Chapter 18 – Compliance Verification System
18.4 Organization and frequency of verification tasks

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The verification tasks are organized into seven (7) sections and related sub-sections.

Section 1: HACCP system implementation and specific control programs

  • Sub-section 1: specific control measures for product safety
  • Sub-section 2: prerequisite programs
  • Sub-section 3: slaughter/processing requirements & control programs
  • Sub-section 4: current issues
  • Sub-section 5: process controls

Section 2: Labelling and other domestic requirements

  • Sub-section 1: labelling
  • Sub-section 2: CFIA stations and facilities
  • Sub-section 3: grading program
  • Sub-section 4: current issues

Section 3: Export

  • Sub-section 1: export USA
  • Sub-section 2: export other than USA
  • Sub-section 3: export all countries
  • Sub-section 4: current issues

Section 4: Comprehensive HACCP system review

  • Sub-section 1: HACCP system design effectiveness
  • Sub-section 2: in-depth review
  • Sub-section 3: food recall
  • Sub-section 4: current issues

Section 5: Animal welfare and animal health

  • Sub-section 1: animal welfare and animal health
  • Sub-section 4: current issues

Section 6: Outcome assessment

  • Sub-section 1: outcome assessment

Section 7: Sampling

  • Sub-section 1: operator sampling
  • Sub-section 2: CFIA domestic sampling
  • Sub-section 4: current issues

Task numbering:

Each verification task is assigned a number. This number represents the Section, Sub-section, and sequential task number. The first part of the task number indicates the Section, the second part indicates the Sub-section, and the last part of the task number represents the sequential task number.

For example:

  • Task #2.2.02 is in Section 2 Labelling and Other Domestic Requirements; Sub-section 2 CFIA Stations and Facilities; and is the second task in this Sub-section.
  • Task #3.1.02 is in Section 3 Export; Sub-section 1 Export USA; and is the second task in this Sub-section.

Each verification task is assigned a minimum frequency. These frequencies are determined considering the:

  • impact on food safety
  • FSEP manual guidelines
  • type of control measures identified at the establishment
  • regulatory requirements
  • export requirements
  • state of compliance of the industry as a whole

The "Verification Task Procedures" provide the procedures for each verification task. Each verification task procedure includes the following information:

  • section and sub-section
  • task number
  • task title that summarizes the task
  • minimum frequency
  • the date the task was last revised
  • references to the MIA, MIR and other applicable regulations
  • provisions of the MIA & MIR subject to administrative monetary penalties
  • the procedure to follow when completing each task to ensure the uniformity of application across the country; each verification task procedure includes:
    • the requirements being assessed by each task
    • how the inspector must assess the operator's compliance to requirements
    • references to the MOP

18.4.1 Section 1: HACCP system implementation and specific control programs

The following sub-sections include verification tasks related to HACCP system implementation and specific control programs required in the Meat Hygiene Manual of Procedures.

  • Sub-section 1: Specific control measures for product safety

The control measure verification tasks are designed to assess the implementation and effectiveness of the operator's HACCP system to meet regulatory requirements. The tasks include: reviewing the written procedure and the records, interviewing, and observing the written procedures being implemented.

The tasks in this sub-section may include operator identified Critical Control Points (CCPs) or other specific control measures recognized by the CFIA. In the case where operator identified CCPs or other control measures are covered by another verification task in section 1 – sub-sections 2, 3 or 5, that CCP or control measure must be verified under that specific task instead of a sub-section 1 task.

  • Sub-section 2: Prerequisite programs

The prerequisite verification tasks are designed to assess the implementation and effectiveness of the operator's prerequisite programs to meet regulatory requirements. The tasks include: reviewing the selected written prerequisite control program and records, interviewing, and observing the procedures being implemented.

  • Sub-section 3: Slaughter/processing requirements & control programs

These verification tasks are designed to assess the implementation and effectiveness of the operator's control programs, as well as compliance with other regulatory requirements related to slaughter and processing operations. The tasks include: reviewing any written control programs, reviewing records, directly observing and interviewing to determine if the regulatory requirements are met and the control programs are implemented effectively as described.

