Food Investigation Response Manual
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This manual was developed to provide guidance with respect to the Canadian Food Inspection Agency (CFIA) operational activities relating to food safety investigation and recall. It applies to CFIA food safety investigations and response and some non-food safety investigations, such as extensive food spoilage or foreign material contamination, where the potentially implicated food product is in the Canadian market place.
This manual is supported by the CFIA Framework for Food Safety Investigation and Response (the FSIR Framework), which describes the Agency's overall approach to food safety investigations and response, the governance and the roles and responsibilities of CFIA Branches, and the Area Operations Framework for Food Safety Investigation and Response. Other governance and management processes are added during a declared food safety emergency, high profile food safety issue, or during the activation of Canada's Foodborne Illness Outbreak Response Protocol (FIORP) to guide a multi-jurisdictional response.
This manual is currently going through a review initiated in 2013.
1.1 Scope of the Food Investigation Response Manual
The purpose of this manual is to provide direction, operational guidance, definitions and policy and procedures for the CFIA with respect to:
- roles and responsibilities;
- investigation of food safety and non-food safety issues and food emergency situations;
- risk management strategies; and
- implementation of food safety recalls.
This manual will also delineate the roles of Health Canada (HC), the Public Health Agency of Canada (PHAC) and the CFIA with respect to food safety investigations, recalls and emergencies, as well as the relationship between the Office of Food Safety and Recall (OFSR) and other partners within the CFIA. Industry also has key roles and responsibilities in the recall process and to address this, CFIA has developed Industry Recall Guides.
1.2 Amendments and Revisions
As the custodian of the document and to ensure information remains current, the OFSR will lead and coordinate the review of the FIRM every two years.
1.3 Stages of a Food Safety Investigation and Recall
Food safety issues require investigation to confirm whether a hazard (physical, chemical, and/or biological) or contravention exists. Where it is determined that a hazard exists, various risk management options may be implemented including, but not limited to, recall, detention, seizure, public advisories, letter of non-compliance, opportunity to be heard, informal meetings, cancellation/suspension of registration or license, prosecution, border lookouts, re-export of the affected product(s), prosecution, etc.
Recall is an effective method of removing food products that pose a risk from the marketplace. It is an action usually taken by manufacturers, distributors, retailers or importers to fulfill their responsibility to protect the public health. They may also carry out recalls to meet regulatory requirements for food products.
The food safety investigation and recall process can be broken down into the following stages:
- Trigger: The initial cause of an issue;
- A Food Safety Investigation (FSI): An issue or product where a health and safety concern and/or a contravention of legislation enforced by the CFIA is suspected. Operations staff in the Areas/Regions take the lead in the food safety investigation, supported as necessary by the OFSR;
- Decision-making: When a health risk has been established, the OFSR coordinates the development of the most appropriate risk management strategy in consultation with internal CFIA sections, such as Technical and Program Specialists, and external departments and agencies for the issue such as HC, PHAC, law enforcement agencies, the Ministry of Environment, Provincial/Territorial Governments, etc. The Executive Director (ED) of the OFSR is responsible and accountable for risk management decisions for potential recalls, with the level of action being appropriate to the health risk. OFSR decision-making includes recall requests for health and safety issues and recall recommendations for some non-health and safety issues. A recall recommendation may be conveyed to the industry when it is deemed that is an appropriate strategy (i.e. extensive spoilage, infestation);
- Recall Implementation: Where it is determined that the appropriate risk management strategy is to recall the affected product, the recalling firm is advised and CFIA staff work with the recalling firm to implement a recall. A public warning may be issued depending on the circumstances;
- Verification of Recall Effectiveness: The recalling firm is responsible for effectively removing the affected product from the market. CFIA Operations monitor the effectiveness of the recall;
- Follow-up: CFIA Operations staff, in consultation with Programs staff, conduct follow- up activities with the recalling firm during/following the recall to ensure that issues are handled consistently and appropriately. Follow up activities may include determining the disposition of returned product and product in storage, evaluation of the corrective action implemented for the recalled product and evaluation of the corrective action implemented to reduce the likelihood of reoccurrence of the issue. Technical Specialists will provide advice, where necessary, in support of Operations and Programs staff. It is important to note that scoping (i.e. the determination whether additional product is on the market place) is not part of the follow-up phase, even though the two activities often occur simultaneously. Programs will track recall trends and take appropriate actions as required.
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