SFCR (Safe Food for Canadians Regs) & HACCP plans for importer

Hi All, 

I have recently started my career in Quality. And I am the only employee.  I am doing everything from scratch for the first time..like developing SOPs, logs and records. 

The company (based in Canada) I work for is importer of prepackaged food from around the world..We ship them out as is. We have categories like- Cheese, vinegars, jams, rubs, canned meat and fish, chocolate, wafers, (more than 3000SKUs) etc. 

I have all the websites and regulations for guidance but I do need some expert advise on following things- 

Do I need to develop HACCP plan based on each category or one plan for all the SKUs? 

As we are selling these imported products as is..is it okay not to have physical and chemical hazards, because we are not opening anything? 

the SFCR document says, the requirement to identify CCPs is not applicable to licence holders who import. so is it okay not have CCP in HACCP?

Any help is appreciated. 

Thanks in advance,

Neha. 

Neha - we are in a similar situation and looking for similar answers. At this point, I'm thinking of just building a preliminary HACCP plan for thee categories: pre-packaged/dry goods, frozen good & refrigerated goods. I'm in the process of identifying those hazards now. 

Any further insights would be welcome from anyone who has walked through this already.

Neha - we are in a similar situation and looking for similar answers. At this point, I'm thinking of just building a preliminary HACCP plan for thee categories: pre-packaged/dry goods, frozen good & refrigerated goods. I'm in the process of identifying those hazards now. 

 

Any further insights would be welcome from anyone who has walked through this already.

 at least some one replied. Thanks a lot. 

I am also categorizing products based on their storage requirements and marking storage temperature controls as CCP. does that make sense? 

Is temperature your only CCP?

Is temperature your only CCP?

yes, I could not think of any other step as CCP. We are selling products as is. 

Are you re-labeling the imported products prior to sale to retail?

How about labeling as CCP?

If you are importing food products and selling as is, so as an importer, you have to ensure that the food product is compliant to Canadian regulations in terms of labeling most especially allergen. Most of imported foods gets recall because of allergen.

Yes, we are relabeling imported product, if the label isn't in English or French already. On the new labels, we ensure the allergens are identified.

As we are developing our PCP we are figuring out a better way to integrate re-labeling into our system, and also how to consistently check labels to ensure they are correct.