10 Tips For CFIA PCP Plan Development

Why Read Our 10 CFIA PCP Plan Development Tips?

The Safe Food for Canadian Regulations (SFCR) is fully in effect as of July 2021. What this means for food businesses is that they need to develop, document, and maintain a PCP to ensure that food products are safe to eat. A PCP needs to be developed, documented, communicated and maintained. This article showcases our Top 10 Tips for PCP Plan Development.

Before we go ahead with the details,

Tip #1:

Know what you need for the SFCR plan from these three SFCR components:

1. Preventive Control Plan
2. Customer Protection Plan
3. Traceability Plan

You may check the requirements for your SFCR plan using the following timelines based on your food categories or by using the following interactive tools:

• SFCR timelines for food categories
• Does your business require a license?
• Does your business require a preventive control plan?
• Does your business require traceability records?

Be sure to save a copy of your assessment if you are using the above interactive tools. You can print-screen and keep a copy of the assessment.

So, what do you need? An SFC license? A Preventive Control Plan? A Traceability Plan? Or combinations of them. No worries, we have you covered.

Tips for Components of Your SFCR Plan

Preventive Control Plan (PCP) is a plan that describes the products’ information, raw materials (ingredients, packaging materials) and chemicals, process flow, and traffic flow. Further, consider the hazard and Preventive control activities that must take place to ensure the product is safe and meet SFCR requirements. The process of developing a Preventive Control Plan is similar to the HACCP program development but utilizes the SFCR PCP template that can be downloaded at the CFIA website.

You must use the Maintenance and Operations of Establishment Checklist and develop the procedures to comply with SFCR requirements under sections 50 to 85, along with the PCP plan. A PCP plan only describes the framework of your process controls. It states the summary of how you can control the identified hazards.

It is like building the frame of the house or an unrenovated house. We can’t call it a home.

If you are familiar with the HACCP program, you will realize quickly that the SFCR requirements and regulations under sections 50 to 81 are the prerequisite programs. Sections 82 to 85 deal with the investigation and notification, and complaint management procedures. These requirements are very straightforward. You may adapt your HACCP procedures to meet these section-specific requirements (and incorporate the missing SFCR requirements for these sections).

If you are not familiar with HACCP plan development, here is a guideline from CFIA for developing your Preventive Control Plan.

In any case, you must ensure that you have procedures and records that cover sections 50 to 85, for a complete Preventive Control Plan. Once you have the procedures for sections 50 to 85, you can then fill up the Maintenance and Operation of Establishments Checklist to indicate whether or not the requirements of the section are met to support the PCP plan.

Tips #2-4:

How to Work on PCP Plan Development -the Strategies

• Start building a Preventive Control framework and use the section-specific requirements and regulations to support the Preventive Control Plan.
• Use the CFIA reference database for hazard determination
• Take your time for the PCP plan development -it can be tedious to develop continuously on an 8-hours workday. Take breaks when you are developing the PCP plan and evaluate your hazard assessment and mitigation strategies

Customer Protection Plan looks into the food product labels, claims, and regulatory requirements for specific food categories. The customer protection plan template can be downloaded here.

With a customer protection plan, it is important to note and review the following:

• Your product label must follow CFIA label requirements and regulations, including the font size for weight, common name, weight, or volume symbols
• Common name must not be misleading and follow the requirements for the standard of identity
• All product claims must be substantiated with evidence.
• It is important to note that certain logos such as halal, kosher, organic, etc. may be under copyright, and the use is exclusive to the specific certified products
• Certain health claims are prohibited. See the full list here
• Avoid visuals that mislead the consumer
• Review any relevant product-specific food categories requirements and regulations here

Tips #5:

In your customer protection, you should document how you review the product labels and evaluate if the products meet the labeling and the listed requirements for product-specific food categories. Remember to include the record that you will use to document these activities.

Traceability Plan

Traceability is a very important step to ensure that any questionable or harmful products can be immediately traced. Further, assisting the recall process to ensure these products are recalled from the market as soon as possible to prevent further harm.

With traceability requirements, you must know your responsibility. As the product owner, you are responsible for all the products you manufacture and sell. This includes tracking all the products. The requirement for traceability is to trace one step forward and one step backward.

• What it means to you as a manufacturer is you must be able to trace back to the ingredient provider and lot code and trace forward to the entities that you shipped them to.

