Food Investigation Response Manual
3.0 Triggers for Food Safety Investigations

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Types of Triggers

The Canadian Food Inspection Agency (CFIA) receives information regarding food safety concerns from all types of sources. These sources are termed "Triggers" and they include:

  • Consumer complaints;
  • Trade complaints;
  • Foodborne illness outbreaks or epidemiological information;
  • Unsatisfactory lab results;
  • Media;
  • Company initiated product removals or product correction: i.e. recalls, stock recovery, product withdrawal, export refusal;
  • Referrals from other government departments (either domestic or international), law enforcement, medical community, industry and consumer associations; and
  • Food safety and non-food safety investigations resulting from product inspection or inspection/audit/assessment/evaluation results that have the possibility of affected product being on the market.

3.1 Referring Food Safety Incidents to the Office of Food Safety and Recall (OFSR)

3.1.1 Definitions

Referral:
The step to formally engage the OFSR for coordination and guidance with respect to a food safety investigation or a recall.
Early Referral:
An immediate referral to the OFSR that is done during the preliminary assessment of a food safety incident or in the early stages of a food safety investigation, even though available information may still be limited. Please refer to Annex A for a list of types of food safety incidents that require an early referral.
High Priority Food Safety Incident:
An incident that takes precedence over all other work by Operations Branch. Please refer to Annex A for a list of high priority food safety incidents.
Normal Priority Incident:
A food safety incident that is not a high priority.
Outbreak:
An incident in which two or more persons experience similar illness after a common source exposure. An outbreak is identified through laboratory surveillance or an increase in illness that is unusual in terms of time or geography. An outbreak is confirmed through laboratory and/or epidemiological evidence (Source: Canada's Food-borne Illness Outbreak Response Protocol).

3.1.2 Documentation

All activities and decisions are recorded in the Issues Management System (IMS).

3.1.3 Procedure

The Process for Referring Food Safety Investigation Incidents to the OFSR is illustrated in Annex B and starts when an incident is triggered. The inspectorate conducts a preliminary assessment which includes assigning one of the following priorities to the food safety incident:

  1. High Priority with an Early Referral
  2. High Priority
  3. Normal Priority

The priority assigned to a food safety incident may change during the course of an investigation.

At any time during a food safety investigation (i.e. before or after notification to the ARC/RRC or referral to the OFSR), the inspectorate can seek advice and guidance from the ARC/RRC to determine whether there is a potential health risk and on appropriate next steps. The ARC/RRC can also seek advice and guidance from the OFSR at any time.

A. High Priority with an Early Referral

Please refer to Annex A for a list of types of food safety incidents that require an early referral.

The OFSR's responsibility for coordinating food safety investigations and recalls at the national level includes communication with internal and external partners. Some types of food safety incidents require the CFIA to engage with partners at an early stage. An early referral to the OFSR enables timely engagement with these partners.

A.1 Notify the ARC/RRC

The Lead Investigator immediately notifies the ARC/RRC, as per the Area's communication protocol, regardless of the amount of information available on the food safety incident. The Lead Investigator provides the following information:

  • Area of concern;
  • Trigger;
  • Summary of information available to date;
  • If illness, injury or reaction has been reported, the number of cases under investigation and the cases' health status, if known;
  • IMS number, if available; and
  • Brief summary of actions taken to date together with the next actions to be taken

The ARC/RRC reviews the information received in the notification. Where necessary, the ARC/RRC requests additional data or information from the Lead Investigator. If the incident does not require an early referral, the ARC/RRC informs the Lead investigator.

A.2 Early Referral to the OFSR

The ARC/RRC immediately refers the incident to the OFSR by telephone using the emergency number (613-720-5087), followed by an e-mail flagged as "urgent" to CFIA.OFSR-BSRA.ACIA@inspection.gc.ca. The subject line of the e-mail should state "Early Referral". The email should include the information that was provided by the Lead Investigator in step A.1, including actions taken to date and proposed next steps.
Once an incident is referred to the OFSR, a Food Safety Recall Specialist is assigned to the file.

