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CFIA Meat Inspection Regs-New Directive-Construction Materials

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#1 stim

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Posted 16 September 2014 - 12:41 PM

Hello All,

 

I am looking for insight into this new directive put forward by the CFIA which eliminates their Approved Supplier List and places the onus on producers to prove that a material brought into the plant is safe for use. This includes the materials used for construction, packaging and processing aids.

 

I am ok handling the latter two materials, but when it comes to approving every construction material that is used in our plant I am stuck. The maintenance department is responsible for purchasing what they need, and while I would like to believe that they consult a list, I have great doubts. Now that we will be required to not only ensure that something is on a list, but supply a letter of guarantee or some other proof of compliance I fear that this will get overlooked.

 

I plan on writing an SOP for approving purchase of construction materials and having maintenance sign off on it, but I do not know how to ensure that the approval process works further than that. As you know maintenance departments are a beast unto their own!

 

Does anyone have any success stories of how they deal with approving materials maintenance uses in the plant?

 

Thanks so much!

 

http://www.inspectio...7/1404169645850


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#2 stim

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Posted 16 September 2014 - 06:58 PM

bump


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#3 fcchoi

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Posted 17 September 2014 - 07:44 AM

use the procurement/purchasing dept instead to spearhead the program by having all suppliers of spare parts/tools used by maintenance to submit your company's version of supplier qualification questionnaire/checklist instead.

with that you will be able to solicit the info you need, tq


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#4 MCIAN

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Posted 17 September 2014 - 07:56 AM

Hi Stim! Welcome to IFSQN!

 

IMO, you need to properly train the one in charge of procuring maintenance/ construction supplies about the parameters they need to look for to quality the items as 'safe' for use. That would be the first line of defence ... then take off from there with documented procedures.

 

 

Regards.

 

 

:cool:


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#5 stim

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Posted 17 September 2014 - 12:55 PM

Thank you,

 

I am looking into training a specific individual for this task. I think it is best to keep things small and contained with one purchaser. There has been talk about expanding who can create POs and I am hoping that doesn't happen!


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#6 Scampi

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Posted 28 November 2014 - 07:46 PM

There needs to be a centralized system by which ALL purchases are approved before they are ordered or at the very least, unloaded. My SOP requires that the person at the loading platform MUST verify that the products are acceptable for use PRIOR to receiving them, which of course means they will probably come to me to ask which is better than the alternative. We also have a follow up validation where by management reviews ALL purchases made since the last review to ensure that they were accepted by CFIA. The only thing left is to train the maintenance buyer that asking for a letter MUST be a part of the process. You might be surprised at how many products really have been approved!!!


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#7 Tony-C

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Posted 29 November 2014 - 05:57 AM

Hello All,

 

I am looking for insight into this new directive put forward by the CFIA which eliminates their Approved Supplier List and places the onus on producers to prove that a material brought into the plant is safe for use. This includes the materials used for construction, packaging and processing aids.

 

I am ok handling the latter two materials, but when it comes to approving every construction material that is used in our plant I am stuck. The maintenance department is responsible for purchasing what they need, and while I would like to believe that they consult a list, I have great doubts. Now that we will be required to not only ensure that something is on a list, but supply a letter of guarantee or some other proof of compliance I fear that this will get overlooked.

 

I plan on writing an SOP for approving purchase of construction materials and having maintenance sign off on it, but I do not know how to ensure that the approval process works further than that. As you know maintenance departments are a beast unto their own!

 

Does anyone have any success stories of how they deal with approving materials maintenance uses in the plant?

 

Thanks so much!

 

http://www.inspectio...7/1404169645850

 

Hi Stim,

 

I think that you are along the right lines and the easiest way to deal with this is to have SOPs for purchasing and receipt that require a letter of guarantee, clearly stipulating the requirements as per the FSEP Manual.

 

From the CFIA website:
How can meat industry demonstrate compliance with the regulatory requirements for use of safe and suitable construction materials, packaging materials and non-food chemicals in their establishments?
Operators of federally registered meat establishments will have following three options to demonstrate to the CFIA inspectors that the construction materials, packaging materials and non-food chemicals used in their establishments are safe and suitable for their intended use and that they meet all regulatory requirements:
Continue to use products that are already pre-approved by the CFIA or Health Canada and are included in the Reference Listing, provided they continue to use the product for its intended and previously approved use (formulation, label directions, etc.).
Have on file a Letter of No Objection (LONO) or Letter of Acceptance (LOA) provided by the CFIA or Health Canada for the product used. Health Canada will continue to assess packaging materials and non-food chemicals (not construction materials) on a voluntary basis if requested by the industry.
Have on file a Letter of Guarantee (LOG) from the supplier of the product or material as described in the Food Safety Enhancement Program (FSEP) Manual.


Food Safety Enhancement Program Manual CFIA 2014-07-01
B.2.1 Purchasing/Receiving/Shipping
Letters of guarantee for construction materials used in rooms where food is manufactured, stored, packaged, received or shipped, must at least contain the following information:
• The name of the firm issuing the letter of guarantee and date of issue;
• The identification of the construction material by brand name or code number;
• A statement that the construction material is cleanable, is free of any noxious constituents and will not be a source of food contamination through its life cycle;
• A statement that the firm will provide, when requested by the Canadian Food Inspection Agency, all supporting documents to demonstrate that the material is safe and suitable for use as intended (see note 2);
• Where applicable, directions for use in food establishments;
• The signature of an official of the firm providing the letter of guarantee.

 

Regards,

 

Tony


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