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Canadian Food processor exporting to US


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#1 patwork

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Posted 08 June 2016 - 10:06 PM

As a Canadian Food Processor, what do I have to do to be compliant with FSMA.


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#2 Scampi

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Posted 09 June 2016 - 06:23 PM

That solely depends on what you are processing


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#3 patwork

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Posted 10 June 2016 - 04:52 PM

Sorry, of course.  We process flax, both as ready to eat and as an ingredient.   We are SQF level 2 certified  and are considered a small facility. 

 I do believe, I must attend the 2.5 day training session to become a PCQI and develop and implement a preventative controls program, but I am being told by others in my industry that this is not required. 

Their reasoning is:   1) That we follow Canadian guidelines and the US has just recently recognized Canada's regulations as equivalent to the US. and therefore already meet their requirements.  and

2) That we have never before had to write our programs to match the US regulations, if this is the case, then do we have to write our program to meet the requirements of every country we ship to.

Both arguments do seem reasonable, but from my research, I think I must become a PCQI and develop the program. 

I hope some one can give me some clarification on this on this.


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#4 Silvialima

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Posted 21 March 2017 - 08:38 PM

  Hello Pat,

 

I know your question was months ago, but I was hoping we can still exchange some information. Since FDA recognized Canada's food safety system as similar or comparable to the US, Canadian producers have modified requirements. FDA states that importers have documentation on file showing that either:

 

1) Canadian Producers appear on a list, issued by CFIA, of facilities that are in good compliance, or

2) Canadian Producers have designations, issued by CFIA, as being in good compliance standing. 

 

Based on this, I believe (not 100% sure because FDA doesn't have too much guidance out there), that Canadian suppliers should be good if they provide their last CFIA inspection audit showing that they didn't have any major non-conformance, and that they are in good compliance standing.

 

 I don't have idea how frequent CFIA inspects food facilities in Canada. So, I don't know how easy could be to get those CFIA inspection reports. Besides CFIA inspection reports, are you aware of what Canadian producers have on file from CFIA that could show a good compliance standing? 

 

Thank you so much!

 

Silvia


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#5 majoy

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Posted 02 May 2017 - 05:56 PM

I know this topic dates back a month ago.

 

So for Canadian manufacturers, if your customers requested for a copy of your food safety plan, do you send the existing CFIA compliant HACCP plan?

 

One of our US customers is requesting a food safety plan, and I assume this is due to changes in FSMA. They are checking if we are compliant with the current regulation. Can I just say that because US recognizes Canadian food safety system as similar or comparable to theirs, that our HACCP Plan is compliant to FSMA? I have doubts our customer will accept this justification.

 

I already started to revise our HACCP plan to HARPC which meets both US, CFIA and 3rd party GFSI requirements but still have doubts doing this.


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#6 Silvialima

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Posted 15 May 2017 - 06:14 PM

Hello Majoy,

 

You don't need to send them your food safety plan. The regulation requires that the US importer needs to have documentation on file showing that the supplier is in good compliance standing with its food safety authority (in this case CFIA). The US importer doesn't have to review any food safety plan. Documentation such as your last CFIA inspection report showing that all minors were already corrected should be enough. 

 

Hope this helps. 

 

Silvia


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#7 Scampi

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Posted 15 May 2017 - 07:08 PM

Majoy, I would suggest you follow the FSEP manual, if you are not doing so already (you probably have monthly/quarterly inspections). With the new Safe food for Canadians regulations coming down the pipe here, it is your most sure fire way to ensure you meet Canadian and US regulations. IMHO, FSEP IS HARPC, then all your bases are covered

 

http://www.inspectio...7674768_eng.pdf


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#8 majoy

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Posted 23 May 2017 - 07:34 PM

Majoy, I would suggest you follow the FSEP manual, if you are not doing so already (you probably have monthly/quarterly inspections). With the new Safe food for Canadians regulations coming down the pipe here, it is your most sure fire way to ensure you meet Canadian and US regulations. IMHO, FSEP IS HARPC, then all your bases are covered

 

http://www.inspectio...7674768_eng.pdf

 

Hi Scampi,

 

Thanks for your response. We follow and in compliance with FSEP, and CFIA inspector is in-house daily in the facility.

 

I have decided against changing anything and just submitted our current food safety plans to US customers and have double checked our good standing with US FDA.

 

I attended one session for SFCR and CFIA said, once regulations are enforced for SFCR, FSEP will be scrapped. So I'm waiting to see what will happen next...


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