B. High Priority

Please refer to Annex A for a list of high priority food safety incidents.

B.1 a) Determine if Affected Product is Potentially in Distribution

The Lead Investigator, in consultation with their Supervisor, evaluates food safety investigation findings as they are being collected. The Lead Investigator notifies the ARC/RRC as soon as the information indicates that the affected product is in distribution or potentially in distribution. A product is considered to be in distribution when it has left the direct control of the regulated party responsible for that product.

When it is not possible for the Lead Investigator to confirm whether the affected product is under control or on hold by the regulated party, the Lead Investigator will consider the product to be distributed.

If the affected product is in distribution or is potentially in distribution, the Lead Investigator proceeds to B.2 Notify the ARC/RRC

If the affected product is confirmed to be not in distribution, the Lead Investigator proceeds to B.1.b) Determine if Other Affected Products are Potentially in Distribution

B.1 b) Determine if Other Affected Products are Potentially in Distribution

The Lead Investigator, in consultation with their Supervisor, evaluates food safety investigation findings and notifies the ARC/RRC as soon as:

  • the information indicates that other affected products have been distributed or could have been distributed; and/or
  • the affected product was imported and there could be other shipments distributed by the same importer or other shipments distributed by other importers that could be affected by the same problem.

The Lead Investigator will notify the ARC/RRC before taking any sample.

If it is determined that no other affected products could have been distributed, the Lead Investigator follows the established procedures to verify compliance and take appropriate compliance measures.

B.2 Notify the ARC/RRC

The Lead Investigator immediately notifies the ARC/RRC as per the Area's communication protocol and provides the following information:

  • Area of concern;
  • Trigger;
  • A summary of the food safety incident and their findings to date;
  • IMS number; and
  • Brief summary of actions taken together with the next actions to be taken.

Once the ARC/RRC is notified of an incident, the ARC/RRC becomes engaged and provides guidance to the inspectorate, as required.

B.3 Refer to the OFSR

The ARC/RRC immediately refers the incident to the OFSR by sending an e-mail flagged as "urgent" to CFIA.OFSR-BSRA.ACIA@inspection.gc.ca. After regular OFSR working hours (i.e. after 5:00 pm ET), the referral should be done by telephone using the emergency number (613-720-5087), followed by an email. The subject line of the e-mail should state "High Priority Referral". The email should include the information that was provided by the Lead Investigator in B.2, including actions taken to date and proposed next steps.

Once an incident is referred to the OFSR, a Food Safety Recall Specialist is assigned to the file. At this stage, the Lead Investigator and the ARC/RRC may not have all the information required for the OFSR to initiate its activities. The Lead Investigator will continue to lead the food safety investigation and the ARC/RRC will continue to provide guidance and advice as necessary. The OFSR will provide guidance and will initiate its activities when required.

C. Normal Priority

C. 1 a) Determine if Affected Product is Potentially in Distribution

The Lead Investigator, in consultation with their Supervisor, evaluates food safety investigation findings as they are being collected and notifies the ARC/RRC as soon as the information indicates that the affected product is in distribution or potentially in distribution. A product is considered to be in distribution when it has left the direct control of the regulated party responsible for that product.

When it is not possible for the Lead Investigator to confirm whether the affected product is under control or on hold by the regulated party, the Lead Investigator will consider the product to be distributed.

If the affected product is in distribution or is potentially in distribution, the Lead Investigator proceeds to C.2 Notify the ARC/RRC

If the affected product is confirmed to be not in distribution, the Lead Investigator proceeds to C.1.b) Determine if Other Affected Products are Potentially in Distribution

C.1 b) Determine if Other Affected Products are Potentially in Distribution

The Lead Investigator, in consultation with their Supervisor, evaluates food safety investigation findings and notifies the ARC/RRC as soon as:

  • the information indicates that other affected products have been distributed or could have been distributed; and/or
  • the affected product was imported and there could be other shipments distributed by the same importer or other shipments distributed by other importers that could be affected by the same problem.