  • Sub-section 4: Current issues (applies to all sections)

The current issues verification tasks will be developed as required. Tasks may be developed in the following situations:

  • extraordinary requests from the President of the CFIA
  • need for data collection on a specific subject of interest
  • survey to industry
  • Sub-section 5: Process controls

These verification tasks are designed to assess the implementation and effectiveness of the operator's process controls. The tasks include: reviewing any written programs, reviewing records, conducting independent and correlation tests, directly observing and interviewing to determine if the regulatory requirements are met and the process controls are implemented effectively as described.

18.4.2 Section 2: Labelling and other domestic requirements

The verification tasks included in this section are designed to assess compliance with labelling and other domestic regulatory requirement not covered under section 1.

The following sub-sections include verification tasks related to labelling and other domestic regulatory requirements.

  • Sub-section 1: Labelling
  • Sub-section 2: CFIA stations and facilities
  • Sub-section 3: Grading program
  • Sub-section 4: Current issues

18.4.3 Section 3: Export

The export verification tasks are designed to assess compliance with export requirements. The tasks include: directly observing if requirements are respected, reviewing any required written control programs, and reviewing records.

Each of the following sub-sections includes verification tasks related to export requirements.

  • Sub-section 1: Export USA
  • Sub-section 2: Export other than USA
  • Sub-section 3: Export all countries
  • Sub-section 4: Current issues

18.4.4 Comprehensive HACCP system review

The tasks included in section 4 are organized in 4 sub-sections:

  • sub-section 1: HACCP system design effectiveness
  • sub-section 2: In-depth review
  • sub-section 3: Food recall
  • sub-section 4: Current issues

18.4.4.1 HACCP system design effectiveness

The goal of the HACCP system design tasks is to verify that the operator's HACCP system:

  • is designed to effectively control food safety hazards
  • meets the FSEP and program requirements
  • is updated and maintained as changes occur;
  • is effective to control the identified hazards
  • is reassessed to ensure food safety hazards remain under control

The HACCP system design tasks are conducted and led by an FSEP specialist inspector. An FSEP specialist inspector is any inspector trained and evaluated to deliver Section 4 tasks and new registration reviews, and where applicable, provide advice and training to regional staff on FSEP and CVS questions and other area delegated responsibilities.

Task 4.1.03 – New HACCP plan/new process in existing HACCP plan

This task is to be conducted when an establishment adds a new HACCP plan or a new process or product to an existing HACCP Plan, as per section 5.1 of the FSEP manual.

The supervisor (or designate) must notify the area FSEP/CVS Coordinator (or designate) of the submission of a new HACCP plan or a new process to an existing HACCP plan. Task 4.1.03 must be completed within 30 calendar days from receipt of the complete written procedures.

Task 4.1.04 – Outcome of HACCP system maintenance and reassessment

This task is conducted at a minimum frequency of at least once every two years in all processing establishments, slaughter establishments, and storages by an FSEP specialist inspector and the responsible inspector (when operationally feasible).

Task 4.1.04 may also be performed when triggered by the Outcome Assessment Task (6.1.02) or when the integrity of the HACCP system is compromised. The supervisor (or designate) will notify the area FSEP/CVS Coordinator (or designate) of the need for immediate support. The Area FSEP/CVS Coordinator will contact the supervisor and/or regional FSEP specialist inspectors and/or managers (if required) to evaluate the situation and, when deemed appropriate, have task 4.1.04 delivered.

18.4.4.2 In-depth review

The goal of the in-depth review tasks is to verify that the operator's HACCP system is designed and implemented to effectively control the risk associated with contamination by pathogens or other specific hazards. The in-depth review tasks are designed to focus on the hazard of concern. Any inspection findings observed outside of the scope should be addressed in accordance with section 18.7.2.2.

