Program Network Specialist
Operations Officer

Appendix 2 - Directed/GMP Inspection Worksheet

Establishmentspace
Reg. No.space

Contactspace
Date space

1.0 Manufacturing Controls
Inspection Task S/NS Corrective Action Date
1.1 Label accuracy (5101)
1.2 Incoming material control (5301)
1.3 Empty container control - handling, storage and use of - glass, barrels etc. (5302, 5401, 5701 )
1.4 Batch preparation (5501)
1.5 Control of filling and labelling (5601,5801)
2.0 Hygienic Practices
Inspection Task S/NS Corrective Action Date
2.1 Sanitary handling of product, ingredients & packaging material (1202)
2.2 Well controlled movement of personnel & equipment between areas (101)
2.3 Absence of cross contamination
  • pests (1301)
  • returned products (503)
  • garbage (104)
  • structure (101, 201, 202)
  • lighting (102)
  • non food chemicals (501)
  • metal detector (901)
2.4 Appropriate clothing, grooming and health condition of personnel. Usage of hand washing and sanitizing stations as required. Controlled movement of personnel & equipment between areas (1101, 1102)
2.5 Product Complaints and Records (1401)
3.0 Outstanding Task List / Action Plans
Inspection Task S/NS Corrective Action Date
Review of Outstanding task list (attach list from MCAP)
Review of Establishments' Action Plan

Observations/Comments:

Inspector's Signature :

Signature of Plant Management:

Chapter 3 - Enforcement & Compliance Actions

3.1 Scope

This Compliance and Enforcement Strategy provides a framework that outlines the principles and actions that will be followed by Canadian Food Inspection Agency (CFIA) inspectors in verifying that registered establishments operate in compliance with the Canada Agricultural Products Act (CAP Act), Honey Regulations (HR), and other applicable legislation. This program specific strategy is consistent with the CFIA's revised Enforcement and Compliance Policy developed and maintained by the Enforcement and Investigation Services (EIS) Directorate. The CFIA Enforcement and Compliance Policy provides the overarching policy for enforcement and compliance activities across all commodity programs.

Compliance is normally achieved through a co-operative approach between the regulated party and the CFIA in correcting non-conformities through the development of appropriate Corrective Action Plans or other methods. However, when this co-operative approach has ceased, or when the regulated party is incapable of correcting non-conformities, this Compliance and Enforcement Strategy provides CFIA staff with enforcement options that are to be used in responding to infractions of the Canada Agricultural Products Act (CAP Act), the Honey Regulations (HR) and other relevant applicable legislation. This policy also defines discretionary parameters for inspectors and establishes principles for fair and consistent enforcement.

3.2 Authorities

Canada Agricultural Products Act, R.S., c. 20
Honey Regulations, C.R.C., c. 287
Food and Drugs Act, R.S., c. F-27
Food and Drug Regulations, C.R.C., c. 870
Consumer Packaging and Labelling Act, R.S., c. 38
Consumer Packaging and Labelling Regulations, C.R.C., c. 417

All inspectors delivering the honey program must be designated under these acts.

3.3 Responsibility for Enforcement Actions

CFIA Area Executive Directors are accountable for enforcement actions taken in their respective Areas. They are also responsible for the approval of all recommendations to prosecute. The Regional Director must also be consulted and informed when significant enforcement actions are being considered. The Director, Food of Animal Origin Division, is responsible for enforcement actions taken in his/her respective area of concern including refusal, suspension and cancellation of certificates of registration. The accountability process for enforcement action is outlined in Chapter 15 of the Enforcement and Compliance Policy.

3.4 General Enforcment and Compliance Principles

The CFIA will encourage compliance with the CAP Act, HR and other applicable legislation through consultation, education and enforcement. These activities are based on the following guiding principles:

  • Honey and honey products in Canada must comply with applicable legislation;
  • Application and enforcement of the CAP Act, HR and other applicable legislation are to be carried out in a fair, consistent and uniform manner in accordance with this strategy and the CFIA's Enforcement and Compliance Policy;
  • CFIA inspectors, who are fully conversant with the CAP Act, HR and other applicable legislation, will conduct inspections, audits, compliance and enforcement and other regulatory activities;
  • CFIA inspectors will consider the facts and circumstances of non-compliance incidents with objectivity and take appropriate corrective action;
  • CFIA inspectors will take an active role in promoting and monitoring compliance and responding to non-compliance;
  • Education measures used to promote compliance will include the publication of information and consultation with regulated parties. CFIA inspectors administering and enforcing legislation and the regulated parties who must comply with the legislation, need to understand why legislation exists, why compliance is necessary, and how enforcement will be carried out; and
  • CFIA inspectors will be available to explain the requirements of the legislation and maintain open lines of communication to regulated parties and communicate to CFIA management the comments and concerns raised by the regulated parties.

3.5 Inspection Powers and Authorites

The following sub-sections identify the appropriate legal authorities that are available to inspectors designated under the CAP Act, the Honey Regulations, the Food and Drugs Act, and the Consumer Packaging and Labelling Act. Inspectors may only exercise powers under acts for which they are designated. An inspector must ensure he/she is designated under the appropriate act for the activity being undertaken.

3.5.1 Canada Agricultural Products Act (Sections 19 to 27)

The powers of the inspector are described in Sections 21 to 27 of the Canada Agricultural Products Act. The following table provides a summary of those sections. Inspectors are designated by the President of the CFIA pursuant to section 19, to enforce the provisions of the Canada Agricultural Products Act and the Honey Regulations.

Powers of Inspectors and Related Provisions - the Canada Agricultural Product Act
PROVISION - CAPA SECTION
a) Designation of Inspectors 19
b) Requirement for a certificate to be produced 19(2)
c) Provisions regarding obstruction, false statements and interference 19(4)
d) Provision that exempts removal, alteration or interference of things seized or detained 19(5)
e) Designation of methods and equipment 20
f) Power of entry 21(1)(a)
g) Power to open any container 21(1)(a)
h) Power to inspect and to take samples 21(1)(b)
i) Power to examine and make copies of documents and records 21(1)(c)
21(2) (a), (b) and (c)
j) Provisions regarding assistance to an inspector 21(3)
k) Power to enter a dwelling house 22(1), (2) and (3)
l) Requirement for a warrant to enter a dwelling house 22(1), 22(2) (a) (b) and (c) and 22(3)
m) Provision for assistance by a peace officer 22(4)
n) Power to seize and detain 23
o) Power to enter and search 24(1)
p) Provision to seize agricultural products or things in addition to those listed on a warrant in 24(1) 24(2)
q) Provision on timing of execution of warrant 24(3)
r) Provision to exercise powers without a warrant 24(4)
s) Provisions for storage and removal of seized articles 25(1)
t) Provision to dispose of or destroy 25(2)
u) Provisions for release of seized articles 26
v) Provisions for time limitations of detention - 180 days 27
w) Provision to require importer to remove from Canada 30(1)
x) Provision for product to be forfeited if not removed from the country within 90 days 30(2)

3.5.2 Honey Regulations

The powers of the Inspector, Director and Minister are described in various places in the Honey Regulations. The following table provides a summary of those sections Inspectors are designated by the President of the CFIA pursuant to section 19, to enforce the provisions of the Canada Agricultural Products Act and the Honey Regulations.

Powers of Inspectors and Related Provisions - the Honey Regulations
PROVISION - HR SECTION
a) Direct that honey be disposed of or destroyed - Inspector 4.3
b) Register the establishment - Director 10(2)
c) Suspend Registration - Director 12(1)
d) Cancellation of Registration - Director 13(1)
e) Require owner /operator to have an employee medically examined - Inspector 17(2)
f) Permit the sale of honey packed in novelty containers of non-standard sizes. - Minister 29(4)
g) Authorization of experimental use size containers - Minister 31
h) Grant an appeal inspection of honey - Director 40(1)
i) Affix a detention tag - Inspector 55(1)
j) Release detained product - Inspector 58

3.5.3 Food and Drugs Act (Section 23 to 27, A.01.026 of the Regulations)

The powers of the inspector are described in Sections 23 to 27 of the Food and Drugs Act. The following table provides a summary of those sections and section 22. Inspectors are designated by the President of the CFIA pursuant to section 22, to enforce the provisions of the Food and Drugs Act and Regulations, which now include the nutrition labelling requirements.

Powers of Inspectors and Related Provisions - Food and Drugs Act
PROVISION - FDA SECTION
a) Designation of Inspectors 22(1)
b) Requirement for a certificate to be produced 22(2)
c) Power of entry 23(1)
23(1)(a.1)
d) Power to enter a dwelling house 23(1.1)
e) Power to examine and to take samples 23(1)(a.1)
23(2)
f) Power to open container packages 23(1)(b)
g) Power to examine and make copies of documents 23(1)(c)
h) Power to seize and detain 23(1)(d)
i) Requirement for a warrant to enter a dwelling house 23(1.2)
23(1.3)
j) Provisions regarding obstruction, false statements and interference 24(1)
24(2)
k) Provisions for storage and removal of seized articles 25
l) Provisions for release of seized articles 26

3.5.4 Consumer Packaging and Labelling Act (section 13 to 17)

The powers of the inspector are described in Sections 13 to 17 of the Consumer Packaging and Labelling Act. The following table provides a summary of those sections. Inspectors are designated by the President of the CFIA pursuant to section 13, to enforce the provisions of the Powers of Inspectors and Related Provisions - Consumer Packaging and Labelling Act.

Powers of Inspectors and Related Provisions - the Consumer Packaging and Labelling Act
PROVISION - CPLA SECTION
a) Designation of Inspectors 13(1)
b) Requirement for a certificate to be produced 13(1)
c) Power of entry 13(2)
d) Power to examine prepackaged products 13(2)(a)
e) Power to open and examine any package 13(2)(b)
f) Power to examine and make copies of documents 13(2)(c)
g) Power to enter a dwelling house 13(2.2)
h) Requirement for a warrant to enter a dwelling house 12(2.2)
i) Provision for use of force and assistance of a peace officer 13(2.3)
21(2) (a), (b) and (c)
j) Provision to provide reasonable assistance to an inspector 13(3)
k) Provisions regarding obstruction, false statements and interference 14(1)
l) Provision that exempts removal, alteration or interference of things seized or detained 14(2)
m) Power to examine and sample 14(3)
n) Power to seize and detain and limitations 15(1), 15(2)
o) Notification to person of provision contravened 15(3)
p) Detention limitation 15(4)
q) Provisions for storage and removal of seized articles 15(5)
r) Provision for extension of detention 16(1), (20) (3) and (4)
s) Provisions for forfeiture 17(1)
t) Provision for forfeiture or other disposal on conviction 17(2)
u) Provisions for release of seized articles 17(3)

3.5.5 Indirect Powers

All three acts as referenced above require that reasonable assistance will be provided to an inspector, or any person acting under the authority of the inspector, by the owner or person in charge of a place, including a conveyance, and every person found in the place that is entered by an inspector. In addition, they will also provide the inspector with any information relevant to the administration of any of the CFIA's Acts.

3.5.6 Direct Powers

During the course of an inspection of a honey establishment, inspectors have the power and authority to respond to non compliance. They may:

  1. recommend withdrawal of registration (Section 12 of the Honey Regulations gives authority to the Director);
  2. seize and detain products or other things (CAP Act section 23 and FDA section 23(1)(d));
  3. restrict or prohibit the movement of products regulated by the CFIA (CAP Act 19 (5));
  4. order the removal of imports from Canada (CAP Act section 30(1));
  5. order the forfeiture of seized products not removed from country (CAP Act section 30(2)) - (to be exercised only after a review of the facts and a determination by appropriate managers that this is justified);
  6. order the disposal of products (CAP Act section 25(2)) -(to be exercised only after a review of the facts and a determination by appropriate managers that this is justified, or upon receipt of a court order and with consultation with appropriate CFIA management).

3.6 Responses to Non-Compliance

Where CFIA inspectors have reasonable grounds to believe there has been a contravention of the CAP Act, the HR or other applicable legislation, they will conduct inspections to determine the facts of the alleged infraction(s). Inspectors and Inspection Managers may seek the advice, guidance and assistance of the Enforcement and Investigation Services, Area Manager or Investigation Specialist, particularly in instances involving circumstances of a complex nature that require specialized investigational expertise. If the facts show that enforcement action is warranted, the inspector shall continue with completing the inspection, make detailed notes of activities and findings related to the non-compliance, copy relevant documents and take samples or photos as appropriate. The inspector shall place all of the relevant information and documents pertaining to the non-compliance in an incident file to be kept by the inspector in a secure place. Once non-compliance has been verified, the inspector will complete an Inspector Non-Compliance Report (CFIA /ACIA 5046 2000\08) along with copies of the supporting documents from the incident file and submit it to their Inspection Manager and Enforcement and Investigation Services. The Inspection Manager is responsible for initiating enforcement action. The Inspection Manager consults with the Area Operations Co-ordinator, Regional Operations Officers, Area Program Network Specialist and Area Program Network Director, who provide advice and guidance on program policies and guidelines. The Inspection Manager may also consult with the Enforcement and Investigation Services, Investigation Specialist, who can provide advice and guidance on enforcement policies, procedures and issues, to determine what enforcement action, if any, should be carried out.

Instances of non-compliance will be evaluated by Enforcement and Investigation Services, prior to proceeding with enforcement action. The following factors, along with other applicable information, will be considered when deciding upon the most appropriate action:

  • the offender's history of compliance with the legislation;
  • a willingness to achieve compliance;
  • evidence of corrective action taken;
  • the intent of the non-compliant party (alleged violator); and
  • the seriousness of harm or potential harm.

3.6.1 Warning

A written warning letter may be used in instances where the non-compliance is unintentional, easily corrected, the regulated party demonstrates due diligence and the individual or company has made reasonable efforts to remedy or mitigate the consequences of the contravention and compliance has been achieved.

3.6.2 Prosecution Action

Prosecutions shall be considered for offences under the Acts and regulations enforced by the CFIA except where, in accordance with the enforcement and compliance policy, it has been determined that:

  1. warning under this policy is the most effective means of achieving compliance; or
  2. registration suspension or cancellation is the most effective means of achieving compliance

If the offence involves the following, then prosecution may be pursued:

  1. death of, or injury to, a person and the evidence indicates that the death or injury was directly attributed to failure to comply with any of the provisions of the Acts or regulations administered and/or enforced by the CFIA;
  2. demonstrable harm or risk to the environment;
  3. risk to the health and safety of humans, animals or plants (propagated material)
  4. the prohibited sale of food;
  5. the unsafe manufacturing of food;
  6. economic fraud (i.e. economic adulteration);
  7. forging, altering or tampering with an inspection certificate/documents;
  8. knowingly providing false or misleading information, or making a false or misleading statement to an inspector;
  9. obstructing or interfering with an inspector exercising his/her powers or carrying out his/her duties and functions;
  10. removing, altering or interfering with any thing seized and detained or the movement of which is restricted or prohibited;
  11. producing records, documents or electronic data that knowingly contains false or misleading information;
  12. refusal to comply with the directions of an inspector, a detention order or a recall order; or
  13. a conviction for a previous similar offence, a repeated offence or a continuing offence.

The Acts administered by the CFIA allow offences to be prosecuted by either summary conviction or as an indictable offence. It is determined by the Crown prosecutor whether to prosecute by way of summary conviction or indictment.