The Lead Investigator will notify the ARC/RRC before taking any sample.

If it is determined that no other affected products could have been distributed, the Lead Investigator follows the established procedures to verify compliance and take appropriate compliance measures.

C.2 Notify the ARC/RRC

The Lead Investigator immediately notifies the ARC/RRC as per the Area's communication protocol and provides the following information:

  • Area of concern;
  • Trigger;
  • A summary of the food safety incident and their findings to date;
  • IMS number; and
  • Brief summary of actions taken together with the next actions to be taken.

Once the ARC/RRC is notified of an incident, the ARC/RRC becomes engaged and provides guidance to the inspectorate.

C.3 Determine When to Refer to the OFSR

The ARC/RRC evaluates the information received in the notification, and determines when to refer the file to the OFSR.
The file should be referred when:

  • Advice or coordination from the OFSR is required to advance the food safety investigation
  • Sampling advice or sampling coordination from the OFSR is required
  • Hazard is in the process of being confirmed (i.e. laboratory results are pending) and product core information (i.e. product details and distribution) is available
  • Presence of a hazard has been confirmed in a product in distribution. For example through:
    • Unsatisfactory laboratory results
    • Inspection observations (e.g. insect infestation, extraneous material)
    • Document review (e.g. calculations of levels of allergens based on formulations and known percentage of ingredient)

If it is determined that the file is not ready to be referred, the ARC/RRC reevaluates the file on an ongoing basis. The ARC/RRC may determine that the file does not need to be referred to the OFSR as no hazard was identified in products in distribution or potentially in distribution.

C.4 Refer to the OFSR

The ARC/RRC immediately refers the incident to the OFSR by sending an e-mail to CFIA.OFSR-BSRA.ACIA@inspection.gc.ca. After regular OFSR working hours (i.e. after 5:00 pm ET), the referral should be done by telephone using the emergency number (613-720-5087), followed by an email. The subject line of the e-mail should state "Referral". The email should include the information that was provided by the inspector in C.2, including actions taken to date and proposed next steps.

Once an incident is referred to the OFSR, a Food Safety Recall Specialist is assigned to the file.

Annex A: High Priority Food Safety Incidents with Requirements for Early Referral

A high priority food safety incident requires immediate and sustained attention. Work on these incidents takes precedence over all other work and may continue after-hours where necessary.

Notifications for both high priority incidents that do not require an early referral and normal priority incidents will be made to the ARC/RRC as soon as it is determined that affected products have been or could have been distributed. The ARC/RRC will refer high priority incidents immediately to the OFSR to initiate collaboration and gain efficiency in the resolution of the incident.

This table outlines types of high priority food safety incidents and identifies the ones that require an early referral.
Type of High Priority Food Safety Incidents Early Referral Required?
Suspected or confirmed foodborne illness outbreak situation Yes
Hospitalization or death related to food Yes
Reported Table Note 1 illness, injury or reaction related to food Yes
Pathogen detected in food or on direct food contact surface (e.g. Listeria monocytogenes detected on a slicer) No
Undeclared priority allergen No
Toxin in food (e.g. marine biotoxins and Staphylococcus toxins) No
Injurious extraneous material in beverages No
Multiple complaints involving the same product or incident No

Hazard in products targeted at a vulnerable population, i.e.:

  • the elderly or the immunocompromised
  • infants and young children
Yes
Tampering incident (suspected or confirmed) Yes

Food safety incident that may generate or has generated public attention through traditional or social media. Includes:

  • evidence of extensive extraneous contamination or spoilage in a food
  • chemical in a widely consumed product
  • where a complainant has indicated their intention to contact the media
  • any incident considered controversial (i.e. incidents that may be low risk but have high sensitivity from the public such as food irradiation or biotechnology)
Yes
Company initiated (includes foreign companies) product recall, removal or correction of a marketed product for food safety incidents Yes
Public warning issued by other government departments Yes
Food safety incident involving shellfish exported to the United States Table Note 2 Yes

Table Notes

Table Note 1

When reported by a doctor, a public health authority representative or considered valid or potentially valid by the inspector/ARC/RRC. Includes reported allergic reactions to non-priority allergens.