Tips #6:

You must document your traceability and recall programs using these 6 steps:

1. Identifying the key personnel and responsibilities in your traceability and recall program. Include key personnel off-hour contact information.
2. Identify how to read the product lot code and how the product lot code changes throughout your entire process from receiving to shipping.
3. Identify relevant documents and records that would be used to trace the products for both traces backward and trace forward activities.
4. List the key customer contact and CFIA information.
5. Indicate how you test the system, typically using a mock recall.
6. Document procedure for evaluating and/or initiating a withdrawal or product recall.

Tips #7: Use this recall guidance from CFIA to guide you through your recall program development

Apply for an SFC license through myCFIA

Once you have the PCP Plan development, procedures, and forms completed to comply with the three components of the SFCR plan, you can then apply for an SFC license. You can apply for an SFC license online through the myCFIA website. To create an account and business profile, you would need your business information, such as your CRA business number and proof of authority forms.

Tips #8-10:

• You may check the guideline for application for an SFC license for the requirements mentioned above here.
• An SFC license is specific to the food categories (e.g. dairy, fish, egg, etc), and activities (e.g. manufacturing, packaging, slaughtering, importing, exporting, etc.). You must ensure that you apply for the right categories. The guidelines above provide an written explanation of how to choose the food categories.
• Licensing structure: It is often confusing to choose the license structure. Check this video to determine if you want to choose single or multiple licenses. Why do you want to take some time to choose the licensing structure? If you have a single license for all the products, any regulatory actions for a single product will apply to all the products under the license. Consider having multiple business licenses if you have multiple product categories or activities, especially if you also import products into Canada.

What do you do after you obtain your SFC license?

You have got your SFC license. Now what? You would need to ensure that you continue to comply with SFCR requirements, including:

1. Maintaining your SFCR plan

The SFCR plan is not a display for obtaining an SFC license. They must be followed thoroughly (and updated when there is any change with the product, ingredients, processing, or supplier and product label).

You must ensure that all the procedures that you have developed are approved and implemented. All the activities indicated in the SFCR plan must be documented. These include all the requirements for the Preventative Control Plan, Customer Protection Plan, and Traceability Plan.

Tips: If the activities are not recorded, they did not happen. That means you do not follow the SFCR plan that you have developed and prepared.

2. Renew your SFC license before the expiry

Tips: Bookmark your SFC license expiry date (at least 2 months before and 2 weeks before the expiry) on your calendar. Then, you would not miss renewing your SFC license.

3. Update your SFC license scope if you work with new food categories or expand your activities (under the SFCR definition)

Tips: If you are an importer, you must also provide the SFC license to your broker to be displayed with your product shipment to prevent delays in customs clearance when the products arrive in Canada.

Please do not import any food products into Canada without the relevant SFC license (except if they meet these exemptions). According to the CFIA, you cannot apply for the SFC license at the border. It would be troublesome to deal with. In addition, the cost of dealing with a held shipment can be extremely costly.

You must ensure that the SFC license is current and valid. Check for SFC licensed facility here.

How do I know my SFCR plan complies with the Safe Food for Canadian Regulations?

To ensure that your SFCR plan complies with the SFCR requirements, you may choose to learn about the SFCR regulations, hire full-time personnel knowledgeable about the SFCR plan requirements or let us help you.

SFPM Consultant can help with your SFCR plan review, including Preventative Control Plan review, Customer Protection Plan review, and Traceability Program review.

Remember, it is not sufficient to have a Preventative Control Plan only. You would need to ensure that you have procedures available to support the requirements of Sections 50 to 81 for your SFCR plan.

Here are some resources for you to get started with your SFCR program development and review:

We know how tedious and time-consuming to write a full SFCR program and like to ensure that you can devote the time to implement the procedures instead. Therefore, we offer two services for you:

• SFCR program template -Customize a ready-made template with your facility information -Best economic options
• Full SFCR program development -get procedures that are ready to use, with minimal editing needed. Simply review and approve the procedures and forms. – The best option for immediate implementation.

I am not familiar with SFCR program implementation -how can SFPM Consulting help?

We understand that developing and maintaining full food safety program requirements are new to many food businesses. Therefore, with our full program development, we offer one hour of complimentary training on using the procedures and forms. Get started the easy way. Click the button on the right to start a chat with us or book a meeting with us here.

Love to hear about you and your business, and we appreciate an opportunity to get to know you.