3.6.3 Product Detention

Detention of product is considered one of the most expeditious and effective tools to promote compliance. An inspector has the authority, under Section 23 of the CAP Act, to seize and detain non-compliant agricultural products. The detention of agricultural products or other things is appropriate when a violation is suspected and when:

  1. the violation poses a health and safety risk;
  2. the violation creates unfair competition to other compliant products; or
  3. the person demonstrates an unwillingness to comply by failing to remove the product from the market or failing to take corrective action to bring the product into compliance.
  4. the product has been illegally imported into Canada (for the purposes of the Honey Regulations, this would apply to products in violation of section 47. Illegally imported products that cannot be brought into compliance would be detained and could be ordered removed from Canada pursuant to section 30 of the CAP Act. or
  5. the product is not in compliance with the CAP Act and/or HR.

Detention of the products can be maintained until:

  1. the product is brought into compliance, disposed of voluntarily or removed from Canada;
  2. court proceedings have been instituted; (Once court proceedings have been started, section 25(1)(b) no longer applies and the detention is maintained until the conclusion of the case and disposition of the detained product is decided by the court), or
  3. the statutory time limitation, if applicable, expires (Subsection 27(1), CAP Act allows for 180 days, unless legal proceedings have been initiated).

3.6.4 Forfeiture and Disposal

Forfeiture can occur in the following instances:

  1. where imported non-compliant products are not removed from Canada as instructed by an inspector (Section 30, CAP Act);
  2. when a person consents to forfeiture; or
  3. when the Court makes such an order (Section 29(1) , CAP Act)

Forfeited products will be disposed of as provided for by the Court, or as directed by the Minister where provided for in the Acts. This will be at the expense of the person from whom the product was seized.

The CAP Act (Section 29.(1) allows for the disposal of a seized product that have been forfeited. Municipal and Provincial jurisdiction regarding disposal of product will be respected.

3.7 De-Registration Situations

There are six circumstances where deregistration procedures will be considered:

  1. establishment closure, for reasons such as fire, flood but not including labour management disputes;
  2. failure to pay fees;
  3. critical problems of a public health significance;
  4. serious or continuous violations to the Act and/or Regulations;
  5. change in ownership that involves a change in management; or
  6. application for registration contains false and misleading information.

3.7.1 Establishment Closure

Where a registered establishment closes due to a decision of the operators and owners (e.g. bankruptcy), the responsible inspector will inform operations management and the Area Program Network Specialist. The Chief, Honey Program, must be informed as soon as possible by the Area Program Network staff. It is the inspector's responsibility to verify that the registration certificate is removed from the establishment. The Area Program Network Specialist will ensure that the establishment's management is informed of implications of the cancellation of the registration. (Appendix 1). The Client Management System (CMS) will be updated to indicate the inactive status of the establishment. The Area Program Network Specialist will ensure that the name and address of that establishment is removed from the central list of registered establishments. The registration number normally will be held (e.g. not re-issued) for a period of two (2) years to avoid any possible confusion.

3.7.2 Failure to Pay Annual Registration Fees

The Certificate of Registration remains in force for the 12 month period following issuance (Section 10(3) of the Honey Regulations). See also Chapter 1 - Section 1.5.5 (Registration Renewal Procedure).

If the renewal paperwork and payment are not received within 2 weeks of the expiration date, the Area Program Specialist may contact the Accounts Receivable office for follow up on invoice payment. The appropriate operations contact in each Region is advised of the pending late payment by the Area Program Network Specialist. The responsible inspector or his/her supervisor will contact (verbal or written) the establishment to remind them of the consequences of non renewal.

If the establishment wishes to renew the registration but the money is not received within 1 week of expiration date, the letter "Final Notice- Expiry of Registration" (Appendix 2) is sent to the establishment. If the application and payment are still not received within three weeks after the expiry date, a "Registration Expired" letter (Appendix 3) is issued to the establishment via registered mail (original copy), with copies sent to the appropriate contacts. Any payments received after the letter "Registration Expired" was sent out, will be deemed to be a new application for registration.

If, when contacted, the owner/operator indicates that he/she does not wish to renew the registration, (i.e. no longer producing products regulated under HR or not shipping inter-provincially) the inspector/supervisor will request confirmation in writing. This written confirmation will be forwarded to the Area Program Specialist so that a "Does Not Wish to Renew " letter (Appendix 4) can be prepared and sent out prior to the expiration date.

The Area Program Network Specialist updates CMS to indicate the inactive status of the establishment. The name and address of the establishment will be removed from the central list of registered establishments and the registration number will be held (not reissued) for a period of two (2) years.

3.7.3 Critical Deficiencies of Public Health Significance (Category I)

Where an inspection of a registered establishment determines that the Act and/or Regulations are being violated to the extent that there is a risk to public health and the operator fails or is unable, to take immediate corrective actions (as evidenced by an unacceptable follow up inspection), steps to suspend the registration will be taken (see section 3.8.2). Cancellation of registration procedures may also be initiated (see section 3.8.3).

3.7.4 Continuous Deficiencies to the Regulations (Category II and/or III)

Where an in-depth and follow-up inspection of a registered establishment results in an unsatisfactory rating (less than 75% Cat II and 65% Cat III), the documented results of the inspections may be used to suspend registration (see section 3.8.2)

3.7.5 Change in Owner/Operator

Section 11(2) of the Honey Regulations states that the certificate of registration cannot be transferred to any other person. Section 13(1)(b) gives the Director the authority to cancel the registration.

A change in owner/operator of the establishment requires that the existing registration be cancelled and a new application for registration be made. In this case, suspension of registration is not required prior to cancellation.

The non-transferability of registration should be stated to the new owners by the previous owners as the business transaction is being finalized. CFIA should be contacted by the new owners. However, when inspection staff become aware of a change in ownership after the fact, the new owners must be advised of the requirement for a new application for registration. This process will require procedures to be followed as outlined in Section 1.3 of Chapter 1. Normally, a new registration number is issued, however, the existing registration number may be retained upon agreement of the previous owner/operator. Inspection staff should advise the Area Program Network Specialist who will issue a letter "Change of Ownership" (Appendix 5) to the former owner(s)/operator(s) of the establishment.

3.7.6 False or Misleading Information on Application for Registration

If there is evidence that false or misleading information has been provided as part of the application for registration, the matter should be discussed with the Inspection Manager, Enforcement and Investigation Services and/or Legal Services.

When it is determined that the application for registration contains false and misleading information the certificate of registration shall be cancelled. In this case no suspension is required prior to cancellation.

3.8 Suspension and Cancellation of Registration

3.8.1 Subsection 12 (1), (2) and (3) of the Honey Regulations states:

12. (1) The Director may suspend the registration of a registered establishment

(a) where

(i) the establishment does not meet the requirements of the Act or these Regulations,

(ii) the operator does not comply with the provisions of the Act or these Regulations, or

(iii) it is reasonable to believe that public health will be endangered if the establishment is allowed to continue operating; and

(b) where the operator has failed or is unable to take immediate corrective measures to remedy any situation referred to in paragraph (a).

(2) No registration shall be suspended under subsection (1) unless

(a) an inspector has, at the time of an inspection, notified the operator of the existence of grounds for suspension under paragraph (1)(a);

(b) an inspector has provided the operator with a copy of an inspection report prepared by the inspector that sets out the grounds for suspension, the required corrective measures and the dates by which those measures must be implemented in order to avoid suspension and cancellation; and

(c) a notice of suspension of registration is delivered to the operator.

(3) A suspension of registration under subsection (1) shall remain in effect

(a) until the required corrective measures have been taken and have been verified by an inspector;

(b) where a cancellation procedure has been commenced under section 13, until the resolution of the cancellation issue.

Subsection 13 (1), (1.1) and (2) of the Honey Regulations states:

The Director may cancel the registration of a registered establishment where

(a) the operator has not implemented the required corrective measures within the 30-day period following the day on which the registration was suspended or within any longer period of time allowed under subsection (1.1);

(b) there is a change in ownership that involves a change of management of the establishment; or

(c) the application for registration contains false or misleading information.

(1.1) If it is not possible for the operator to implement the required corrective measures within 30 days, the Director shall, on the request of the operator, allow the operator a longer period of time that is adequate to implement those measures.

(2) No registration shall be cancelled under subsection (1) unless

(a) the operator was advised of an opportunity to be heard in respect of the cancellation and was given that opportunity; and

(b) a notice of cancellation of registration was delivered to the operator.

3.8.2 Steps for Suspension of Registration

For any unsatisfactory establishment inspection (in-depth, follow-up or directed/GMP) where the evidence shows that allowing the establishment to continue operating would constitute a public health hazard, or where repeated inspections and follow-ups demonstrate chronic inaction/non-compliance occurs, the following procedures must be followed:

  1. the Inspection Manager is consulted (by regional inspection staff) before suspension. It is the Inspection Manager's responsibility to notify senior CFIA management (area executive director, area program specialist, area network director, etc.).
  2. any product(s) posing a health and safety risk is (are) immediately detained; and any product on the market is evaluated for recall in conjunction with OFSR.
  3. all regulatory conditions required to suspend registration must be followed as indicated below (assistance and supervision by management/specialists is required):
Regulatory Conditions 12.(2)
Only the Director may suspend registration when all of the following conditions are met
Required Action
(Inspector and Management/Program team)
a) the inspector has, at the time of the inspection, notified the operator of the existence of grounds for suspension (this inspection must reflect current conditions in the establishment) During the exit meeting with management, the inspector(s) must review the inspection and highlight the unsatisfactory conditions (Chapter 2 - 2.4.3). Specific reference must be made to the unsatisfactory condition(s) for which suspension might be based (public health hazard and/or chronic inaction/non-compliance) and the regulatory conditions which are not met. The inspector must document the basic details to validate that this was done for his/her own record.
b) an inspector has provided the operator with a copy of an inspection report that sets out the grounds for suspension, the required corrective measures and the dates by which those measures must be implemented The MCAP Outstanding Task Worksheet, or the Directed/GMP Inspection Worksheet can be used as the basis for this requirement. (The team must decide in advance what minimum outstanding tasks must be corrected) For each of these tasks, the regulatory reference must be stated. A statement must be made stating that corrective measures are required, as well as a target date (within 30 days).
c) a notice of suspension of registration is delivered to the operator Once the above required conditions are documented, the HQ Chief/National Manager must be copied. A Notice of Suspension will be prepared for the Director - Food of Animal Origin Division's signature. This Notice (letter) will be personally delivered to the operator by the inspector or couriered for acceptance by the operator so delivery can be proven. (Appendix # 6).

Once an establishment is suspended other CFIA regions are notified so that interprovincial shipments of product can be monitored. If the establishment continues to operate within the province after suspension of registration, the appropriate CFIA officials responsible for non registered establishments and provincial and municipal authorities will be notified that the establishment no longer falls under federal registration requirements. If the party has labels that include such things as federal grades, or an establishment number, then they can no longer be used. It is important that those consequences of the suspension are stated in the notice/letter of suspension as well. At the time of suspension the Certificate of Registration must also be surrendered by the establishment.

The inspector verifies and documents whether the operator has taken the corrective measures required by the specified dates. If within 30 days of suspension (or other agreed upon time) the establishment does not correct the minimum outstanding tasks, then a member of the management/program team notifies the Director, Food of Animal Origin Division to initiate steps for cancellation of registration.

If the corrective measures required have been taken then suspension will be lifted and the certificate of registration is returned to the operator (Appendix 7).

3.8.3 Steps for Cancellation

3.8.3.1 Letter of Intent to Cancel

The Director, after consultation with Headquarter Officers and Area officials, will notify the Regional Executive Director to continue cancellation procedures. The inspection manager will send a letter to the operator of the establishment indicating that a recommendation for cancellation is being considered and arrangements will be made for a hearing prior to cancellation (Appendix 8). A mutually agreed-to location, date and time are set for the hearing and the establishment's management is advised in writing (Hearing Confirmation - Appendix 9). The establishment is informed that they have the right to bring legal representation or technical support.

3.8.3.2 Hearing

The CFIA will be represented at the hearing by the Director, Food of Animal Origin Division, or a designate, as well as appropriate supporting staff (e.g. inspector, program and supervisory representatives and a CFIA legal advisor, if required).

The hearing should be chaired by a neutral CFIA representative. The purpose of the hearing is to review the history of the case and reasons why or why not the registration should be cancelled.

3.8.3.3 Hearing Decision

At the end of the hearing, a recommendation will be made, choosing one of the following options:

(a) Cancellation of the registration.

(b) Suspension is lifted - company retains registration - certificate of registration is returned - An in-depth inspection should be carried out within one month.

(c) Other ( decision pending - e.g. additional inspection)

3.8.3.4 Notice of Cancellation

Once it has been decided to cancel the establishment's registration, a Notice/Letter of Cancellation of Certificate of Registration, will be signed by the Director, Food of Animal Origin Division and delivered to the operator (Appendix 10).

When the registration is cancelled, the operator of the establishment will not be allowed to apply a Canada grade, export any of their agricultural products, sell their graded agricultural products outside the province, or sell their graded product to an agent who may sell it outside the province. If an inspector has reason to believe that the operator of the deregistered establishment is in violation of the above criteria, a compliance verification inspection shall be undertaken. The inspector shall make detailed notes of activities and findings related to the non-compliance, copy relevant documents and take samples or photos as appropriate. Once non-compliance has been verified, the inspector will complete an Inspector Non-Compliance Report (CFIA/ACIA 5046 2000\08) along with copies of the supporting documents from the incident file and submit them to their Inspection Manager and Enforcement and Investigation Services.

3.8.3.5 Decision Not to Cancel - Lifting of Suspension

A letter notifying the operator of the decision not to proceed with cancellation of the registration will be sent from the Inspection Manager (Appendix 11) . The certificate of registration is returned to the operator. An in-depth inspection is performed within one month of commencement of production.

3.8.3.6 Other

This may include other options that the hearing committee may consider, such as another inspection, as a result of the review of the evidence that was presented at the hearing.

Appendix 1 - Covering Letter Example - Establishment Closure

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: CANCELLATION OF HONEY ESTABLISHMENT REGISTRATION - CLOSURE

Please be advised that due to the closure of your establishment, the registration for the federally registered establishment # XXXX to operate under the Honey Regulations (HR) is cancelled.

Federal registration is required for all establishments that prepare honey or honey products standardized under the HR, and trade internationally and/or interprovincially or carry a "Canada" grade mark. Should you wish to engage in any of these activities in the future a new application for registration must be made to your local CFIA office.

If you have not already done so please return the Certificate of Registration to your local CFIA office.

If you require further information and/or application forms, please do not hesitate to contact the undersigned or your local CFIA representative.

Yours truly,

Area Program Network Specialist

c.c.
Inspector
Operations Officer
Program Chief

Appendix 2 - Covering Letter Example - Final Notice - Expiry of Registration

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: EXPIRY OF HONEY ESTABLISHMENT REGISTRATION - FINAL NOTICE

Please be advised that the registration for your federally registered establishment to operate under the Honey Regulations (HR) expires on DATE. Federal registration is required for all establishments that prepare honey or honey products standardized under the HR and trade internationally and/or interprovincially or carry a "Canada" grade mark. Establishments that allow their registration to lapse, will lose their registration and subsequent trade privileges.

A renewal package which includes the necessary application forms and the current fee structure was previously sent to you. If it is your intention to maintain your registration, please notify us immediately and send a completed application and payment (cheque or money order payable to the Receiver General for Canada) to

Address of the Area Canadian Food Inspection Agency Office (CFIA)
Telephone Number

Establishments no longer requiring federal registration should also notify the Area Office at this time.

