12 replies to this topic

[Scampi]

CFIA has posted an updated version of the FSEP manual to merge with SFCR

 

http://www.inspectio...2/1525869759693

[majoy]

This is good! At least FSEP is still relevant! Thank goodness, FSEP bullets are all reference on our procedures!

[Scampi]

Me too, and we know the Canadian auditors are generally used to the FSEP format

 

p.s. if it were up to me, the whole universe would use this model!  Easy to implement/understand and pretty much all encompassing (less a couple country specific requirements---think bio terrorism)

[RoundEggs]

This is good! At least FSEP is still relevant! Thank goodness, FSEP bullets are all reference on our procedures!

 

 

Yes me 2!

[RoundEggs]

CFIA has posted an updated version of the FSEP manual to merge with SFCR

 

http://www.inspectio...2/1525869759693

 

Good Morning!

 

Thanks for posting this. 

 

By the way I finally did find out when we can apply for a license and it is on December 10 - CFIA sent a letter out. 

[Scampi]

Hey Roundeggs, could you post the letter here perhaps?

That's great news!

 

I was on a call in last week about SFCR and I think alot of the issue is that they have been so focused on NEW business, the forgot about everyone else and all the questions we may have!

 

I have been waiting a week to get a response about shipping containers and labels required........old regs spell it all out...........new regs.....zippo

[RoundEggs]

I was concerned that our CCP's would need to be validated in some manner as they are based on a regulation that in January will be null and void. 

 

 

I had asked our CFIA inspectors about this and they told me any CCP based on an old regulation will still be considered to be effective. 

They also said that the examples of preventative control plans based on food commodity can be considered to be a guidance document - so if your limits or specs are in the document then you can still base controls and CCP's off of them and it is considered valid - just an FYI.

[RoundEggs]

 CFIA_ACIA - Letter.DOCX   31.88KB   32 downloads

Hey Roundeggs, could you post the letter here perhaps?

That's great news!

 

I was on a call in last week about SFCR and I think alot of the issue is that they have been so focused on NEW business, the forgot about everyone else and all the questions we may have!

 

I have been waiting a week to get a response about shipping containers and labels required........old regs spell it all out...........new regs.....zippo

 

[RoundEggs]

 I believe that all registered establishments can apply on December 10. 

Edited by RoundEggs, 28 November 2018 - 02:12 PM.

[Scampi]

Once I get a response about the shipping containers I will post it here too

[AKmuz]

The evidence that CFIA is saying is needed for a control measure is effective which could either be a PRP like sanitation or GMP, would they be looking for validation or verification activity for those. 

 

I remember that in one of there sessions they mentioned that for plants that already are under FSEP or QMP, the validation previously done would be okay as the process is not changing. Is this still relevant?

 

Lastly, how CFIA has now provided guidance for FSEP correlating with SFCR what does that mean? If a plant is following FSEP and have all of the elements as set out in the FSEP, do we need to create a document stating how this is relevant to the SFCR. I am asking as I have a matrix which relates the FSEP PRP bullets to our relevant procedures, do we need to provide more info on our FSEP matrix?

 

Looking for some guidance..... :)

[Scampi]

The evidence that CFIA is saying is needed for a control measure is effective which could either be a PRP like sanitation or GMP, would they be looking for validation or verification activity for those.  Yes, if you are using say sanitation as a control, then you need records for when the activity occurred and a pre op inspection (that can just be a visual inspection)

 

I remember that in one of there sessions they mentioned that for plants that already are under FSEP or QMP, the validation previously done would be okay as the process is not changing. Is this still relevant?  Yes, a validation is always applicable UNLESS the process/ingredients etc change

 

Lastly, how CFIA has now provided guidance for FSEP correlating with SFCR what does that mean? If a plant is following FSEP and have all of the elements as set out in the FSEP, do we need to create a document stating how this is relevant to the SFCR. I am asking as I have a matrix which relates the FSEP PRP bullets to our relevant procedures, do we need to provide more info on our FSEP matrix?  I have no plans to change my FSEP program at all. My inspector said the only item that may need pulled out of FSEP and spelled out is the market fairness provision..........which should already be covered (labelling/grading/standards of identity)

 

Looking for some guidance..... :)

 

 

If you google CFIA SFCR webinars, you can find a page where they are posting webinars they are hosting. Also and industry org that you belong to may also be hosting sessions. I know NSF is, but they are VERY expensive and I think probably unnecessary to those of us already following FSEP and/or already a registered company with CFIA

[AKmuz]

Thank you very much for your quick response. I was going through the guidance for FSEP that CFIA has added on to their website.  We are also just spelling the market fairness separately as well.