On July 7, 2013, the Canadian Food Inspection Agency (CFIA)
released a discussion document: A New Regulatory Framework for
Federal Food Inspection (Regulatory Framework Document) and is
asking consumers and food industry stakeholders to comment on
elements of the Safe Food for Canadians Action Plan which aim to
strengthen and modernize Canada's food safety system.
The consultation will provide input into the regulations that
are being developed in connection with the Safe Food for Canadians
Act (SFCA) – legislation that was passed in November 2012 but
which is still not in force. The regulatory regime that will
underlie the new legislation is still in the development
Consistent with regulation in other federal areas, the proposed
food inspection regulations under the SFCA will also be supported
by guidance documents, which will provide examples of how outcomes
could be achieved. The proposed regulations will have requirements
that will apply to all federally regulated food commodities traded
inter-provincially and internationally such as licensing,
preventive controls, traceability, recordkeeping, and a review
The Regulatory Framework Document describes how existing federal
licensing requirements would be extended to encompass all parties
who import food commodities or prepare them for interprovincial
trade. All importers of food commodities would be required to be
The Regulatory Framework Document notes that "Canada
requires a food safety system capable of continuous improvement
that evolves with new food safety practices, technology and other
developments in industry to deliver the best possible protection
for Canadians from food safety risks." It is focussed on
industry responsibility for safe food commodities and requires
globally recognized HACCP-based approaches best designed to deliver
safe food commodities.
The Regulatory Framework Document also looks to provide industry
with flexibility for food safety approaches within facilities
(recognizing that when it comes to food manufacturing,
"one-size" does not necessarily fit all) and enables
rapid response to emerging food safety risks. Key to the Regulatory
Framework Document is also recognition of the need for alignment
between provincial/territorial governments and international
trading partners, in particular, the United States, to support
greater market access.
The Regulatory Framework Document describes new requirements in
the following areas:
processes and product
sanitation and pest control
hygiene and competencies
equipment design and maintenance
physical structure and maintenance
receiving, transportation and storage; and
recalls, complaints and recordkeeping.
While some of the requirements in the Regulatory Framework
Document will already have been implemented through food
manufacturing controls plans (such as HACCP plans) all food
importers, distributors, manufacturers and retailers should review
the Regulatory Framework Document in the context of their own
With respect to recalls, complaints and record-keeping, for
example, the Regulatory Framework Document requires license holders
develop, implement and maintain written procedures for the
recall of food products,
develop and maintain any product distribution records that are
necessary to facilitate the location of products in the event of a
review the product recall procedures and to conduct a product
recall simulation at least once a year, and
make available to the inspector, in a readily accessible format
and location, a copy of the product recall procedures, the results
of the product recall simulations for the previous year and the
product distribution records for at least one year after the expiry
date on the label or container or if there is no expiry date, for
at least two years after the date of sale.
The focus of the Regulatory Framework Document is on compliance
promotion and on industry responsibility for quality systems at all
stages of the food manufacturing, distribution and delivery
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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