If you have any questions, please do not hesitate to contact the undersigned or your local CFIA representative for more information.

Yours truly,

Area Program Network Specialist

c.c.
Inspector
Operations Officer
Program Chief

Appendix 3 - Covering Letter Example - Registration Expired

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear Operator:

SUBJECT: CANCELLATION OF EXPIRED HONEY ESTABLISHMENT REGISTRATION

Please be advised that the registration for your federally registered establishment to operate under the Honey Regulations (HR) expired on DATE. As we have not yet received your renewal application for FISCAL YEAR, we are interpreting this as your intention to let your federal registration lapse. The name of your establishment and address are being deleted from our list of registered honey establishments.

The Honey Regulations states that federal registration is required for all establishments that prepare honey or honey products standardized under the HR and trade internationally and/or interprovincially or carry a "Canada" grade mark.

Violation of these regulations can result in the initiation of appropriate enforcement action by the Canadian Food Inspection Agency (CFIA).

If you require further information and/or application forms, please do not hesitate to contact the undersigned or your local CFIA representative.

Yours truly,

Area Program Network Specialist

c.c.
Inspector
Operations Officer
Program Chief

Appendix 4 - Covering Letter Example - Does Not Wish to Renew

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: CANCELLATION OF EXPIRED HONEY ESTABLISHMENT REGISTRATION

Please be advised that as per your request of DATE the registration for federally registered establishment #XXXX to operate under the Honey Regulations (HR) has been cancelled.

Federal registration is required for all establishments that prepare honey or honey products standardized under the HR and trade internationally and/or interprovincially or carry a "Canada" grade mark. Should you wish to engage in any of these activities in the future a new application for registration should be made to your local CFIA office.

If you have not already done so, please return the Certificate of Registration to your local CFIA inspection office.

If you have any questions, please do not hesitate to contact the undersigned or your local CFIA representative for more information.

Yours truly,

Area Program Network Specialist

c.c.
Responsible Inspector
Operations Officer
Program Chief

Appendix 5 - Covering Letter Example - Change of Ownership - sent to previous owner(s)

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: CANCELLATION OF HONEY ESTABLISHMENT REGISTRATION

Please be advised that the registration for federally registered establishment # XXXX to operate under the Honey Regulations (HR) is cancelled and cannot be transferred.

Section 11(2) of the Honey Regulations states that: "No operator shall transfer a certificate of registration to any other person and any purported transfer of a certificate of registration is void."

Section 13(1)(b) states that: "The Director may cancel the registration of a registered establishment where
(b) there is a change in ownership that involves a change of management of the establishment;

If you have not already done so please return the Certificate of Registration to your local CFIA inspection office.

If you have any questions, please do not hesitate to contact the undersigned or your local CFIA representative for more information.

Yours truly,

Area Program Network Specialist

c.c.
Inspector
Operations Officer
Program Chief

Appendix 6 - Covering Letter Example - Notice of Suspension

Hand Delivered or Couriered for Signature by Operator Area Address

159 Cleopatra Drive
Ottawa, Ontario
K1A 0Y9

Telephone: 613-773-2342
Facsimile:

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: NOTICE OF SUSPENSION OF REGISTRATION - ESTABLISHMENT NUMBER XXXX

The purpose of this letter is to advise you that the registration of establishment # XXXX, "name of establishment", is suspended as of DATE in accordance of section 12 (1) of the Honey Regulations.

A letter to you dated DATE from Inspector NAME outlined the infractions of the Honey Regulations pursuant to the Canada Agricultural Products Act found during an DATE inspection, a copy of this DATE inspection report having been provided to you. A subsequent inspection carried out on DATE which confirms that the majority of the infractions have not been corrected as indicated in the attached inspection report of DATE.

The suspension of your registration means that your company cannot trade honey interprovincially or internationally or apply the Canadian grade mark and registration number on product labels. At this time you will also be required to surrender your Certificate of Registration.

The suspension of you registration will remain in effect for 30 days or until the prescribed infractions are corrected and verified by an inspector, whichever comes first. A satisfactory verification will lead to the lifting of the suspension and the return of your Certificate of Registration. An unsatisfactory verification will lead to the initiation of cancellation of your registration.

If you need further clarification or information, please do not hesitate to contact NAME, Area Program Network Specialist.

Yours sincerely,


Director, Food of Animals Origin Division

c.c.
Executive Director
Program Network Director
Program Chief
Enforcement

Appendix 7 - Covering Letter Example - Lifting of Suspension

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: LIFTING OF SUSPENSION OF REGISTRATION - ESTABLISHMENT NUMBER #XXXX

The purpose of this letter is to advise you that the suspension of registration for establishment # XXXX "Name of Establishment", has been lifted and the Certificate of Registration will be returned to you.

An inspection carried out on DATE by Inspector NAME confirms that the required infractions have been corrected.

Your company can now resume interprovincial or international trade in honey and apply the Canadian grade mark on product labels.

If further clarification is required or if you need additional information, please do not hesitate to contact NAME , Area Program Network Specialist.

Yours sincerely,

Inspection Manager

c.c.
Inspector,
Operations Officer,
Program Network Specialist,
Executive Director,
Program Network Director,
Program Chief,
EIS/Legal

Appendix 8 - Covering Letter Example - Intent to Cancel

Hand Delivered or Couriered for Signature by Operator

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: INTENT TO CANCEL - HEARING CONVOCATION

The purpose of this letter is to advise you that CFIA is considering cancellation of the registration of establishment # XXXX, "name of establishment".

Subsequent to the suspension of registration dated DATE an inspection was carried out on DATE by inspector NAME. This inspection confirmed that the required infractions have not been corrected.

In view of the above, it is necessary to convene a hearing to discuss your establishment's registration. This will provide you and your representatives with an opportunity to be heard with respect to the cancellation.

Subsections 13 (1), 13(1.1) and 13(2) of the Honey Regulations state:

13.(1) The Director may cancel the registration of a registered establishment where

(a) the operator has not implemented the required corrective measures within the 30-day period following the day on which the registration was suspended or within any longer period of time allowed under subsection (1.1);

(1.1) If it is not possible for the operator to implement the required corrective measures within 30 days, the Director shall, on the request of the operator, allow the operator a longer period of time that is adequate to implement those measures.

(2) No registration shall be cancelled under subsection (1) unless
(a) the operator was advised of an opportunity to be heard in respect of the cancellation and was given that opportunity; and
(b) a notice of cancellation of registration was delivered to the operator.

If you wish to have a hearing, please contact the undersigned before DATE so that a place, date and time may be scheduled. Also, be advised that legal representation or technical support may accompany you to this hearing. If we do not receive notification by DATE it will be assumed that you do not wish to have a hearing, and a recommendation to cancel your registration will be forwarded to the Director, Food of Animal Origin Division..

If you have questions about any of the matters covered by this letter, please do not hesitate to contact me at 123-123-4567.

Sincerely,

Regional Director

c.c.
Inspector
Operations Officer
Program Network Specialist
Executive Director
Program Chief
EIS/Legal

Appendix 9 - Covering Letter Example - Hearing Confirmation

Hand Delivered or Couriered for Signature by Operator

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: HEARING CONFIRMATION

Thank you for your call / letter of DATE requesting a hearing to discuss the registration of your establishment and the maintenance of your registration under the Honey Regulations. Please be advised that you have the right to bring legal representation and/or technical advisors to this meeting.

It has been agreed that the hearing will be held at:
Office location
Room Number
on........................., at ........................... hrs.

Sincerely,

Regional Director

c.c.
Inspector
Operations Officer
Program Network Specialist
Executive Director
Program Chief
EIS/Legal

Appendix 10 - Hearing Decision - Notice of Cancellation

Hand Delivered or Couriered for Signature by Operator

159 Cleopatra Drive
Ottawa, Ontario
K1A 0Y9

Telephone: 613-773-2342
Facsimile:

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: Notice of Cancellation of Registration - Establishment Number XXXX

The purpose of this letter is to advise you that the registration of establishment # XXXX, "name of establishment", is suspended as of DATE in accordance of section 12 (1) of the Honey Regulations.

A letter to you dated DATE from Inspector NAME outlined the infractions of the Honey Regulations pursuant to the Canada Agricultural Products Act found during an DATE inspection, a copy of this DATE inspection report having been provided to you. A subsequent inspection carried out on DATE which confirms that the majority of the infractions have not been corrected as indicated in the attached inspection report of DATE.

The suspension of your registration means that your company cannot trade honey interprovincially or internationally or apply the Canadian grade mark and registration number on product labels. At this time you will also be required to surrender your Certificate of Registration.

The suspension of you registration will remain in effect for 30 days or until the prescribed infractions are corrected and verified by an inspector, whichever comes first. A satisfactory verification will lead to the lifting of the suspension and the return of your Certificate of Registration. An unsatisfactory verification will lead to the initiation of cancellation of your registration.

If you need further clarification or information, please do not hesitate to contact NAME, Area Program Network Specialist.


Yours sincerely,


Director, Food of Animals Origin Division

c.c.:
Executive Director
Program Network Director
Program Chief, Enforcement

Appendix 11 - Covering Letter Example - Hearing Decision - Lifting of Suspension

Area Address

Date

Operator Name
Name and Address of
registered establishment


2920-1- Reg. #

Dear NAME:

SUBJECT: LIFTING OF SUSPENSION OF REGISTRATION - ESTABLISHMENT NUMBER XXXX

The purpose of this letter is to advise you that the suspension of registration for establishment # XXXX "Name of Establishment", has been lifted and the Certificate of Registration will be returned to you.

An inspection carried out on DATE by Inspector NAME confirms that the required infractions have been corrected.

Your company can now resume interprovincial or international trade in honey and apply the Canadian grade mark on product labels.

If further clarification is required or if you need additional information, please do not hesitate to contact NAME , Area Program Network Specialist.

Yours sincerely,

Inspection Manager

c.c.
Inspector,
Operations Officer,
Program Network Specialist,
Executive Director,
Program Network Director,
Program Chief,
EIS/Legal

Appendix 12 - Deregistration Flow Diagram

Click on image for larger view
Deregistration Flow Diagram

Deregistration Flow Diagram

This flowchart shows the Deregistration Flow Diagram.

  • The process begins with an in-depth inspection and an exit meeting.

If the inspection is unsatisfactory:

  • If the in-depth inspection results indicates that public health may be endangered, a letter and report will be issued immediately and a follow up inspection will take place as soon as possible. At the completion of this follow up inspection there will be an exit meeting to discuss the results of the inspection.

    • If the results of this follow up inspection are satisfactory, Directed/Good Manufacturing Practice Inspections will continue as scheduled in the workplans
    • If not, see the directions below.
  • If the result of the in-depth inspection is unsatisfactory but does not indicate that public health is endangered, a letter and report will be issued within one week and a follow up inspection will take place within 30 days. At the completion of the follow up inspection there will be an exit meeting.

    • If the results of this follow up inspection are satisfactory, Directed/Good Manufacturing Practice Inspections will continue as scheduled in the workplans
    • If the results of this follow up inspection are not satisfactory both operations and programs are consulted. These consultations can results in:
      • No suspension - further actions or
      • Initiation of suspension. Once suspension is initiated,
        • A notice of suspension is issued by the Director
        • The operator is required to surrender of the certificate of registration
        • A follow up inspection takes place in 30 days (or another agreed upon time).

        * If the follow up inspection is satisfactory, the suspension will be lifted and the certificate of registration will be returned.

        * If the follow up inspection is unsatisfactory a Letter of Intent to Cancel and an Invitation to be Heard is issued by the responsible Inspection Manager. A hearing will be held with two possible outcomes:

        1) The suspension will be lifted and the certificate of registration will be returned. In this case an additional in-depth inspection will take place within one month

        2) There will be a decision to cancel, followed by a Notice of Cancellation issued by the Director

If the in-depth inspection is satisfactory:

  • There will be an exit meeting, and the establishment must provide a written corrective action plan addressing all infractions recorded during the inspection. Workplans require regularly scheduled Directed/Good Manufacturing Inspections. During these inspections, the inspector reviews progress being made to correct the identified infractions.

    • If the inspection shows ineffective corrective actions, this is brought to the attention of the establishment at an exit meeting and will result in further follow up.
    • If ineffective corrective actions result in possible public health endangerment there is consultation with operations and programs and the suspension process may be initiated.

Chapter 4 - Environmental Controls

4.1 Premises

4.1.1 Building Exterior

4.1.1.1 Outside Property and Building

1 Task

Principle

Buildings and surrounding areas are designed, constructed and maintained in a manner to prevent conditions which may result in the contamination of food.

Assessment Criteria

Grounds, Roadways and Drainage

  • The surrounding land is maintained to control sources of contamination such as debris and pest harborage areas.
  • The building is not located in close proximity to any environmental contaminants.
  • Roadways are properly drained, graded, compacted and appropriately treated to reduce dust.
  • The surrounding property is adequately drained.

Exterior Building Structure

  • The building exterior is designed, constructed and maintained to prevent entry of contaminants and pests (e.g. No unprotected openings, air intakes are appropriately located, and the roof, walls and foundation are maintained to prevent leakage).
Rating Examples

I

  • N/A

II

  • Exterior of building in poor condition allowing entry of pests.
  • Pest harborage areas and evidence of pest infestation inside the building.
  • Accumulation of garbage/waste resulting in obnoxious odours.

III

  • Inadequate drainage and pooling of water.
  • Exterior of building in poor condition and no signs of pest entry.
  • Roadways not properly graded, compacted, dust proofed or drained.
  • Pest harborage areas but no signs of pest entry.
Reference

4.1.2 Building Interior

4.1.2.1 Design, Construction, and Maintenance

101 Task

Principle

Building interiors and structures are designed, constructed and maintained in a manner to prevent conditions which may result in the contamination of food.

Assessment Criteria

Floor, Walls and Ceilings

  • Floors, walls, and ceilings are constructed of material that is durable, impervious, smooth, cleanable and suitable for the production conditions in the area.
  • Where appropriate, wall, floor and ceiling joints are sealed to prevent contamination and facilitate cleaning.
  • Floors, walls and ceilings are composed of materials that will not result in the contamination of the environment or food.
  • Floors are sufficiently sloped to facilitate the draining of liquids to trapped outlets.
  • Ceilings, overhead structures, stairs, and elevators are designed, constructed and maintained to prevent contamination.

Windows and Doors

  • Windows are sealed or equipped with close fitting screens.
  • Where there is a likelihood of breakage of glass windows that could result in the contamination of food, the windows are constructed of alternative materials or are adequately protected.
  • Doors have smooth, non-absorbent surfaces and are close fitting and self-closing where appropriate.

Process Flow Separation

  • Adequate separation of activities is provided by physical or other effective means where cross contamination may result.
  • Buildings and facilities are designed to facilitate hygienic operations by means of a regulated flow in the process from the arrival of the raw material at the premises to the finished product.
Rating Examples

I

  • Contamination (e.g. fiberglass insulation, broken glass etc.) directly over open product that has resulted in contamination of the product.

II

  • Windows and doors improperly sealed showing evidence of major infestation and contamination.
  • Flaking paint or rust on overhead structures and wall that has or may result in contamination.

III

  • Floors not properly sloped, and pooling of water.
  • Windows and doors improperly sealed and pest entry possible.
Reference

4.1.2.2 Lighting

102 Task

Principle

Adequate natural or artificial lighting should be provided throughout the establishment and all artificial lighting in production areas must be of a safety type and protected to prevent contamination of the food.