Return to table note 1  referrer

Table Note 2

To enable timely notification by OFSR of the incident to the United States.

Return to table note 2  referrer

Notes:

  • The priority assigned to a food safety incident may change during the course of an investigation.
  • In all situations, but particularly complex ones, the Lead Investigator can consult with the ARC/RRC to determine whether a situation should be treated as high priority. The OFSR is available to assist the ARC/RRC in the determination.

Annex B: Process for Referring Food Safety Incidents to the OFSR

Click on image for larger view
Flowchart - Process for Referring Food Safety Incidents to the Office of Food Safety and Recall. Description follows.

Description of Annex B Process for Referring Food Safety Incidents to the OFSR

This annex illustrates a flow chart that describes the steps for referring food safety incidents to the Office of Food Safety and Recall. The process starts with a trigger followed by a step where the Lead Investigator determines the priority of the food safety incident. The Lead Investigator assigns one of the three following priorities: A) high priority and early referral required; B) high priority; or C) normal priority. Each of these priorities has its own set of steps to follow, which are outlined below.

A) High priority and early referral required

When the Lead Investigator determines that the food safety incident is a high priority and requires an early referral to the Office of Food Safety and Recall, he/she follows step A.1 and immediately notifies the Area Recall Coordinator/Regional Recall Coordinator. In step A.2, the Area Recall Coordinator/Regional Recall Coordinator reviews the information and immediately refers the incident to the Office of Food Safety and Recall.

B) High priority

When the Lead Investigator determines that the food safety incident is a high priority and does not require an early referral, he/she follows step B.1 a) and determines if the affected product is in distribution or potentially in distribution. If the Lead Investigator determines that the affected product is in distribution or potentially in distribution, he/she follows step B.2, and immediately notifies the Area Recall Coordinator/Regional Recall Coordinator.

If the Lead Investigator determines that there are no affected products in distribution, he/she follows to step B.1 b) and determines if there are other affected products that are potentially in distribution. If the Lead Investigator determines that there are other affected products potentially in distribution, he/she follows step B.2 and immediately notifies the Area Recall Coordinator/Regional Recall Coordinator. If the Lead Investigator determines that there are no other affected products potentially in distribution, he/she will verify compliance and follow appropriate procedures.

In step B.3, when the Area Recall Coordinator/Regional Recall Coordinator receives a notification from the Lead investigator, he/she immediately refers the incident to the Office of Food Safety and Recall.

C) Normal priority

When the Lead Investigator determines that the food safety incident is normal priority, he/she follows step C.1 a) and determines if the affected product is in distribution or potentially in distribution. If the Lead Investigator determines that the affected product is in distribution or potentially in distribution, he/she follows step C.2, and immediately notifies the Area Recall Coordinator/Regional Recall Coordinator.

If the Lead Investigator determines that there are no affected products in distribution, he/she follows step C.1 b) and determines if there are other affected products that are potentially in distribution. If the Lead Investigator determines that there are other affected products potentially in distribution, he/she follows step C.2 and immediately notifies the Area Recall Coordinator/Regional Recall Coordinator. If the Lead Investigator determines that there are no other affected products potentially in distribution, he/she will verify compliance and follow appropriate procedures.

In step C.3, when the Area Recall Coordinator/Regional Recall Coordinator receives a notification from the Lead investigator, he/she determines when it should be referred to the Office of Food Safety and Recall. The Area Recall Coordinator/Regional Recall Coordinator will refer the file when advice is needed for coordination and sampling; when product core information is available and laboratory results are pending; and when hazard is confirmed.

In step C.4, the Area Recall Coordinator/Regional Recall Coordinator immediately refers the incident to the Office of Food Safety and Recall.

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