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Wondering how you are developing your Preventative Control Plan?

Example of your PCP

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#1 Jim E.

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Posted 23 November 2018 - 11:10 PM

Hello all you Canadian Processors.  Wondering how you are developing your PCP.  I have a HACCP plan but struggling with which direction to go with the new SFCR requirements.  My first thought is to just complete a cross reference matrix.  But then we get into the HA and the need to identify control measures and if it needs to be listed on my current HA.  Anyone care to share examples?  Thanks in advance.

 

:shutup:  :shutup:  :shutup:  :helpplease:



#2 Charles.C

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Posted 23 November 2018 - 11:13 PM

Hello all you Canadian Processors.  Wondering how you are developing your PCP.  I have a HACCP plan but struggling with which direction to go with the new SFCR requirements.  My first thought is to just complete a cross reference matrix.  But then we get into the HA and the need to identify control measures and if it needs to be listed on my current HA.  Anyone care to share examples?  Thanks in advance.

 

:shutup:  :shutup:  :shutup:  :helpplease:

 

Hi Jim,

 

Repetition I know but a little context may assist -

 

product ?

process ?


Kind Regards,

 

Charles.C


#3 Jim E.

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Posted 23 November 2018 - 11:21 PM

Well if you are in a Canadian market it does not really matter, every manufacturer basically will be falling under the same new program, SFCR.  Be it meat, vegetable, honey etc.  But for clarity we area vegetable processor that makes and packages frozen product. Just not sure how much I have to revise my current programs to meet the new regulations and start date is nearing. 



#4 Charles.C

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Posted 23 November 2018 - 11:32 PM

Well if you are in a Canadian market it does not really matter, every manufacturer basically will be falling under the same new program, SFCR.  Be it meat, vegetable, honey etc.  But for clarity we area vegetable processor that makes and packages frozen product. Just not sure how much I have to revise my current programs to meet the new regulations and start date is nearing. 

 

Hi Jim,

 

Thanks. Must admit I would rarely equate meat and vegetables other than on a plate. :smile:

 

i guess you have already seen the, I think, semi-deluge of posts/links from Scampi on this topic ?.


Kind Regards,

 

Charles.C


#5 Scampi

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Posted 26 November 2018 - 02:01 PM

Hi Jim

 

If you've already been using an FSEP model for your HACCP plan, the only item you need to ensure you've covered is the "market fairness" requirement (as per our inspector) 

 

http://www.inspectio...1488527_eng.pdf

 

It is probably all covered in your HACCP plan in other words in other sections, but having this 

http://www.inspectio...488527_eng.pdf 

document completed may expedite inspections

 

I'm guessing your already inspected under the processed products regs?


Because we always have is never an appropriate response!


#6 dugaucher

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Posted 26 November 2018 - 03:16 PM

Hi all,

 

The new SFCR targets mostly companies that do not have a food safety system.

 

Previously, the CFIA used to require a HACCP Plan (Under the FSEP model) for everybody. Now the minimum required is a Preventive Control Plan (PCP) which is a little bit less complex than a HACCP Plan.

 

If you already have a developed HACCP Plan, it would meet the requirement of the SFCR.

 

Now providing you start from the scratch, you may consider going ahead with PCP.


Dugaucher

#7 RoundEggs

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Posted 28 November 2018 - 03:51 PM

Hi all,

 

The new SFCR targets mostly companies that do not have a food safety system.

 

Previously, the CFIA used to require a HACCP Plan (Under the FSEP model) for everybody. Now the minimum required is a Preventive Control Plan (PCP) which is a little bit less complex than a HACCP Plan.

 

If you already have a developed HACCP Plan, it would meet the requirement of the SFCR.

 

Now providing you start from the scratch, you may consider going ahead with PCP.

 

FSEP is not required for everyone. The only processing facilities where FSEP is mandatory is meat - for all other food processing it is voluntary. FSEP is for registered processing facilities only. 

 

Previously a registered processing facility not processing meat could operate without FSEP so long as they were meeting the applicable regulations. 

 

Now all processing facilities must meet the requirements of the SFCR and have PCP's. Yes if you have FSEP you are already meeting the requirements of SFCR.



#8 RoundEggs

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Posted 28 November 2018 - 04:12 PM

Hi Jim

 

If you've already been using an FSEP model for your HACCP plan, the only item you need to ensure you've covered is the "market fairness" requirement (as per our inspector) 

 

http://www.inspectio...1488527_eng.pdf

 

It is probably all covered in your HACCP plan in other words in other sections, but having this 

http://www.inspectio...488527_eng.pdf 

document completed may expedite inspections

 

I'm guessing your already inspected under the processed products regs?

 

All that market fairness is is ensuring proper labelling, weight declaration etc. 

 

If you have packaging procedures, labelling procedures etc then this requirement is being met.

Especially if you have FSEP and third party audits -you are definitely meeting this requirement. There is no need to list them all out - I am not sure why an inspector would say that is required. The procedures that you would have in place to ensure market fairness are covered by FSEP bullets in the prerequisite programs. 



#9 Scampi

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Posted 28 November 2018 - 04:26 PM

Round Eggs, they have listed a slightly revised format of FSEP as a program to follow to help write the PCP and allow those of us who adopted it to keep using it


Because we always have is never an appropriate response!


#10 RoundEggs

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Posted 28 November 2018 - 05:10 PM

Round Eggs, they have listed a slightly revised format of FSEP as a program to follow to help write the PCP and allow those of us who adopted it to keep using it

 

Yes I know I have reviewed it.  What they are referring to in that document is Section 89 (1)(a) and b of Part 6 of the SFCR. This section outlines the content of the PCP. It states that you must have a description of measures for ensuring that applicable requirements ( it lists them) are met. 

 

I would think that if you have procedures, pre-req's and SOP's in place to meet these requirements ( which you do if you have FSEP) would meet "the description of measures taken" that they are looking for here.  Listing them all doesn't seem necessary - that is my interpretation anyway. I have asked CFIA inspector to provide clarification. 



#11 RoundEggs

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Posted 28 November 2018 - 06:05 PM

Link below discusses writing PCP

 

This link - see section 3 outlines an example of what would be an acceptable description of measures taken and the example provided shows a written procedure being acceptable. 

 

http://www.inspectio...02868878#table2


Edited by RoundEggs, 28 November 2018 - 06:06 PM.


#12 Jim E.

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Posted 28 November 2018 - 07:42 PM

Thanks Scampi & RoundEggs some good thoughts to work with.  I have not seen that last table that RoundEggs put up that was what I would consider a cross reference aid.  In the justification section I would also include the compliant FSEP prerequisite for my own help when ever we get inspected. CFIA at the plant next week for a PPR I am sure we will find time to discuss SFCR or I will at least push for it with them.

 

Cheers

 

:spoton:



#13 nlesperance

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Posted 19 February 2019 - 01:53 PM

I just completed my PCQI training about a month ago, and what I have taken away from it is that the PCP goes hand-in-hand with HACCP (With a few additions required). Preventive controls would be processing preventive controls (i.e. washing, cutting, cooking, metal detectors, etc.), allergen preventive controls, sanitation preventive controls, and supply chain! 

 

I am currently working on just adding my preventive controls to the end of my HACCP plan!



#14 Scampi

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Posted 19 February 2019 - 01:59 PM

nlesperance, you may still find the "old" FSEP plans/guides useful. 

 

It is a very robust format, that works for almost all the PCP's and allows you to easily match it against a GFSI


Because we always have is never an appropriate response!





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