Assessment Criteria

Lighting is appropriate such that the intended production or inspection activity can be effectively conducted. The lighting does not alter food colour and should not be less than the following:

  • 540 lux (50 foot candles) in inspection areas (Container filling)
  • 220 lux (20 foot candles) in work areas (Extracting)
  • 110 lux (10 foot candles) in other areas (Storage rooms)

Inspection areas are defined as any point where the food product or container is visually inspected or instruments are monitored (e.g. empty container evaluation, product sorting and inspection).

Light bulbs and fixtures suspended over honey materials in any stage of production must be of a safety type and protected to prevent contamination of food in case of breakage.

Rating Examples

I

  • Remains of broken glass from lights over exposed food in production areas.

II

  • Unprotected lighting over exposed food in processing.
  • Lighting not sufficient to conduct process control activities (e.g. reading critical instruments).

III

  • Lighting below minimum requirements and process safety not affected.
Reference

4.1.2.3 Ventilation

103 Task

Principle

Adequate ventilation is provided to prevent excessive heat, steam, condensation and dust, and to remove contaminated air.

Assessment Criteria

Ventilation provides sufficient air exchange to prevent unacceptable accumulations of steam, condensation heat or dust.

Ventilation openings are equipped with close fitting screens or filters as appropriate to prevent the intake of pests and contaminants. Filters are cleaned or replaced as necessary.

Rating Examples

I

  • N/A

II

  • Inadequate ventilation resulting in contamination of the product (e.g. mould, condensation).

III

  • Inadequate ventilation, condensation/mould evident, contamination not likely.
  • Screens, filters not tight fitting.
  • Filters are not cleaned or replaced as necessary.
Reference

4.1.2.4 Waste Disposal

104 Task

Principle

Sewage, effluent and waste storage and disposal systems are designed, constructed and maintained to prevent contamination.

Assessment Criteria

Drainage and sewage systems are equipped with appropriate traps and vents.

Establishments are designed and constructed so that there is no cross-connection between the sewage system and any other waste effluent system in the establishment.

Effluent or sewage lines do not pass directly over or through production areas unless they are controlled to prevent contamination.

Adequate facilities and equipment are provided and maintained for the storage of waste prior to removal from the establishment. These facilities are designed to prevent contamination.

Containers used for waste are clearly identified, leak proof and where appropriate are covered.

Waste is removed and containers are cleaned and sanitized at an appropriate frequency to minimize contamination potentials.

Rating Examples

I

  • Sewage effluent backing up or leaking from overhead lines into food handling areas.

II

  • Uncontrolled drainage lines over production areas.

III

  • Cross connections identified between sewage and other waste effluent system(s).
  • Waste containers not clearly identified.
Reference

4.1.3 Sanitary Facilities

4.1.3.1 Employee Facilities

201 Task

Principle

Employee facilities are designed, constructed and maintained in such a manner that employees are encouraged to use proper hygiene in order to prevent contamination.

Assessment Criteria

Processing areas are provided with an adequate number of conveniently located hand washing stations with trapped waste pipes to drains.

Washrooms have hot and cold potable running water, soap dispensers, soap, sanitary hand drying equipment or supplies and a cleanable waste receptacle.

Washrooms, lunchrooms and change rooms are maintained in a clean condition.

Hand washing notices are posted in appropriate areas.

Rating Examples

I

  • N/A

II

  • Washroom and/or employee facilities are unclean.
  • No soap, no hot water for hand washing.

III

  • Direct access of washrooms off of production areas.
  • No handwash stations in production areas.
  • No hand washing notices.
Reference

4.1.3.2 Equipment Cleaning and Sanitizing Facilities

202 Task

Principle

Facilities and equipment for cleaning and sanitizing equipment are adequately designed, constructed and maintained to prevent contamination of food.

Assessment Criteria

Facilities and equipment are constructed of corrosion resistant materials capable of being easily cleaned and are provided with potable water at temperatures appropriate for the cleaning chemicals used.

Equipment cleaning and sanitizing facilities are adequately separated from food storage, processing and packaging areas to prevent contamination.

Rating Examples

I

  • N/A

II

  • Inadequate separation from food areas with a high risk of contamination with hazardous materials.

III

  • Inadequate separation from food areas but a low risk of contamination.
Reference

4.1.3.3 Bee Control

203 Task

Principle

Effective bee controls are in place to prevent entry, to eliminate bees in the production area and to prevent the contamination of food.

Assessment Criteria

There are effective bee controls in the premises to eliminate excessive bees in production area.

Rating Examples

I

  • N/A

II

  • N/A

III

  • Excessive bees in production area.
Reference

4.1.4 Water and Ice

4.1.4.1 Water and Steam Quality, Records and Program

301 Task

Principle

The potability of hot and cold water is controlled to prevent contamination.

Written records that adequately reflect control of water and steam quality and treatment are available upon request.

Assessment Criteria

Water meets the requirements of Health Canada's "Guidelines for Canadian Drinking Water Quality" and/or Provincial Public Health Standards for water. On site source water is analyzed by the establishment or municipality at a frequency adequate to confirm its potability (minimum annually).

There are no cross-connections between potable and non-potable water supplies or all hoses, taps and other similar sources of possible contamination are designed to prevent back-flow or back siphoning.

Where it is necessary to store water, storage facilities are adequately designed, constructed and maintained to prevent contamination (e.g. covered.)

Water treatment chemicals, where used, are listed in the "Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products", published by CFIA or the establishment has a "letter of no objection" from Health Canada.

The chemical treatment is monitored and controlled to deliver the desired concentration and to prevent contamination.

Recirculated water is treated, monitored and maintained as appropriate to the intended purpose. Recirculated water has a separate distribution system which is clearly identified.

The establishment has records available to demonstrate the adequacy of the microbiological and/or chemical safety of the water and steam supply as follows:

Water Potability Records

  • Water source
  • Sample site
  • Analytical results
  • Analyst
  • Date

Water Treatment Records

  • Method of treatment
  • Sample site
  • Analytical results
  • Analyst
  • Date

Boiler Feedwater Treatment Records

  • Method of treatment
  • Analytical results
  • Analyst
  • Date
Rating Examples

I

  • Non-potable water is used in production/wash-up areas.

II

  • Water does not meet the requirements of Health Canada's "Guidelines for Canadian Drinking Water Quality" or Provincial Public Health Standards for water.
  • Water is not tested at a frequency adequate to confirm its potability (minimum annually).
  • Cross-contamination of potable and non-potable water not controlled.
  • Use of non-approved chemicals for water treatment.

III

  • Water treatment chemicals not listed but not hazardous.
  • Records are incomplete.
Reference

4.2 Transportation and Storage

4.2.1 Transportation

4.2.1.1 Food Carriers

401 Task

Principle

Carriers used by the establishment are designed, constructed, maintained, cleaned and utilized in a manner to prevent food contamination.

Assessment Criteria

The establishment verifies that carriers are suitable for the transportation of food by ensuring that:

  • Carriers are inspected on receipt and prior to loading to ensure they are free from contamination and are suitable for the transportation of food.
  • There is a program in place to demonstrate the adequacy of cleaning and sanitizing (e.g. for bulk tankers -a written cleaning and sanitizing procedure is available).
  • Bulk tanks are designed and constructed to allow for complete drainage and to prevent contamination.
  • Where appropriate, materials used in carrier construction are suitable for food contact.
  • Carriers are loaded, arranged and unloaded in a manner that prevents damage to and contamination of the food.
  • Where the same carriers are used for food and non-food loads (e.g. dual use), procedures are in place to restrict the type of non-food loads to those that do not pose a risk to subsequent food loads after an acceptable clean out or to food loads in the same shipment the establishment should:
    • Receive a cleaning certificate and a record of the previous material transported prior to loading or unloading dual use tankers.
    • Have a program in place to verify the adequacy of cleaning (e.g. tanker inspections or analysis as appropriate).
Rating Examples

I

  • Tankers used for food and hazardous non-food materials, without cleaning certificate, no record of previous material transported and adequacy of cleaning not verified.

II

  • Tankers or carriers used for food and hazardous, non-food materials.
  • Use of tankers not adequately designed for complete drainage.

III

  • No cleaning certificate provided with tanker used for food and non-hazardous, non-food materials.
  • No program to verify adequacy of cleaning but cleaning certificate provided with tanker used for food and non-hazardous, non-food materials.
  • Inadequate inspection of carriers.
  • No inspection of carriers of bulk raw product.
Reference

4.2.1.2 Hand Carts and Dollies

402 Task

Principle

Hand carts and dollies used are designed, constructed, maintained, cleaned and utilized in a manner to prevent food contamination.

Assessment Criteria

Materials used in construction of hand carts and dollies are suitable.

Hand carts and dollies are properly maintained.

Dollies and carts must have restricted use in either the field or in the plant or there must be a program in place to demonstrate the adequacy of cleaning and sanitizing.

Rating Examples

I

  • N/A

II

  • Cross utilization of carts between field and plant with inadequate cleanings.

III

  • Carts and dollies not adequately cleaned to prevent contamination.
Reference

4.2.2 Storage

4.2.2.1 Non-Food Chemicals - Receiving and Storage

501 Task

Principle

Non-food chemicals are received and stored in a manner to prevent contamination of food, packaging materials and food contact surfaces.

Assessment Criteria

Chemicals are received and stored in a dry, well ventilated area.

Non-food chemicals are stored in designated areas such that there is no possibility for cross-contamination of food or food contact surfaces.

Chemicals are stored in clean, correctly labeled containers.

Non-food chemicals used in the establishment are listed in the "Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products", published by CFIA or the establishment has a "Letter of No Objection" from Health Canada.

Rating Examples

I

  • N/A

II

  • Hazardous non-food chemicals stored in an unlabeled container in a processing area.
  • No cleaning certificate provided with tanker used for food and non-hazardous, non-food materials.
  • Unacceptable non-food chemicals and/or materials received and/or stored.

III

  • Chemicals stored in corroded containers.
  • Storage conditions inadequate (e.g. damp or insufficient ventilation-not directly affecting finished product or equipment).
  • Storage of non-food chemicals in unlabeled containers.
  • Non-food chemicals are not stored in designated areas.
Reference

4.2.2.2 Ingredient and Packaging Material Storage EXCEPT Bulk Containers

502 Task ***REVISED JUNE 2009***

Principle

Storage and handling of incoming honey, ingredients, food additives/processing aids and packaging materials are controlled to prevent damage and contamination.

Note: See Task 505 for empty bulk container storage.

Assessment Criteria

Honey, ingredients, food additives/processing aids and packaging materials are stored and handled in the establishment in a manner to prevent damage and/or contamination.

Full bulk containers (e.g. drums, totes) of honey must be stored in a manner that prevents deterioration of the containers (e.g. stored inside) and prevents the entry of water and contaminants into the containers.

Ingredient, and where appropriate, packaging material rotation, is controlled to prevent deterioration and spoilage.

Humidity sensitive ingredients and packaging material are stored under appropriate conditions to prevent deterioration.

Rating Examples

I

  • N/A

II

  • Storage of damaged/improperly sealed honey containers (e.g. exposure of honey to contamination).
  • Storage of open/damaged containers of ingredients, food additives/processing aids and packaging materials.

III

  • Closed full bulk containers (e.g. drums, totes) of honey are stored outside with no/inadequate covering (e.g. tarpaulin) to prevent contamination. Note: Adjust corrective action time frames to achieve compliance in the short-term.
  • Inadequate rotation of ingredients or packaging material may result in possible deterioration or spoilage.
  • Incoming materials stored in an area where humidity may cause damage.
Reference

4.2.2.3 Finished Product Storage

503 Task

Principle

Finished products are stored and handled to prevent damage and contamination.

Assessment Criteria

Finished product is stored and handled under conditions to minimize deterioration (e.g. rusting or corrosion).

Finished product is stored and handled in a manner to minimize damage (e.g. control of stacking heights and forklift damage).

Rating Examples

I

  • N/A

II

  • N/A

III

  • Inadequate control of finished product handling (e.g. damaged containers evident).
Reference

4.2.2.4 Storage of Honey Supers

504 Task

Principle

Storage and handling of honey supers is controlled to prevent damage and contamination of the food.

Assessment Criteria

Honey supers are handled and stored in a manner to prevent damage and/or contamination.

Honey supers are maintained in a manner to prevent contamination of the food product.

Honey supers are rotated in an adequate manner as to prevent contamination of the food product and to minimize the spread of disease.

Rating Examples

I

  • N/A

II

  • Honey supers, which are placed in the extractor, are in poor condition (e.g. wood slivers, heavy peeling paint)
  • Improper storage or inadequate rotation of supers resulting in a potential for contamination (e.g. chemicals, veterinary drugs).

III

  • Improper handling and storage of supers resulting in a potential for contamination.
Reference

4.2.2.5 Storage of Empty Bulk Containers (e.g. drums, totes)

  • Incoming Empty Containers (e.g. used to pack honey)
  • Outgoing Empty Containers

505 Task ***REVISED JUNE 2009***

Principle

The establishment stores empty bulk containers such that no biological, chemical or physical hazards result in the food.

Assessment Criteria

All empty bulk containers (e.g. drums, totes) must be stored in a manner that prevents deterioration of the containers and prevents the entry of water and contaminants into the containers.

Empty bulk containers that are stored outside are properly closed, adequately covered and off the ground to prevent deterioration and contamination.

Residual honey from bulk containers is removed prior to storage to prevent pest harbourage.

Rating Examples

I

  • N/A

II

  • Open empty bulk containers (e.g. drums, totes) are stored with no/inadequate covering (e.g. tarpaulin) to prevent contamination.
  • Emptied bulk containers are stored without removing residual honey.

III

  • Closed empty bulk containers (e.g. drums, totes) are stored outside with no/inadequate covering (e.g. tarpaulin) to prevent contamination.
Reference

4.3 Equipment

4.3.1 General Equipment

4.3.1.1 Design, Installation and Maintenance

601 Task

Principle

All equipment is designed, constructed, installed and maintained to function as intended, to allow for effective cleaning and sanitation and to prevent contamination of food.

Assessment Criteria

Equipment is designed, constructed and installed to ensure that it is capable of delivering the requirements of the process. (Specific equipment design, construction and installation requirements are assessed under Sections 4.3.1.2, 4.3.1.3, 4.3.1.4, 4.3.1.5, 4.3.1.6, 4.3.1.7 et 4.3.2. All other equipment is assessed in this sub-section.)

Equipment is designed, constructed of food grade material and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Equipment is designed, constructed and installed to prevent contamination of the product during operations (e.g. location of lubricant reservoirs).

Where necessary, equipment is exhausted to the outside to prevent excessive condensation.

Equipment is designed, constructed and installed to allow for proper drainage and where appropriate, is connected directly to drains.

Cleaning and sanitizing equipment is designed for its' intended use and is properly maintained.

Rating Examples

I

  • N/A

II

  • Potential contamination of a chemical nature due to poor design/installation (e.g. by dripping of lubricants from bearings, gears, motors, and other overhead equipment).

III

  • Design, construction and/or installation does not allow for adequate cleaning, sanitizing, maintenance and inspection (e.g. equipment installed too close from walls and ceilings).
  • Improper drainage or exhaust of equipment.
  • Welded joints not even, continuous and smooth, use of lead solder in manufacture.
Reference

4.3.1.2 Honey Extractors

602 Task

Principle

All honey extracting equipment is designed, constructed, installed and maintained to function as intended, to allow for effective cleaning and sanitation and to prevent contamination of food.