The in-depth review tasks are conducted in these situations:

  • when intensified inspections do not resolve the state of extended non-compliance after the following occurs:
    • repetitive unsatisfactory test results indicating there may be a health risk associated with a product, either distributed in the marketplace or not, and/or
    • confirmed illness/death cases related to food
  • if selected as a related task to address unscheduled verification findings during a food safety investigation (recall) related to the specific hazard, or
  • at the request of senior management

The in-depth review team may include but is not limited to:

  • area/Regional FSEP specialist
  • veterinarian in charge/responsible inspector
  • supervisor inspector
  • regional veterinarian officer, and/or
  • operational specialist

Other experts from National or area programs/operations/science/enforcement could be included in the in-depth review team, if deemed necessary for the situation.

18.4.4.3 Follow-up after a food safety investigation/recall

The Office of Food Safety and Recall (OFSR) will send an e-mail notification to the National Inspection Division (NID) when a decision to request a food recall is made, including the associated Issues Management System (IMS) number. The date of the decision to request a recall will be captured in the IMS.

The NID will immediately send notification to the Quality, Planning and Integration Manager (QPIM) in the applicable areas requesting that the process described below begins if the recalling firm is a meat registered establishment. The related IMS number will be included in the notification to the QPIM. The NID will track each process and verify that the timelines are met. Reminders will be sent to the QPIMs as required.

All non-compliances identified during the food safety investigation will be treated as unscheduled verification findings. Once a recall has been initiated, Operational Procedure (OP-150-2014) – Procedure for Following up on the Underlying Cause(s) of a Food Recall must be implemented by the region of the recalling establishment. If a root cause is identified during the food safety investigation for which corrective action can be implemented by the recalling firm, an action plan must be requested from the recalling firm as per OP-150-2014. In order to accomplish this, the RI will rate the related CVS task (such as: 1.1.09, 1.2.13, 4.2.02, 7.1.04, etc.) "Unacceptable" and issue an IR-CAR. The date for corrective measures identified by the RI in the IR-CAR must respect the requirement that CFIA follow-up activities outlined in OP-150-2014 must be completed within 60 days from the date the recall was first initiated. (such as: CFIA still requires time after the date for completion of corrective measures to complete follow-up). Where appropriate, more than one IR-CAR related to the recall may be issued.

An action plan is requested from the operator as per section 18.7.4.3. The RI and the lead food safety inspector will review the Corrective Action Plan (CAP) together to determine if it meets requirements outlined in both section 18.7.5 of the MOP and section 5.4 of OP-150-2014. The RI will document the date of receipt of the CAP on the "follow-up" section of the IR-CAR, as per section 18.7.5.2. Extensions for the date of corrective measures may be granted by the RI provided requirements outlined in section 18.7.5.3 of the MOP and section 9.0 of OP-150-2014 are met.

If the investigation does not identify a root cause in line with the activities of the registered establishment, an IR-CAR does not need to be issued and follow-up to the underlying cause of the recall is not required as per section 3.1.1 of OP-150-2014. The RI will treat the observations of the recall investigation as an unscheduled verification finding, as per 18.7.2.2 and will record the following information on the verification worksheet (CFIA/ACIA 5470) under "Activities Conducted to Assess Compliance" (Box 10) using code 9.1.10:

"[Product description] recall determined to be an isolated incident. See IMS #[xyz]. No further follow-up activities required."

In order to meet the requirements outlined in OP-150-2014, follow-up to any IR-CARs issued related to the recall must be completed 60 days from the date the recall was first initiated. Follow-up will be completed together by the lead food safety inspector and the RI. If the IR-CAR cannot be closed, the RI initiates enforcement actions as per MOP Chapter 14 (see 18.7.6.2).

Task 4.3.01 – reassessment after a recall must be initiated within 30 days from the original due date of the IR-CAR issued. Task 4.3.01 is completed by an FSEP Specialist Inspector as the lead, with assistance from the RI of the establishment. If no IR-CAR was issued as a result of the recall, then task 4.3.01 does not need to be completed. If the IR-CAR was issued under a subsection 4.2.00 "in-depth review" task, then task 4.3.01 also does not need to be completed. The goal of task 4.3.01 is to verify that the operator reassessed and updated their HACCP system accordingly after a recall.

