Food Safety Enhancement Program Manual
Section 2 - Responsibilities
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2.1 CFIA responsibilities
Under FSEP, the responsibilities of CFIA are to:
- Recognize federally registered establishments' HACCP systems.
- Verify the implementation, effectiveness and maintenance of the HACCP system in federally registered establishments.
- Verify compliance to regulations, policies and directives in federally registered establishments.
- Provide competent staff for the recognition and verification of establishments' HACCP system.
- Ensure consistency of the recognition processes and consistency of the verification of compliance in all federally registered establishments.
- Provide the resources to enable the timely recognition of HACCP systems.
- Consider any copies of the establishment HACCP system documentation that are obtained by an inspector on grounds that they contain information relevant to the administration or enforcement of applicable Acts and Regulations as Agency original records with mandatory confidentiality and maintenance requirements as stated under the Library and Archives of Canada Act.
2.2 Establishment responsibilities
2.2.1 Establishment senior management commitment
Under FSEP, the responsibilities of the establishment's senior management are to:
- Ensure that the establishment complies with all regulatory and CFIA program requirements.
- Ensure that the establishment's HACCP system complies with all requirements of the FSEP manual.
- Ensure that food safety is fully embedded in every level of their business.
- Demonstrate a commitment to their HACCP system by:
- providing the necessary resources and the time required for the development, implementation and effective maintenance of the HACCP system and for the training of appropriate staff in their area(s) of responsibility;
- providing the financial resources to ensure that the construction of the premises, its internal fittings, the installation of the equipment, the maintenance of the premises and equipment, as well as the supplies required to perform the above, meet all applicable regulatory and program requirements and support the implementation and effectiveness of the HACCP system;
- designating personnel that have defined responsibilities and the authority to initiate, implement and record corrective actions;
- communicating to employees the importance of meeting the requirements of the establishment's HACCP system, including any regulatory and CFIA program requirements related to food safety, and the importance of reporting problems to the identified person(s);
- allowing designated management personnel to enforce compliance of the food safety procedures identified in the establishment's HACCP system for any person entering or working within the facility;
- allowing the continuous improvement of the HACCP system to ensure its effectiveness through the validation of control measures, by making changes to the system as a result of corrective actions or reassessment activities, and through the use of HACCP team meetings;
- providing sufficient time for HACCP team meetings.
- Ensure all information and documentation is accessible to the CFIA staff during recognition processes and subsequent verification activities.
A letter of commitment shall be included in the HACCP System documentation. The letter of commitment shall be signed and dated by a representative of senior management at the establishment with authority to ensure adherence to responsibilities described in this section. The letter shall be signed on an annual basis and when that senior manager is replaced. The letter must:
- confirm senior management's full support for developing, implementing and maintaining an effective HACCP system;
- confirm the establishment's commitment to produce food in compliance with all regulatory and CFIA program requirements.
2.2.2 HACCP team leader
Senior Management shall appoint a HACCP team leader who, irrespective of other responsibilities, shall have the responsibility and authority:
- to ensure that the HACCP system is developed, implemented, maintained and reassessed;
- to be the main HACCP related contact with CFIA staff.
Note: It is recommended that the HACCP team leader be on the premises on a regular basis. Where the HACCP team leader is not at the establishment on a regular basis, an on-site liaison person must be identified to take on these responsibilities and authorities.
2.2.3 HACCP team
The HACCP team consists of assigned personnel that have adequate knowledge and or experience. Representing various areas within an establishment such as production, sanitation, quality control, food microbiology and equipment maintenance, they are responsible for assisting the HACCP team leader in developing, implementing and maintaining the HACCP system.
The number of people on the HACCP team may vary based on the complexity of the process and the number of employees at the establishment. In small plants with a limited number of staff, the HACCP team may be made up of a few people that have a good understanding of the facility and its products, as well as HACCP.
The HACCP team should meet on a regular basis to discuss, among other points:
- Changes in the HACCP System
- Deficiencies in the HACCP System
- Root causes
- Action plans
- CFIA concerns
It is recommended that representatives from senior management participate periodically in HACCP team meetings to be aware of the HACCP system performance within their facility.
The HACCP team leader should, at a minimum, be knowledgeable of:
- Food safety hazards common to the establishment's products and processes
- Applicable regulatory and CFIA program requirements
- FSEP requirements
- HACCP principles
The HACCP team should be knowledgeable of:
- The HACCP principles
- The technology or equipment used on processing lines
- The equipment preventative maintenance
- The practical aspects of food operations
- The flow of processes
- The sanitation techniques
- The applied aspects of food safety hazards as they relate to the process
Designated employees involved in the delivery of procedures developed in response to the requirements of the prerequisite programs, CCPs, process controls and reassessment activities must, at a minimum, be knowledgeable of their roles and responsibilities within the HACCP system.
It is important to note that the ultimate responsibility for a food safety system resides with the establishment operator and their employees. They cannot rely solely on the expertise of external consultants.
2.2.5 HACCP system performance reporting
A documented procedure shall be established which defines how the HACCP system performance is communicated to the senior manager who has signed the letter of commitment (see section 2.2.1).
The procedure shall include as a minimum:
- The name or title of personnel responsible to communicate the HACCP system performance and CFIA verification results.
- The frequency of communication.
- The method used to communicate the information.
- The method used to demonstrate to the CFIA that the communication took place.
The main objectives of the communication process are to:
- Make establishment senior management aware of the overall HACCP system performance within their facility.
- Convey the information required for senior management to provide support and supply resources to the HACCP team to ensure issues are corrected.
2.2.6 Signing and dating the HACCP system documentation
The first page of the prerequisite programs, HACCP plan(s) and process control(s) shall be signed and dated by the HACCP team leader or senior management representative:
- Upon initial implementation;
- Upon any modification that has an impact on the control of a hazard;
- At least annually, upon reassessment.
All pages of the prerequisite programs, HACCP plan(s), process control(s) and supporting documentation linked to the HACCP system (standard operating procedures, work instructions, etc.) shall be dated:
- upon initial implementation;
- upon any modification.
The signature shall signify that the prerequisite programs, HACCP plan(s), process control(s) and supporting documentation have been approved by the HACCP team leader or senior management representative and will be implemented as specified.
The establishment's HACCP team leader or senior management representative may utilize an electronic signature or a stamp in lieu of their signature. The stamp must have their actual signature and may also incorporate the date. Procedures must be in place to ensure control over access and use of the stamp(s). The establishment must implement appropriate controls to ensure the integrity of electronic signatures.
2.2.7 Control of records
Records shall be maintained to provide evidence of conformity to requirements and evidence of the effective operation of the HACCP system.
Records maintained on computers are acceptable provided the establishment implements appropriate controls to ensure the integrity of the electronic data and signatures.
Unless otherwise specified in CFIA program requirements, records shall be retained for at least one year or for the shelf life of the product, whichever is greater.
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