Assessment Criteria

Equipment is designed, constructed of food grade material and installed to ensure that it is capable of delivering the requirements of the process.

Equipment is designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Food contact surfaces of equipment and utensils are smooth, non-corrosive, non-absorbent, non-toxic, free from pitting, cracks or crevices and can withstand repeated cleaning and sanitation.

Coatings, paints, chemicals, lubricants and other materials used for food contact surfaces or equipment where there is a possibility of contact with food are listed in the "Reference Listing of Accepted Construction, Packaging Materials and Non-Food Chemical Agents" published by CFIA or the establishment has a "Letter of No Objection" from Health Canada.

Rating Examples

I

  • N/A

II

  • Use of non approved material and hazard from such material is not known or documented.
  • Potential contamination of a chemical nature due to poor design/installation (e.g. by dripping of lubricants from bearings, gears, motors, and other overhead equipment).

III

  • Design, construction and/or installation does not allow for adequate cleaning, sanitizing, maintenance and inspection (e.g. equipment installed too close from walls and ceilings).
  • Improper drainage or exhaust of equipment.
  • Welded joints not even, continuous and smooth.
  • Use of coatings, paints not listed in the CFIA reference listing or reviewed by Health Canada or known to be non-hazardous.
Reference

4.3.1.3 Honey Sump

603 Task

Principle

Honey sumps are constructed of appropriate materials and are maintained in a manner to prevent contamination of food.

Assessment Criteria

Food contact surfaces of equipment and utensils are smooth, non-corrosive, non-absorbent, non-toxic, free from pitting, cracks or crevices and can withstand repeated cleaning and sanitation.

Coatings, paints, chemicals, lubricants and other materials used for food contact surfaces or equipment where there is a possibility of contact with food are listed in the "Reference Listing of Accepted Construction, Packaging Materials and Non-Food Chemical Agents" published by CFIA or the establishment has a "Letter of No Objection" from Health Canada.

Equipment is designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Equipment is designed, constructed of food grade material and installed to prevent contamination of the product during operations (e.g. covers on sumps).

Rating Examples

I

  • N/A

II

  • Use of non approved material and hazard from such material is not known or documented.
  • Consistent contamination due to poor design/installation and maintained (e.g. no cover when required).

III

  • Design, construction and/or installation does not allow for adequate cleaning, sanitizing, maintenance and inspection.
  • Surfaces are pitted, cracked, absorbent.
  • Use of coatings, paints not listed in the CFIA reference listing or reviewed by Health Canada or known to be non-hazardous.
Reference

4.3.1.4 Honey Dump / Melting Tanks

604 Task

Principle

Honey dump tanks/melting tanks are constructed of appropriate materials and are maintained in a manner to prevent contamination of food.

Assessment Criteria

Tanks are designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Tanks are designed, constructed of food grade material and installed to prevent contamination of the product during operations.

Rating Examples

I

  • N/A

II

  • Consistent contamination due to poor design, installation and maintenance (e.g. no cover when required).
  • Potential contamination due to poor design and installation.

III

  • Design, construction and/or installation does not allow for adequate cleaning.
  • Welded joints not even, continuous and smooth.
  • No covers on tanks.
Reference

4.3.1.5 Honey Heat Treatment Equipment

605 Task

Principle

Adequate equipment for rapid controlled heating/cooling for liquefying honey without scorching or impairing colour, flavour or cleanliness and maintained in a manner to prevent contamination of food.

Adequate equipment for heating and cooling is sufficient so that the honey is free of viable sugar tolerant yeasts without scorching or impairing colour, flavour or cleanliness and maintained in a manner to prevent contamination of food (pasteurizing establishments).

Assessment Criteria

Equipment and instruments are designed, constructed of food grade material and installed to ensure that it is capable of delivering the requirements of the process.

The rapid controlled application of heating and cooling is sufficient so that the honey is free of viable sugar tolerant yeasts (time and temperature controls).

Equipment and instruments are designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Equipment and instruments are designed, constructed and installed to prevent contamination of the product during operations.

Where used, other temperature/measuring devices are installed calibrated and maintained as necessary to ensure accuracy.

The establishment uses one temperature scale consistently throughout the processing system (e.g. Celsius or Fahrenheit).

Rating Examples

I

  • N/A

II

  • N/A

III

  • Design, construction and/or installation does not allow for adequate cleaning, sanitizing, maintenance and inspection (e.g. equipment installed too close to walls and ceilings).
  • Welded joints not even, continuous and smooth.
  • Pressure gauges are inaccurate.
  • No verification that the honey is free from viable sugar tolerant yeasts.
  • Measuring instruments not calibrated on a minimum annual basis (e.g. thermometers).
  • Calibration using a standard of unknown accuracy.
Reference

4.3.1.6 Hand Tools/Utensils

606 Task

Principle

All utensils are designed and constructed to function as intended, to allow for effective cleaning and sanitation and to prevent contamination of food.

Assessment Criteria

Food contact surfaces of utensils are smooth, non-corrosive, non-absorbent, non-toxic, free from pitting, cracks or crevices and can withstand repeated cleaning and sanitation.

Rating Examples

I

  • N/A

II

  • Utensil design and maintenance may result in contamination of the product.

III

  • Utensils are pitted, cracked or absorbent.
Reference

4.3.1.7 Filters

607 Task

Principle

All filters are designed, constructed and installed to function as intended, to allow for effective cleaning and sanitation and to prevent contamination of food.

Assessment Criteria

Canada No.1 requires that honey is free from any foreign material that would be retained on a U.S. National Bureau of Standards standard 80-mesh screen.

Canada No.2 requires that honey is free from any foreign material that would be retained on a U.S. National Bureau of Standards standard 60-mesh screen.

Equipment is designed, constructed of food grade material and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Rating Examples

I

  • N/A

II

  • Potential contamination may occur due to poor design/installation/maintenance.

III

  • Design, construction and/or installation does not allow for adequate cleaning, sanitizing, maintenance and inspection.
  • Welded joints not even, continuous and smooth.
Reference

4.3.1.8 Equipment Maintenance and Calibration Programs and Records

608 Task

Principle

An effective maintenance and calibration program is in place to ensure that equipment performs consistently as intended and prevents contamination of the food.

Records are available to demonstrate adherence to the maintenance and calibration program for equipment.

Assessment Criteria

The establishment has an effective written preventative maintenance and calibration program to ensure that equipment and instruments function as intended.

This program must include:

  • A list of equipment requiring regular maintenance and calibration.
  • The maintenance and calibration procedures and frequencies (e.g. equipment inspection, adjustments and part replacements) are based on the equipment manual or equivalent effective frequencies.
  • Equipment is maintained to ensure that no physical or chemical hazard potentials result (e.g. inappropriate repairs, flaking paint and rust, excessive lubrication).
  • Maintenance and calibration of equipment is performed by appropriately trained personnel.

The typical information expected in maintenance and calibration records for equipment:

  • Identification of equipment
  • Maintenance activity
  • Date, person
  • Reason for activity
  • Calibration results and corrective action as required
Rating Examples

I

  • N/A

II

  • Improper or no maintenance for critical equipment which may result in contamination (e.g. glass filler/capper).

III

  • Incomplete equipment maintenance and calibration program (e.g. missing frequencies for equipment).
  • No written equipment maintenance and calibration program.
  • Improper or no maintenance and calibration for equipment.
  • Equipment not functioning as intended.
  • Information in maintenance records not complete.
  • Absence of records.
Reference

4.3.2 Pre-Process Equipment

4.3.2.1 Preparation/Blending Equipment and Instrumentation

701 Task

Principle

Preparation and blending equipment is designed, installed and maintained to function as intended, to allow for effective cleaning and sanitation and to prevent contamination of the product during operations.

Assessment Criteria

Equipment and instruments are designed, installed, as necessary to ensure that they function as intended. The following are some examples of instrumentation that may be used for preparation/blending equipment to control factors in the process:

Mercury in Glass (MIG) thermometers, temperature recorders, other temperature measuring devices

  • Equipment is designed, installed, and maintained in accordance to the equipment manual.

Scales and Meters

  • Equipment is designed, installed, and maintained in accordance to the equipment manual.

Other Instrumentation

  • Other specialized instrumentation necessary (e.g. refractometer, honey colour classifier).
Rating Examples

I

  • N/A

II

  • Equipment maintenance and operation may result in contamination of the product during operations.

III

  • Equipment and instruments are not designed, installed, and maintained as necessary to ensure that they function as intended.
Reference

4.3.2.2 Honey Uncapping Devices

702 Task

Principle

All equipment and utensils are designed, constructed, installed and maintained to function as intended, to allow for effective cleaning and sanitation and to prevent contamination.

Assessment Criteria

Equipment is designed constructed of food grade material, installed and maintained to ensure that it is capable of delivering the requirements of the process.

Equipment is designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Equipment is designed, constructed and installed to prevent contamination of the product during operations.

Food contact surfaces of equipment and utensils are smooth, non-corrosive, non-absorbent, non-toxic, free from pitting, cracks or crevices and can withstand repeated cleaning and sanitation.

Rating Examples

I

  • N/A

II

  • Equipment maintenance and operation may result in contamination of the product during operations.

III

  • Surfaces are pitted, cracked, absorbent (e.g. wood scratching boards).
Reference

4.3.3 Post-Process Equipment

4.3.3.1 Metal Detector

901 Task

Principle

Metal detecting equipment is designed, constructed, installed and maintained such that the equipment is capable of delivering the required process.

Assessment Criteria

Metal detection equipment is designed , installed and maintained in accordance with the equipment manual This may include:

  • Timing of the reject mechanism
  • Suitability for environmental conditions
  • Observation of calibration check
Rating Examples

I

  • N/A

II

  • Metal detector is not functioning effectively.

III

  • Metal detector is not installed correctly.
Reference

4.3.3.2 Honey Holding Tanks

902 Task

Principle

Honey holding tanks are constructed of appropriate materials and are maintained in a manner to prevent contamination of food.

Assessment Criteria

Tanks are designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Tanks are designed, constructed of food grade material and installed to prevent contamination of the product during operations (e.g. covers on tanks).

Rating Examples

I

  • N/A

II

  • Unacceptable covers or covers absent on tanks that may result in contamination of the product during operations.
  • Potential contamination due to poor design/installation.
  • Use of interior coating which is not listed as accepted for food contact in the "Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products", published by CFIA or the establishment has "Letter of No Objection" from Health Canada.
  • Interior coating flaking with visible contamination of the honey.

III

  • Design, construction and/or installation does not allow for adequate cleaning.
  • Welded joints not even, continuous and smooth.
  • Unacceptable covers or covers absent on tanks.
Reference

4.3.3.3 Wax Removal

903 Task

Principle

Wax handling equipment is designed, constructed, installed and maintained such that the equipment is capable of delivering the required process to prevent contamination of food.

Assessment Criteria

Equipment is designed, constructed of food grade material, installed and maintained to ensure that it is capable of delivering the requirements of the process.

Equipment is designed, constructed and installed to be accessible for cleaning, sanitizing, maintenance and inspection.

Rating Examples

I

  • N/A

II

  • Potential contamination of a chemical nature (e.g. residues in barrels, damaged coatings, leaking heat exchanger tubing).

III

  • Equipment not easy to dismantle.
  • Improper drainage of equipment.
  • Welded joints not even, continuous and smooth.
Reference

Honey Regulations: Sections 16(f), 4.1(1).

4.3.3.4 Container Filling - Honey Filling Equipment

904 Task

Principle

Filling equipment is designed, constructed, installed and maintained such that the equipment is capable of delivering the required process to prevent contamination of food.

Assessment Criteria

Filling equipment is designed, constructed of food grade material, installed and maintained such that the equipment is capable of delivering the required process to prevent contamination of food.

Rating Examples

I

  • Equipment maintenance and operation results in contamination of the product during operations (e.g. glass).

II

  • Potential contamination from extraneous material.

III

  • Design, construction and/or installation does not allow for adequate cleaning.
  • Equipment not easy to dismantle.
Reference

4.4 Personnel

4.4.1 Training

4.4.1.1 General Training

1001 Task

Principle

Every food handler is trained in personal hygiene and hygienic handling of food and operation of equipment such that they understand the precautions necessary to prevent the contamination of food.

Assessment Criteria

The establishment has a written training program for employees which is delivered as follows:

  • Appropriate training in personal hygiene.
  • Appropriate training in hygienic handling of food and operation of equipment is provided to all food handlers at the beginning of their employment.
  • The training is reinforced and updated at appropriate intervals (e.g. new and modified equipment or processes).
Rating Examples

I

  • N/A

II

  • No training program and evidence of unacceptable employee practices.

III

  • No training updates conducted.
  • No written program.
Reference

4.4.2 Hygiene and Health Requirement

4.4.2.1 Cleanliness and Conduct

1101 Task

Principle

All persons entering food handling areas maintain an appropriate degree of personal cleanliness and take the appropriate precautions to prevent the contamination of food.

Assessment Criteria

All persons wash their hands upon entering food handling areas, before starting work, after handling contaminated materials, after breaks and after using washroom facilities.

Protective clothing, hair covering, footwear and/or gloves, appropriate to the operation in which the employee is engaged, are worn and maintained in a sanitary manner (e.g. employees in production areas wear effective hair coverings).

Any behavior which could result in contamination of food, such as eating, use of tobacco, chewing gum, or unhygienic practices (sneezing, spitting) are prohibited in food handling areas.

All persons entering food handling areas remove jewelry and other objects which may fall into or otherwise contaminate food. Jewelry which cannot be removed, including wedding bands and medical alerts are covered.

Upon entering food handling areas all field protective clothing will be covered or replaced with clean clothing.

When employees have changed into protective clothing street clothing is not to be kept in food handling areas. Personal effects shall not be stored in food handling areas.

Access of personnel and visitors is controlled to prevent contamination. The traffic pattern of employees prevents cross-contamination of the product.

Rating Examples

I

  • N/A

II

  • Employees not washing their hands upon entering food handling areas, before starting work, after handling contaminated materials, after breaks or after using toilet facilities.

III

  • Personal effects at the work station.
  • Personnel wearing jewelry (e.g. earrings, watches, etc.).
  • Uncontrolled visitor access.
  • Unclean or unacceptable clothing in food handling areas.
  • Employees exhibiting behavior which could result in contamination of food.
Reference

4.4.2.2 Communicable Diseases and Injuries

1102 Task

Principle

No person while known to be infected with a disease likely to be transmitted through food, or with open cuts or wounds, is permitted to work in food handling areas where there is a likelihood of such a person directly or indirectly contaminating the food.

Assessment Criteria

The establishment has and enforces a policy to prevent personnel known to be suffering from, or known to be carriers of a disease transmissible through food, from working in food handling areas.

The establishment requires that employees advise management when they are suffering from a communicable disease likely to be transmitted through food.

Employees having open cuts or wounds do not handle food or food contact surfaces unless the injury is completely protected by a secure waterproof covering (e.g. rubber gloves).

Refer to Appendix 2 for further details.

Rating Examples

I

  • N/A

II

  • Employees working with open cuts and wounds while handling food.
  • Employees working with uncovered dressings/bandages while handling food.

III

  • The establishment does not have a policy to prevent personnel known to be suffering from, or known to be carriers of a disease transmissible through food, from working in food handling areas.
Reference

4.5 Sanitation and Pest Control

Sanitation

4.5.1.1 Sanitation Program and Records

1201 Task

Principle

An effective sanitation program and records for equipment and premises is in place to prevent contamination of food.