Throughout the food safety investigation, the RI will work with the lead food safety inspector. The lead food safety inspector is responsible for ensuring all required information is entered into the IMS as per section 5.4 of OP-150-2014. The RI is responsible for documenting all follow-up activities on the "follow up" section of the IR-CAR(s).

18.4.5 Section 5: Animal welfare and animal health

The animal welfare and animal health verification tasks are designed to assess compliance with regulatory requirements. The tasks include: reviewing any written control programs, reviewing records, directly observing and interviewing to determine if the regulatory requirements are met and the control programs are implemented effectively as described.

Each of the following sub-sections includes verification tasks related to animal welfare and animal health.

  • Sub-section 1: Animal welfare and animal health
  • Sub-section 4: Current issues

18.4.6 Section 6: Outcome assessment

This section includes tasks that will be used by CFIA for purposes other than verifying operator's compliance to Acts and Regulations and assigning a compliance level. This section includes the outcome assessment task which is used to evaluate the outcome of the control measures applied by the operator by obtaining a global picture of the current processes, building conditions, and operating environment. The inspector will use the results of the assessment to trigger and prioritize verification tasks for delivery when situations are observed that may impact food safety, constitute fraudulent activities, or indicate the operator's HACCP system may not be effective.

18.4.7 Section 7: Sampling

This section incorporates both Operator sampling activities and CFIA sampling activities. Operator sampling activities are based on policy requirements. Tasks that verify export sampling requirements are located under Section 3 Export.

18.4.7.1 Operator sampling

Operator sampling tasks focus on elements of prescribed sampling programs. This includes verifying written plans, sampling activities, frequencies and results. Operators are required to notify the CFIA of non-compliant product and environmental results.

Based on the task guidance, if an IR-CAR is issued there may be follow up sampling required. Follow up samples and results received must be documented on the follow up section of the IR-CAR. Follow up sampling results do not require additional IR-CARs to be issued.

The only exception is in the case where an operator notifies the CFIA of a positive Listeria environmental sample result. The inspector will issue an IR-CAR under Task 7.1.02. According to the MOP Chapter 4, the operator must then conduct product sampling. Should that product sample test positive, the CFIA will issue the operator another IR-CAR under Task 7.1.04.

This ensures the positive product sample is differentiated from the environmental sample in CVS. The action plan submitted by the operator can be the same action plan for both IR-CARs provided it meets the requirements of an acceptable action plan and addresses both non-compliances.

18.4.7.2 Domestic CFIA sampling

These tasks encompass the scheduled domestic sampling plans conducted by CFIA inspectors in the field. It should be noted that these sampling tasks differ from other CVS tasks. The task rating is determined by the analysis result and not information gathered. In addition, there are no criteria to verify other than the sample collection. Each task will contain a certain amount of follow up guidance; however, in each case the MOP and current guidelines must always be consulted.

Domestic – Microbiological sampling

In the case of domestic meat products sampled in accordance with the CFIA Microbiological Sampling Program, non-compliant or unsatisfactory product analysis results indicate that the operator does not meet the regulatory requirements related to the manufacturing of edible meat products.

Follow up samples that are related to an initial non-compliant or unsatisfactory result must be documented on the follow up section of the IR-CAR. Non-compliant or unsatisfactory follow-up sampling results do not require additional IR-CARs to be issued.

The only exception is in the case where product samples are collected as a result of non-compliant environmental sampling results (Task 7.2.11). The product sample must be collected and documented on the verification worksheet under Task 7.2.01. If the product analysis result is non-compliant, another IR-CAR is issued under Task 7.2.01.

This ensures the positive product sample is differentiated from the environmental sample in CVS. The action plan submitted by the operator can be the same action plan for both IR-CARs provided it meets the requirements of an acceptable action plan and addresses both non-compliances.

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