Assessment Criteria

The establishment has a written cleaning and sanitation program for all equipment which includes:

  • The identification of responsible person.
  • The frequency of the activity.
  • Chemicals and concentration when used.
  • Temperature requirements.
  • Potable hot water may be the sole agent used for cleaning and/or sanitizing equipment.
  • Procedures for cleaning and sanitizing as follows:
    • Cleaned Out Of Place Equipment (C.O.P. e.g. hand-cleaned)
      • Identify equipment and utensils.
      • Disassembly/reassembly instructions as required for cleaning and inspection.
      • Areas on equipment requiring special attention are identified.
      • Method of cleaning, sanitizing and rinsing.
    • Cleaned In Place Equipment
      • Identify lines and/or equipment.
      • CIP setup instructions.
      • Method of cleaning, sanitizing and rinsing.
      • Disassembly and reassembly instructions as required for cleaning and inspection.

The establishment has a written cleaning and sanitation program for premises (production and storage areas) which specifies areas to be cleaned, method of cleaning, person responsible and the frequency of the activity.

Special sanitation and housekeeping procedures required during production are specified within the document (e.g. removal of product residues during breaks).

Accepted chemicals are used in accordance with the manufacturers instructions.

The sanitation program is carried out in a manner that does not contaminate food or packaging materials during or subsequent to cleaning and sanitizing (e.g. aerosols, chemical residues).

The records of sanitation activities include the date, person responsible, the findings, corrective action taken, and microbiological test results where appropriate.

Effectiveness of the sanitation program is monitored and verified (e.g. by routine inspection of premises and equipment and/or microbiological testing) and where necessary, the program is adjusted accordingly.

Operations begin only after sanitation requirements have been met.

Rating Examples

I

  • N/A

II

  • Improper use of cleaning chemicals with a high risk of food contamination.
  • Improper rinse of filter after cleaning, resulting in contamination of product with concentrated cleaning material.

III

  • No written sanitation program.
  • No sanitation records.
  • Monitoring program not in place.
  • Isolated instance of missing information on a daily sanitation record.
  • Incomplete sanitation program or records.
Reference

4.5.1.2 Premises Cleanliness

1202 Task

Principle

The sanitation program is being followed so that the interior of the building and all other physical facilities are maintained in a sanitary and tidy condition that prevents contamination of food.

Assessment Criteria

The establishment maintains the building and physical facilities in a clean and sanitary manner:

  • The interior premises is kept free of debris and refuse.
  • Floor, wall and ceiling surfaces are maintained in a sanitary manner, free from accumulations of food particles, dust, grease, wax and propolis.

Sanitation is carried out in a manner that does not contaminate food or packaging materials.

Rating Examples

I

  • N/A

II

  • Inappropriate/poor sanitation practice that results in contamination of food or packaging materials.

III

  • Build up of wax and propolis on interior structure.
  • Excess equipment (frames, supers, tools, parts) stored in production areas.
  • Poor housekeeping practices.
  • Poor sanitation practices (e.g. splashing of wash up water).
  • Unclean overhead beams throughout the plant.
  • Inadequate separation of activities where a potential for contamination may result.
Reference

4.5.2 Pest Control

4.5.2.1 Pest Control Program and Records

1301 Task

Principle

Effective pest control programs are in place to prevent entry, detect and eliminate pests and to prevent the contamination of food and accurate records are kept.

Assessment Criteria

There is an effective written pest control program for the premises and equipment that includes:

  • The identification of the person at the establishment assigned responsibility for pest control.
  • Where applicable, the name of the pest control company or the name of the person contracted for the pest control program.
  • The list of chemicals used, the concentration, the location where applied, method and frequency of application.
  • A map of trap locations.
  • The type and frequency of inspections to verify the effectiveness of the program (e.g. area is inaccessible to determine the effectiveness of the pest control program).
  • The records to include the date, person responsible, the findings and corrective action taken.

Pesticides used are registered under the Pest Control Products Act and Regulations and are listed in the "Reference Listing of Accepted Construction, Packaging Materials and Non-Food Chemical Agents" published by CFIA or has a "Letter of No Objection" from Health Canada. Pesticides are used in accordance with the label instructions.

Treatment of equipment, premises or ingredients to control pests is conducted in a manner to ensure that the maximum residue limit of the Food and Drugs Act and Regulations is not exceeded (e.g. limiting the number of fumigation treatments per lot).

Birds and animals are excluded from establishments.

Pallets and materials are stored at a sufficient distance from the wall to avoid potential harbourage of pests.

Rating Examples

I

  • Major infestation resulting in contamination.

II

  • Major infestation with a high risk of contamination.
  • Pesticide used inappropriately and risk of direct contamination (e.g. spraying during operation).

III

  • Absent or incomplete written pest control program.
  • Absent or incomplete pest control records.
  • Pesticides not listed in the "Reference Listing of Accepted Construction, Packaging Materials and Non-Food Chemical Agents" published by CFIA and does not have a "Letter of No Objection" from Health Canada.
  • Low level infestation.
  • The type and frequency of pest control inspections cannot be adequately assessed (e.g. area is inaccessible to determine the effectiveness of the pest control program).
  • Pallets and materials stored too close to walls - possible harbourage.
Reference

4.6 Complaints and Recalls

4.6.1 Complaint Handling

4.6.1.1 Product Complaints and Records

1401 Task

Principle

The establishment has an effective well documented system for handling and investigating complaints to prevent reoccurrence and ensure compliance to the regulations.

Assessment Criteria

The manufacturer has a system to handle and investigate product complaints as follows:

  • The manufacturer has identified the person or persons responsible for receiving, evaluating, categorizing and/or investigating complaints.
  • Complaints are accurately categorized according to health and safety risks.
  • Potentially serious complaints are forwarded immediately to appropriate personnel for action.
  • Safety and contamination complaints are investigated by trained personnel.
  • Examination of the complainant's specimen, retail product or other product of the same code is conducted on complaints related to food safety.
  • The depth of the investigation is appropriate to the risk and similar complaint trends.

Appropriate corrective action is taken for deviations identified during the investigation.

The establishment maintains detailed records of all complaints received, investigation findings and corrective action taken. The minimum information required for complaint records are as follows:

  • Complainant Information
    • Name, address, telephone number, date received
    • Details of complaint and/or illness
    • Product name, code and size
    • Retail outlet
    • Corrective action taken to prevent recurrence
  • Investigation results
    • Name of responsible person
    • Date
    • Findings
    • Corrective action taken
    • Indication of whether recall action has been initiated or not
Rating Examples

I

  • N/A

II

  • Complaints affecting food safety (e.g. illness, glass, metal etc.), are not referred to appropriate personnel for action.
  • Potentially serious complaints are not investigated promptly.
  • No records of investigations of health and safety complaints.
  • No record of corrective action taken on health and safety complaints.

III

  • Records are incomplete but there is sufficient information to verify the adequacy of complaint investigation (e.g. complainant name, address, date, retail outlet, etc.).
  • No records of complaints.
  • No records of investigations of non-health and safety complaints.
  • No record of corrective action taken to prevent recurrence.
Reference

4.6.2 Recall System

4.6.2.1 Recall Plan, Capability and Records

1501 Task

Principle

Every food establishment has a written plan to facilitate the complete and rapid recall of any lot of food from the market.

Assessment Criteria

The establishment is capable of producing accurate information on a timely basis to verify that all affected product can be rapidly identified and removed from the marketplace.

There are ten basic elements which should be included in your recall plan. All of these elements must be included, each element plays a specific role and provides a different benefit.

  1. Recall Management Team
    • Including after hours contact information
  2. Complaint File
  3. Recall Contact List
    • Including notification of CFIA
  4. Tracing of Raw Ingredients, Packaging Materials and Finished Products
  5. Product Amounts
  6. Distribution Records
    The following minimum information is required for distribution records:
    • Product identification and size
    • Lot number or code
    • Quantity
    • Customer names, addresses, and phone numbers (home and work) to the initial level of product distribution
  7. Recalled Product Records
  8. Recall Procedures
    • Methods to identify, locate and control recalled product
  9. Recall Effectiveness Procedures
  10. Testing the Recall Plan (internal mock recall)
Rating Examples

I

  • N/A

II

  • Recall procedures tested and found not to be effective. No corrective action taken.
  • No distribution records.

III

  • Incomplete or no written recall procedure.
  • Information on distribution records incomplete.
  • No testing of recall system.
Reference

4.6.2.2 Product Code Identification

1502 Task

Principle

Each prepackaged and bulk container is identified with code marks or lot numbers on the label, case or container.

Assessment Criteria

Each label, case or container shall have permanent, legible code marks or lot numbers.

Code marks used and the exact meaning of the code is available.

Where used, case codes are legible and represent the container code within.

Rating Examples

I

  • N/A

II

  • N/A

III

  • Case code does not coincide with container code.
  • No code, illegible code.
Reference
  • Honey Regulations: Sections 21(1)(a)(i),(ii) and (iii), 21(2), 26(1) and (2), 27(1),(2),(3) and (4), 36(1)(f).
  • Appendix 7 - Recall Program.

4.7 Records

4.7.1 General Records

4.7.1.1 Glass Breakage Procedures and Records

1601 Task

Principle

The establishment has an effective glass breakage control procedure developed for their operation.

Records of glass breakage are maintained and are available upon request.

Assessment Criteria

The manufacturer has a written procedure developed for each line where glass is used (related to the speed of the line, the jar size).

The glass breakage procedure specifies:

  • Who is responsible
  • The line where it applies
  • The immediate action to initiate when a glass breakage occur (e.g. stop the line
  • The number of jars to reject from the line (e.g. empty jars, filled jars, closed jars) depending on where the breakage occurs
  • The cleaning procedure of the piece of equipment or conveyor and surrounding area where the breakage occurred (e.g. cleaning material to use)
  • Evaluation of the cause of breakage
  • Disposal of the glass/jars and affected product

The glass breakage procedure has to be available to the production employees.

Any other glass breakage occurrences (e.g. from glass bulbs, thermometers, windows, etc.) are to be covered by this procedure.

Records are available and demonstrate control of broken glass and affected product.

Glass breakage records have to include:

  • The date/time, where it occurred, corrective action taken, responsible person initials or signature.

NOTE: The application of the glass breakage procedure is evaluated within the process step (filling, closure, etc.) and premises.

Rating Examples

I

  • N/A

II

  • No written glass breakage procedure.

III

  • Glass breakage procedures not available to production employees.
  • Incomplete glass breakage procedure.
  • Records of glass breakage incidents were unavailable.
Reference

4.7.1.2 Certificate of Registration

1602 Task

Principle

The operator shall have the certificate of registration posted in the establishment.

Assessment Criteria

The certificate of registration shall be posted in a conspicuous place in the registered establishment for the period during which the certificate remains in effect.

Rating Examples

I

  • N/A

II

  • N/A

III

  • No certificate of registration posted in registered establishment.
  • Current certificate of registration not posted in establishment.
Reference

Appendix 1 - Water Quality Program

Water is analyzed by the establishment or municipality at a frequency adequate to confirm its potability.

There are no cross-connections between potable and non-potable water supplies or all hoses, taps and other similar sources of possible contamination are designed to prevent back-flow or back siphoning.

Where it is necessary to store water, storage facilities are adequately designed, constructed and maintained to prevent contamination (e.g. covered and sanitized on a regular basis).

Water treatment chemicals, where used, are listed in the "Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products", published by CFIA or the establishment has a "Letter of No Objection" from Health Canada. The chemical treatment is monitored and controlled to deliver the desired concentration and to prevent contamination.

Recirculated water is treated, monitored and maintained as appropriate to the intended purpose. Recirculated water has a separate distribution system which is clearly identified. The establishment has records available to demonstrate the adequacy of the microbiological and/or chemical safety of the water and steam supply as follows:

  • Water Potability Records

    • Water source
    • Sample site
    • Analytical results
    • Analyst
    • Date  
  • Water Treatment Records
    • Method of treatment
    • Sample site
    • Analytical results
    • Analyst
    • Date  
  • Boiler Feedwater Treatment Records
    • Method of treatment
    • Analytical results
    • Analyst
    • Date

For more information refer to:

http://www.hc-sc.gc.ca/ewh-semt/water-eau/drink-potab/guide/index-eng.php
http://www.cala.ca/regions.html

ASSESSMENT CRITERIA

Check if Complete

Comments if incomplete or N/A

WHAT

Water is analyzed by the establishment or municipality at a frequency adequate to confirm its potability.

checkbox
WHAT

There are no cross-connections between potable and non-potable water supplies or all hoses, taps and other similar sources of possible contamination are designed to prevent back-flow or back siphoning.

checkbox
WHAT

Where it is necessary to store water, storage facilities are adequately designed, constructed and maintained to prevent contamination (e.g. covered and sanitized on a regular basis).

checkbox
HOW

The establishment has records available to demonstrate the adequacy of the microbiological and/or chemical safety of the water and steam supply as follows:

checkbox
HOW
  • Water Potability Records
    - Water source, Sample site, Analytical results, Analyst, Date.
checkbox
HOW
  • Water Treatment Records
    - Method of treatment, Sample site, Analytical results, Analyst, Date.
checkbox
HOW
  • Boiler Feedwater Treatment Records
    - Method of treatment, Analytical results, Analyst, Date.
checkbox
HOW

At the time of construction or structural changes there are no cross-connections between potable and non-potable water supplies.

checkbox
HOW

As required all hoses, taps and other similar sources of possible contamination are designed to prevent back-flow or back siphoning.

checkbox
HOW

Water storage facilities are covered and sanitized on a regular basis.

checkbox
FREQUENCY

Weekly

checkbox
FREQUENCY

Monthly

checkbox
FREQUENCY

Annually (minimum requirement)

checkbox
WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Appendix 2 - Personnel Training Programs

The establishment has a written training program for employees which is delivered as follows:

  • Appropriate training in personal hygiene and hygienic handling of food and operation of equipment is provided to all employees at the beginning of their employment, such that they understand the precautions necessary to prevent the contamination of food.
  • The basic understanding or standard operating procedure of the establishment in regards to dress code, personal hygiene, handling of honey as a food, and injury prevention and response to injuries (cuts and open wounds).
  • It is imperative to ingrain the understanding that this is a food handling establishment and the product they are handling will be consumed by customers.

The "Health Surveillance an Management Procedures For Food-Handling Personal" Technical Report from the World Health Organization, dated 1989 is a good reference document on the hygienic approach to food handling. According to this document infections and intoxications potentially transmissible by food handlers include: Staphlococus aureus infection, typhoid, and paratyphoid fevers, non-typhi salmonellosis, Escherichia coli enteritis, Shigellosis, Cholera and Viral hepatitis A. Since health examinations of food-handling personal are not effective in preventing the spread of food borne diseases, alternative measures might include: the use of a HACCP system within the establishment, education and training of managers and food-handlers in food safety, provision and maintenance of hand washing facilities and the sanitary collection and disposal of wastes.

For more information Refer to: "Health surveillance and management procedures for food-handling personnel. Technical Report" Series 785, 1989 http://whqlibdoc.who.int/trs/WHO_TRS_785.pdf

ASSESSMENT CRITERIA

Check if Complete

Comments if incomplete

WHAT

The establishment has a written program for training employees in personal hygiene, hygienic handling of food and operation of equipment.

checkbox
HOW

Training in basic understanding or standard operating procedure of the establishment in regards to:

Dress code

Protective clothing, hair covering, footwear and/or gloves, appropriate to the operation.

checkbox
HOW

Personal hygiene:

Washing hands upon entering food handling areas, after handling contaminated materials, after breaks and after using toilet facilities.

checkbox
HOW

Remove jewelry and other objects which may fall into or otherwise contaminate food.

checkbox
HOW

Unhygienic practices which could result in contamination of food, such as eating, use of tobacco, chewing gum, sneezing, spitting are prohibited.

checkbox
HOW

Personnel known to be suffering from, or known to be carriers of a disease transmissible through food, are prohibited from working in food handling areas.

checkbox
HOW

Employees having open cuts or wounds do not handle food or food contact surfaces unless the injury is completely protected by a secure waterproof covering (e.g. rubber gloves).

checkbox
HOW

Appropriate training in the operation of equipment is provided to all food handlers at the beginning of their employment.

checkbox
HOW

Training is reinforced and updated.

checkbox
FREQUENCY

New employee

checkbox
FREQUENCY New or modified equipment or process checkbox
FREQUENCY Annually checkbox
WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Appendix 3 - Sanitation Program

The establishment has a written cleaning and sanitation program for all equipment which includes the following:

  • The identification of responsible person (if applicable).
  • The activity and frequency is listed (start of the season, start of day, during the day, end of the day and end of the season).
  • Chemicals and concentrations when used.
  • Potable hot water maybe the sole agent used for cleaning and/or sanitizing equipment.
  • Procedures for cleaning, sanitizing and rinsing.
  • Disassembly/reassembly instructions as required for cleaning and inspection.
  • Areas on equipment requiring special attention are identified.

The establishment has a written cleaning and sanitation program for the premises, (production and storage areas) which specifies the following:

  • The areas to be cleaned, method of cleaning, person responsible and the frequency of the activity (start of the season, start of day, during the day, end of the day and end of the season).
  • Special sanitation and housekeeping procedures required during production are specified within the document.
  • The sanitation program is carried out in a manner that does not contaminate food or packaging materials during or subsequent to cleaning and sanitizing.
  • Effectiveness of the sanitation program is monitored and verified.
  • The records of sanitation activities include the date, person responsible, the findings, corrective action taken, and microbiological test results where appropriate.

For more information refer to: "Reference listing of accepted construction materials, packaging materials and non food chemical products, Canadian Food Inspection Agency.
http://www.inspection.gc.ca/active/scripts/fssa/reference/refsearec.asp?lang=e&c=1"

ASSESSMENT CRITERIA

Check if Complete

Comments if incomplete or N/A

WHAT

The establishment has a written cleaning and sanitation program for all equipment.

 

checkbox

WHAT

The establishment has a written cleaning and sanitation program for the premises, (production and storage areas).

checkbox
HOW

The identification of responsible person (if applicable).

checkbox
HOW Equipment and areas on equipment requiring special attention are identified. checkbox
HOW Disassembly/reassembly instructions as required for cleaning and inspection. checkbox
HOW

The equipment and frequency for the cleaning of:

Extractors, uncapping equipment, sump, wax handling equipment, tanks, hand tools, dollies, filters, heat treatment equipment, filling and packaging equipment.

checkbox
HOW

The frequency for the cleaning of:

Floors, walls, ceiling, windows sinks, lavatories, lights, ventilation system.

checkbox
HOW Chemicals and concentrations when used. checkbox
HOW Procedures for cleaning, sanitizing and rinsing, are included in the program (Potable hot water maybe the sole agent used for cleaning and/or sanitizing equipment). checkbox
HOW Effectiveness of the sanitation program is monitored and verified. checkbox
HOW

The records of sanitation activities include the date, person responsible, the findings, corrective action taken.

checkbox
FREQUENCY  AS IT APPLIES

Start of the season

checkbox
FREQUENCY  AS IT APPLIES Start of day checkbox
FREQUENCY  AS IT APPLIES During the day checkbox
FREQUENCY  AS IT APPLIES End of the day checkbox
FREQUENCY  AS IT APPLIES

End of the season

checkbox
WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Appendix 4 - Pest Control Program

There is an effective written pest control program and records for the premises and equipment that includes:

  • Where applicable, the identification of the person at the establishment assigned responsibility for pest control
  • Where applicable, the name of the pest control company or the name of the person contracted for the pest control program
  • The list of chemicals used, the concentration, the location where applied, method and frequency of application. Pesticides must be used in accordance with the label instructions.
  • A map of trap locations, the findings and corrective action taken

Treatment of equipment, premises or ingredients to control pests is conducted in a manner that prevents contamination of product. Birds and animals are excluded from establishments.

ASSESSMENT CRITERIA

Check if Complete

Comments if incomplete or N/A

WHAT

There is an effective written pest control program and records for the premises and equipment (super and super storage).

checkbox
HOW

Where applicable, the identification of the person at the establishment assigned responsibility for pest control.

checkbox
HOW Where applicable, the name of the pest control company or the name of the person contracted for the pest control program. checkbox
HOW The list of chemicals used, the concentration, the location where applied, method and frequency of application. checkbox
HOW

Pesticides must be used in accordance with the label instructions.

  • A map of trap locations, the findings and corrective action taken
checkbox
HOW Treatment of equipment, premises or ingredients to control pests is conducted in a manner that prevents contamination of product. checkbox
HOW The records of pest control include the date, person responsible, the findings, corrective action taken. checkbox
FREQUENCY

checkbox

WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Appendix 5 - Equipment Maintenance and Calibration Program & Records

An effective maintenance and calibration program is in place to ensure that equipment performs consistently as intended and prevents contamination of product. Records are available to demonstrate the application of the maintenance and calibration program.

The establishment has an effective written maintenance and calibration program to ensure that equipment functions as intended. This includes:

  • A list of equipment requiring regular maintenance and calibration
  • The maintenance and calibration procedures and frequencies, (e.g. equipment inspection, adjustments and part replacements) are based on the equipment manufacturer's manual or equivalent, or are based on operating conditions that could affect the condition of the equipment.
  • Equipment is maintained to ensure that no physical or chemical hazard potential results, (e.g. inappropriate repairs, flaking paint and rust, excessive lubrication).
  • Maintenance and calibration of equipment is performed by appropriately trained personnel.

The typical information expected in maintenance and calibration records for equipment:

  • Identification of equipment
  • Maintenance of activity
  • Date, person
  • Reason for activity
  • Calibration results and corrective action required

For more information refer to: "Reference listing of accepted construction materials, packaging materials and non food chemical products, Policy, Planning & Coordination Directorate, Canadian Food Inspection Agency."

ASSESSMENT CRITERIA

Check if Complete

Comments if incomplete or N/A

WHAT

An effective maintenance and calibration program is in place to ensure that equipment performs consistently as intended and prevents contamination of product.

checkbox
WHAT Records are available to demonstrate the application of the maintenance and calibration program. checkbox
HOW

Written maintenance and calibration program:

A list of equipment requiring regular maintenance and calibration

checkbox
HOW The maintenance and calibration procedures (e.g. equipment inspection, calibration adjustments and part replacements) are based on the equipment manufacturer's manual or equivalent, or are based on operating conditions that could affect the condition of the equipment. checkbox
HOW Equipment is maintained to ensure that no physical or chemical hazard potential results, (e.g. inappropriate repairs, flaking paint and rust, excessive lubrication). checkbox
HOW Maintenance and calibration of equipment is performed by appropriately trained personnel. checkbox
HOW Maintenance records for equipment:
- identification of equipment, maintenance of activity, date, person, reason for activity.
checkbox
HOW Calibration records for equipment. checkbox
HOW Calibration results and corrective action. checkbox
FREQUENCY

Based on Manufactures Recommendations for Maintenance and Calibration.

checkbox
WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Appendix 6 - Glass Breakage Procedures and Records Programs

There is an effective glass breakage control procedure developed for the operation, all glass breakage occurrences (e.g. from glass containers, glass bulbs, thermometers, windows, etc.) are to be covered by this procedure. Records of glass breakage are maintained and are available upon request.

The establishment should have in place written glass breakage procedures during transit, testing, unloading, handling, moving, stacking, storing, depalletizing, inspecting, cleaning, conveying, filling and capping. Variables such as speed of lines; size and shape of container; protective shielding; types of fillers and cappers, make each plant unique. Therefore clean-up procedure for glass breakage will vary.

There is a written procedure developed where glass is present in the establishment.

The glass breakage procedure specifies:

  • Who is responsible.
  • The immediate action taken when a glass breakage occur (e.g. stop the line), the number of jars to reject from the line (empty jars, filled jars, closed jars).
  • The cleaning procedure for the equipment and surrounding area where the breakage occurred.
  • Evaluation of the cause of breakage and the disposal of the glass/jars and affected product.

The glass breakage procedure must be available to all employees.

Glass breakage records are available and have to include:

  • The date/time, where it occurred, corrective action taken, responsible person initials or signature.

NOTE: The application of the glass breakage procedure is evaluated within the process step (e.g. filling, closure, etc.) and premises.

ASSESSMENT CRITERIA

Check if Complete

Comments if incomplete

WHAT

There is an effective glass breakage control procedure developed for the operation, all glass breakage occurrences (e.g. from glass containers, glass bulbs, thermometers, windows, etc.) are to be covered by this procedure.

checkbox
WHAT Records of glass breakage are maintained and are available upon request. checkbox
HOW

There is a written procedure developed where glass is present in the establishment.

The glass breakage procedure specifies:
-Who is responsible.

checkbox
HOW -The immediate action taken when a glass breakage occur (e.g. stop the line), the number of jars to reject from the line (empty jars, filled jars, closed jars). checkbox
HOW -The cleaning procedure for the equipment and surrounding area where the breakage occurred. checkbox
HOW -Evaluation of the cause of breakage and the disposal of the glass/jars and affected product. checkbox
HOW The glass breakage procedure must be available to all employees. checkbox
HOW

Glass breakage records are available and have to include:

  • The date/time, where it occurred, corrective action taken, responsible person initials or signature.

NOTE: The application of the glass breakage procedure is evaluated within the process step (filling, closure, etc.) and premises.

checkbox
FREQUENCY

Continuous monitoring

checkbox
WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Appendix 7 - Recall Program

The establishment is capable of producing accurate information on a timely basis to verify that all affected product can be rapidly identified and removed from the marketplace.

There are ten basic elements which should be included in your recall plan. All of these elements must be included, each element plays a specific role and provides a different benefit.

  1. Recall Management Team.
    • Including after hours contact information .
  2. Complaint File.
  3. Recall Contact List.
    • Including notification of CFIA.
  4. Tracing of Raw Ingredients, Packaging Materials and Finished Products.
  5. Product Amounts.
  6. Distribution Records. The following minimum information is required for distribution records:
    • Product identification and size.
    • Lot number or code.
    • Quantity.
    • Customer names, addresses, and phone numbers (home and work) to the initial level of product distribution.
  7. Recalled Product Records.
  8. Recall Procedures.
    • Methods to identify, locate and control recalled product.
  9. Recall Effectiveness Procedures.
  10. Testing the Recall Plan (internal mock recall).

For more information refer to: Food Recalls: Make a Plan and Action It! Manufacturers' Guide,
http://www.inspection.gc.ca/eng/1376326890597/1376327095576
Labelling of Foods Causing Allergies and Sensitivities, Canadian Food Inspection Agency
http://www.inspection.gc.ca/eng/1332442914456/1332442980290.

ASSESSMENT CRITERIA Check if Complete Comments if incomplete
WHAT The establishment is capable of producing accurate information on a timely basis to verify that all affected product can be rapidly identified and removed from the marketplace. checkbox
HOW

There are ten basic elements which should be included in your recall plan. All of these elements must be included, each element plays a specific role and provides a different benefit:

1.Recall Management Team.

  • Including after hours contact information.
checkbox
HOW 2.Complaint File. checkbox
HOW

3.Recall Contact List.

  • Including notification of CFIA.
checkbox
HOW 4.Tracing of Raw Ingredients, Packaging Materials and Finished Products, extracting and filling records dated (for trace back to yards where possible). checkbox
HOW 5.Product Amounts. checkbox
HOW

6.Distribution Records: minimum information

  • Product identification and size, Lot number or code, quantity, customer names, addresses, and phone numbers (home and work) to the initial level of product distribution.
checkbox
HOW 7.Recalled Product Records. checkbox
HOW

8.Recall Procedures

  • Methods to identify, locate and control recalled product.
checkbox
HOW 9.Recall Effectiveness Procedures. checkbox
HOW 10.Testing the Recall Plan (internal mock recall). checkbox
FREQUENCY Annual testing checkbox
WHO

Establishment contact (Manager, Owner)

checkbox

DATE: space

SIGNATURE: space

Chapter 5 - Manufacturing Controls

5.1 Manufacturing Controls

5.1.1 Product Formulation

5.1.1.1 Label Accuracy

5101 Task

Principle

The establishment ensures that the label information accurately represents the composition of the food.

Assessment Criteria

Procedures are in place to ensure that all labels accurately represent product formulation, composition and claims especially where allergens or ingredients which may cause sensitivities are used.

Allergens include milk, eggs, fish, crustaceans, shell fish, tree nuts, peanuts, soy, wheat, sulphites, sesame seed.

Ingredients which may cause sensitivities include lactose, monosodium glutamate (MSG).

The following are examples of such procedures:

  • New label review.
  • Incoming label review for accuracy and correctness.
  • Formulation changes and substitutions.
Rating Examples

I

  • Omission of allergens in list of ingredients with a known history of producing anaphylactic reaction in sensitive individuals.

II

  • Inadequate or no control of label accuracy and listed ingredients which may cause sensitivities are used in the establishment.

III

  • Use of labels with inaccurate ingredient listings but no listed allergens used in the plant.
  • Inadequate control of label accuracy (e.g. no new label review but no listed allergens used in the plant).
Reference

5.1.2 Incoming Material Control

5.1.2.1 Ingredients/Additives, Processing Aids and Bee Treatments

5301 Task ***REVISED JUNE 2009***

Principle

The establishment controls incoming honey, other ingredients, food additives, processing aids and bee treatments such that no biological, chemical or physical hazards result in the food.

Assessment Criteria

The establishment controls incoming honey, other ingredients, food additives, processing aids and bee treatments through a program consisting of:

  • Written specifications for incoming honey and containers in which it is packed, other ingredients, food additives, processing aids and bee treatments.
  • Specifications include a provision for compliance with the Food and Drugs Act and Regulations and Honey Regulations.
  • The requirement for a letter of guarantee from the supplier.
  • Monitoring and testing to verify adherence to specifications.

Honey (Producer-Graders)

Establishments extracting honey must ensure that:

  • Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).
  • Treatments used are in accordance with Canadian requirements.

Honey (Packers or Pasteurizers)

Establishments packing and/or pasteurizing honey must ensure that:

  • Written procedures are in place to ensure incoming honey and containers in which it is packed do not pose any biological, chemical or physical hazards; and meets compositional standards of honey.
  • A system is in place to inform suppliers of specifications/requirements for incoming honey, including the use of food grade liners when the drum history and/or interior coating type are not known to be suitable.
  • A mechanism is in place to communicate and follow up on non-compliant issues.
Rating Examples

I

  • Use of adulterated/contaminated honey, incoming ingredients, food additives or processing aids.
  • Medications used for treating bees are not in accordance with Canadian requirements.

II

  • Incoming honey is received and accepted in drums without a food grade plastic liner or food grade coating.
  • Acceptance of contaminated incoming honey, other ingredients, food additives or processing aids.
  • No letter of guarantee from suppliers for honey, other ingredients, food additives and processing aids to indicate regulatory compliance.
  • The establishment has specifications for incoming honey but does not do any verification or monitoring to demonstrate adherence.
  • No program or documentation to verify adherence to specifications for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).

III

  • No specifications for non-critical ingredients (e.g. mustard, flavours).
References

5.1.2.2 Empty Containers (Bulk and Retail)

5302 Task ***REVISED JUNE 2009***

Principle

The establishment controls empty containers and all other packaging materials (bulk/retail) such that no biological, chemical or physical hazards result in the food and to ensure compliance with Division 23 of the Food and Drug Regulations and the Honey Regulations.

Assessment Criteria

All food contact surfaces must be food grade and suitable for its application.

Suppliers of packaging materials should have their products listed in the "Reference Listing of Accepted Construction, Packaging Materials and Non-Food Chemical Agents" published by the CFIA or have a "Letter of No Objection" from Health Canada.

Documentation (e.g. purchasing specifications) is available to show that the purchased packaging materials comply with the Food and Drug Regulations and Honey Regulations (including standardized container size for honey sold in Canada).

All packaging material is adequately protected from contamination and damage upon arrival.

Packaging materials are evaluated at a set frequency to ensure that correct material is received and free from defects.

Containers to pack honey must be clean, sanitary, in sound condition and have a tightly fitting lid.

Prepackaged

  • Every container for prepackaged honey must be new.

Bulk Containers

  • The establishment has a written bulk container program that is effectively implemented with maintained records (see "A Guide to Developing a Bulk Container Program").
  • All bulk containers (e.g. drums/totes) are free from severe dents or buckling that break the inner coating, and are free from obvious signs of internal rusting.
  • All metal drums are either coated with a food grade coating, or lined with a food grade plastic liner, suitable for honey storage.
  • The exterior coating is non-toxic and durable (e.g. no excessive peeling which could contaminate the honey).
  • All plastic liners are new, food grade and have a letter of compliance from the supplier.
  • Gaskets and plastic seals are food grade and new, or a plastic liner is used.

New or Reconditioned Metal Drums (first time use after reconditioning)

  • A letter of compliance from the drum re-conditioner or supplier is available.

Used Metal Drums

  • Food grade liners are used when the historical use of the drums and/or the interior coating are not known.
  • They must be in good repair as indicated above.

Plastic Drums/Totes

  • New plastic drums and tote bladders should be used, and have a letter of compliance from the supplier.
  • Used plastic drums or tote bladders may be used if traceability is available and have been used only for honey storage and do not contaminate or impart any odours/flavours to the honey.
Rating Examples

I

  • N/A

II

  • Packaging material/empty bulk containers do not comply with Division 23 of the Food and Drug Regulations.
  • Plastic liners are not food grade.
  • Containers (e.g. metal drums) are not free from severe dents and buckling or obvious signs of internal rusting.

III

  • Containers or plastic liners are known to be food grade from a known supplier but no documentation is available.
  • Exterior coating has cracked peeling paint which may come in contact with honey.
  • Old labels are not removed.
  • The establishment does not have a written Bulk Container Program.
References

5.1.3 In-Process Package Control

5.1.3.1 Empty Container Handling (Bulk and Retail)

5401 Task ***REVISED JUNE 2009***

Principle

Empty container handling is controlled to minimize damage and to prevent the use of damaged, defective or contaminated containers.

Assessment Criteria

Containers are handled, transferred and cleaned (when necessary) in a manner that minimizes damage and contamination.

The establishment has an effective cleaning system in place.

The establishment has an effective system in place to prevent the use of damaged, defective or contaminated containers.

This can be accomplished by ensuring that:

  • Empty containers are visually or electronically examined to identify, remove and segregate non-compliant containers prior to use.
  • If applicable, there is a back-up system in place in case the electronic inspection system fails.
  • The establishment has controls in place to prevent contamination of clean containers. For example:
    • No containers and lids are left on the line at breaks, during clean-up or extended downtime unless adequate measures are in place to prevent contamination.
    • Containers are used only for their intended purposes.
    • Lids fit tightly.

Additional Criteria for Bulk Containers

All bulk containers (e.g. drums/totes) are free from severe dents or buckling that break the inner coating, and free from obvious signs of internal rusting.

  • New or reconditioned drums that are not washed prior to use must be clean.
  • All used drums must be washed before filling even when a food grade liner is used.
  • Washed drums are turned upside down and left to dry on a clean surface.
Rating Examples

I

  • Glass particles detected in open containers or in finished products.
  • Harmful extraneous material (> 2 mm) detected in open containers or in finished products.

II

  • Containers with evidence of contamination being used to pack honey.
  • Food grade liners are not used when drum history and/or coating type are not known.
  • Used metal drums are not washed or improperly washed prior to packaging honey.
  • Deficiencies in the container handling control program which may result in use of seriously damaged containers.
  • Washed ready-to-fill bulk containers are inverted directly on the floor.
  • Containers are not used for their intended purpose.

III

  • No continuous visual monitoring, however, other visual inspection of assessment criteria are satisfactory.
References

5.1.4 Product Preparation and Blending Controls

5.1.4.1 Honey Batching and Blending

5501 Task

Principle

Factors for each specific batch/lot are controlled during blending to ensure specified requirements in the Honey Regulations are met.

Assessment Criteria

The establishment has controls in place to ensure that the composition of the honey in each batch or lot has been accurately evaluated. Areas which require evaluation are:

  • Colour
  • Moisture
  • Absence of Foreign Material
  • Characteristic Flavour
  • Floral Source (if declared)
  • Lot numbers
  • Country of Origin

The establishment has signed verifications of all batch or lot evaluations.

The owner or operator of each registered establishment shall keep and make available to the CFIA at all times, an accurate, up-to-date record of his honey pack that shows:

  • The quantity of honey pooled or purchased and the persons from whom it was received or purchased.
Rating Examples

I

  • N/A

II

  • N/A

III

  • The establishment has no controls and documentation in place for batch or lot blending.
  • Evaluations performed but no signed verification.
  • Incomplete/inaccurate evaluations of each batch.
Reference

5.1.5 Filling Control

5.1.5.1 Filling of Containers

5601 Task

Principle

Controls are in place to prevent damage or contamination of containers, lids and product during the filling process.

Assessment Criteria

The establishment has controls in place to prevent hazards associated with product filling.

The establishment has controls in place to prevent contamination of clean containers and product, for example:

  • Filled containers without lids are not left on the line at breaks, during clean-up or extended downtime unless adequate measures are in place to prevent contamination.
Rating Examples

I

  • N/A

II

  • Filled containers left on the line during breaks, clean-up, downtime where there is a high risk of contamination.
  • The establishment does not have adequate controls in place to prevent hazards associated with product filling (glass).

III

  • Filled containers left on the line at breaks and downtime where there is a low to moderate risk of contamination.
  • The damaged container control or visual monitoring program is absent or deficient such that defective containers may be used.
  • The establishment does not have adequate controls in place to prevent hazards associated with product filling.
Reference

5.1.6 Container Closure Control

5.1.6.1 Container Closure

5701 Task

Principle

Container closure controls are in place to prevent contamination of the food.

Assessment Criteria

The establishment controls the closing equipment to ensure the integrity of the container by:

  • Protecting the cap or lid hopper from contamination.
  • Adjusting closing equipment to avoid damage to containers.
  • Adequate container closure.
Rating Examples

I

  • N/A

II

  • Harmful extraneous material found in capping hopper or capper.

III

  • Capping area not inspected regularly for potential contamination.
  • Inadequate container closure.
Référence

5.1.7 Process Control

5.1.7.1 Control of Filling and Labelling

5801 Task

Principle

The establishment has controls in place to prevent mislabelling and improper filling.

Assessment Criteria

The establishment has controls in place to prevent mislabelling and improper filling of containers.

Typical controls should be:

  • Container size for product to be sold in Canada.
  • Effective separation of products during changeovers with records.
  • At the labeller different product labels are effectively separated and the number of product label types are kept to a minimum.
  • Tops and bottoms of label bundles are visually checked for mixed labels prior to use.
  • Prevention of mixing of individual or bundles of labels during storage (e.g. storage in separate boxes, no loose labels, and ensuring that unused labels are returned to the correct boxes.)
  • Effective weight control system to ensure proper filling at the declared weight.
  • Effective grading system to ensure correct grade evaluations.
Rating Examples

I

  • N/A

II

  • N/A

III

  • Use of incorrect labels or inadequate control of label application.
  • No effective weight verification system in place.
  • No effective grade evaluation system in place.
Reference

Appendix 1 - Incoming Honey and Ingredients Program

The establishment controls incoming honey and ingredients (food additives and processing aids) through a program consisting of:

  • Written specifications for honey, incoming ingredients (food additives and processing aids). Specifications include a provision for compliance with the Food and Drugs Act and Regulations.
  • The requirements for a letter of guarantee from the supplier.
  • Monitoring and testing to verify adherence to specifications.

The establishment that extracts honey must ensure that:

  • Medications used have been approved for use for treating bees.
  • The recommended preparation and dosage level of the medications have been followed.
  • The withdrawal time for the medication has been followed before the honey is harvested.
  • Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control).
Reference
Assessment Criteria Check if Complete Comments if incomplete or N/A
What The establishment controls incoming honey and ingredients (food additives and processing aids). checkbox
How 1. Written specifications for honey and incoming ingredients (food additives and processing aids). checkbox
How 2. Specifications are in compliance with the Food and Drugs Act and Regulations (e.g. contaminants and adulterants). checkbox
How 3. A letter of guarantee from the supplier,
Monitoring and testing to verify adherence to specifications.
checkbox
How The establishment that extracts honey must ensure that:

1. Medications used have been approved for use for treating bees.

checkbox
How

2. The recommended preparation and dosage level of the medications have been followed.

checkbox
How

3. The withdrawal time for the medication has been followed before the honey is harvested.

checkbox
How

4. Records are kept for all applications of treatments to the colonies (e.g. medications, colony evacuation for honey removal, mite control.)

checkbox
Frequency Per shipment or per colony checkbox
Who Establishment contact (Manager, Owner) checkbox

Date: space

Signature: space

Appendix 2 - A Guide to Developing a Bulk Container Program

***Revised June 2009***

Objective

This document is intended to provide guidance on developing a written bulk container program. The program will provide details on how the establishment will control biological, chemical and physical hazards which can be associated with bulk containers (capacity of more than 5 kg).

Regulatory Requirements

  • Honey Regulations:
    • 16(b), 32 - Containers are suitable for use
    • 25(d) - Containers are maintained in clean and sanitary condition
    • 30 - Prescribed container sizes
    • 33 - Boxes are suitable and not defaced by old markings
  • Food and Drug Regulations: Division 23, Section 4 and 7

References

Written Program Components

Objective (why)

State the objectives of your bulk container program.

Example:

Bulk containers used in packing honey are received/unloaded, handled, filled, emptied and stored such that no biological, physical or chemical hazard results in the food and to ensure regulatory compliance:

  • are clean
  • are sanitary
  • are of sound condition, durable and non-toxic
  • have tightly fitting lids
  • are free of severe dents or buckling
  • have no obvious signs of internal rusting
  • all food-contact surfaces are food grade and suitable for the application

Criteria

A written bulk container program explains:

  • Where bulk containers are sourced (e.g. suppliers)
  • Type of bulk containers sourced and their specifications (e.g. suitable for storing honey)
  • How bulk containers will be evaluated to ensure that specifications are met (e.g. that they meet the requirements of the Honey Regulations, Division 23 of the Food and Drug Regulations and the Honey Industry Bulk Container Standard).

For example, bulk containers are:

  • coated with or lined with a food grade coating
  • clean, sanitary and in sound condition
  • have tight fitting lids
  • free from severe dents or buckling
  • free from obvious signs of internal rusting
  • how containers will be cleaned and maintained to prevent contamination and damage
  • if liners are used, where are they sourced and their specifications (e.g. proof that they are food grade)records are available and demonstrate that controls are in place and that the bulk containers meet regulatory requirements.

Procedures/Tasks (what/how)

Describe the type of bulk containers sourced and where.

What documentation will be obtained to show that the bulk containers are made of food grade materials?

  • Explain how empty bulk containers will be received and evaluated to ensure that requirements are met.
  • Explain where empty bulk containers will be stored to minimize contamination.
  • Explain how bulk containers will be cleaned and inspected prior to filling with honey.

Position Responsible (who)

  • State the position/name responsible for the bulk container program.
  • State the position/name responsible for each procedure or task.

Frequency (when/how often)

  • State the frequency each procedure or task will be done (e.g. daily, weekly, monthly).

Records

  • What records will be kept to show that the bulk container program has been implemented and is effective.
  • Records should include bulk container sources, documentation to show that the bulk containers are made of food grade materials, (e.g. letter of compliance from suppliers.)
  • Records to show that bulk containers were evaluated prior to filling and include findings, actions taken to correct an identified problem and to prevent recurrence.

Additional records for bulk container distributors:

  • Records indicating client name and contact information, bulk container description, shipping date, number of bulk containers shipped.

Corrective Action

Indicate what corrective action will be taken when a bulk container does not meet the required specifications.

Verification

Who will verify that all elements of the program are implemented and effective:

  • The procedures are followed.
  • The corrective actions have been implemented.
  • The bulk containers meet the specifications.
  • The bulk container program is effective again.
  • What, how and when will this be done and what records will be kept.
  • Approved by (signature):
  • Print name:
  • Approved date:
  • Revision date:

Checklist to assess the bulk container written program

Name of Establishment and Registration Number:

  Evaluation criteria Check if complete Comments if incomplete
What The establishment has established controls for biological, chemical or physical hazards and complies with regulatory requirements. checkbox
How The establishment has effective written procedures to:

1. Purchase acceptable bulk containers

checkbox
How 2. Evaluate that empty containers meet regulatory requirements at receiving (e.g. free from severe dents, buckling, rust, are sound, clean, sanitary and have tightly fitting lids, food grade as appropriate.) checkbox
How 3. Carry out the cleaning, handling and storage of the bulk containers. checkbox
How 4. Ensure old labels are removed. checkbox
How 5. Inspect bulk containers prior to filling. checkbox
Who An establishment contact (e.g. owner/operator)has been identified to be responsible for the program. A position/person is identified to be responsible for carrying out each procedure. checkbox
Who A position/person is identified to be responsible for carrying out each procedure. checkbox
Frequency Procedures are set at a frequency adequate to address risks. checkbox
Records The establishment has records for:
1. Where bulk containers were sourced.
checkbox
Records 2. Type of bulk containers sourced. checkbox
Records 3. Letter of compliance from drum reconditioner/supplier (for new or reconditioned drums) checkbox
Records 4. Documentation to show plastic liners, gaskets and plastic seals are food grade. checkbox
Records 5. Records to show that the procedure(s) have been completed and followed. checkbox
Records 6. Documentation to show corrective action taken. checkbox
Records 7. Documentation to show that the corrective action was verified and the corrective action taken corrected the problem effectively and will not result in recurrence. checkbox
Records 8. If drums were distributed, records indicating; date shipped, description of the drum(s), product lot code, quantity, client name and contact information. checkbox
Corrective action The establishment has written procedures to determine root cause when deviations have occurred. This includes evaluation of risk to the product. checkbox
Verification A person is identified to verify that all elements of the program are implemented and effective.
What and how will this be done and what records will be kept.
checkbox

Date: space

Name of Inspector: space

Date modified: