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Query regarding Safe Food for Canadians (SFCR) Licence One Product/ Other Product Provincially Inspected

SFCR

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#1 Jackobelly

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Posted 24 April 2020 - 04:56 PM

Hello,

 

We are planning on only getting a SFCR license for one product and our other product would stay provincially inspected.

Does somebody know if  we will get both, CFIA and our local health inspector coming in for inspections?

 

I would assume so but I couldn't find much about how such cases are handled.

 

Appreciate any inputs!



#2 majoy

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Posted 08 May 2020 - 07:00 PM

So SFCR licences are for activities carried out in the facility and not for specific products.

 

Say, you applied for licence of manufacture of foods for inter provincial trade, then you will have that licence attached to your facility. This means that in your facility, you can manufacture products that can be sold to other provinces.

 

What you need to do is to ensure you have segregation procedures in place so that the raw materials, process and finished products are not mixed up with the 'domestic' only products. This is what you have to prove to CFIA when you get audited.


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#3 Jackobelly

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Posted 08 May 2020 - 07:37 PM

So SFCR licences are for activities carried out in the facility and not for specific products.

 

Say, you applied for licence of manufacture of foods for inter provincial trade, then you will have that licence attached to your facility. This means that in your facility, you can manufacture products that can be sold to other provinces.

 

What you need to do is to ensure you have segregation procedures in place so that the raw materials, process and finished products are not mixed up with the 'domestic' only products. This is what you have to prove to CFIA when you get audited.

Hi!

Thank you for your input!

 

Ok so we only produce two different products, one for inter-provincial trade and the other one we only sell within the province.

 

So when I set up the preventive control plan, the maintenance and operations part is obviously not attached to a specific product.

But the HACCP plan, traceability, labeling/packaging would be for all my products or just for the one?

 

About the segregation, the raw materials for both products are the same but the processing and end-product is very different. How do I show segregation?

 

Thank you, any help is very much appreciated!



#4 olenazh

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Posted 08 May 2020 - 07:42 PM

Hi Majoy.

As far as I know, Federal Registration is required when a company's selling out of the province the products are manufactured in. However, I've never heard of "segregation procedures" for products sold domestically and inter-provincially. Could you please reference me to the regulation stating that?



#5 majoy

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Posted 11 May 2020 - 01:54 PM

Hi Majoy.

As far as I know, Federal Registration is required when a company's selling out of the province the products are manufactured in. However, I've never heard of "segregation procedures" for products sold domestically and inter-provincially. Could you please reference me t

o the regulation stating that?

 

References to applicable Acts and Regulations:

SFCR 15, 47, 60, 61, 62, 86(1), 88, and 89

 

It is mostly toward inter provincial trade and export.

 

I mentioned segregation for domestic (province) to inter provincial because in my opinion this will be treated as incompatible activities in a licence establishment. Logically, If i am CFIA how will i know that you are only producing products bound for interprovincial if there is no segregation policy in place between products?

 

Atleast on meat plants, CFIA conducts segregation tasks

Task: 2.5.01     Segregation Requirements- Incompatible Activities and Separation of Licensed Food

 

So the title of the task itself will let you know what they're looking for when they do this task.


"Whatever you do, do it well..." - Walt Disney


#6 olenazh

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Posted 11 May 2020 - 02:09 PM

Hi Majoy;

Sorry to contact you here as I'm not sure how to send this message directly to you.

The reason I was doubting is that one of my clients is an ice cream factory. They're selling part of their products inter-provincially, and other part's sold within Ontario. They're Federally and Provincially registered. However, they've never had any segregation of neither processes, nor products. Additionally, they've been regularly inspected by CFIA and never had comments RE: this. May be, it's different in meat industry.

I see, you're experienced Member:) Could you please assist me on how to communicate directly to the person from a thread?

Thanks a lot in advance!



#7 majoy

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Posted 11 May 2020 - 02:16 PM

Hi!

Thank you for your input!

 

Ok so we only produce two different products, one for inter-provincial trade and the other one we only sell within the province.

 

So when I set up the preventive control plan, the maintenance and operations part is obviously not attached to a specific product.

But the HACCP plan, traceability, labeling/packaging would be for all my products or just for the one?

 

About the segregation, the raw materials for both products are the same but the processing and end-product is very different. How do I show segregation?

 

Thank you, any help is very much appreciated!

 

I'm not very familiar with provincial level, but i assume, they have same requirements for HACCP plan. So if these are two different processing and different end-product, you should maintain 2 HACCP Plan.

 

Just some ideas

- on your procedure, state that the RMs are approved for both use - this should show that specs are checked for provincial and federal requirement (if there exists any)

- on processing, when do you process the interprovincial? maybe say it is scheduled and specific day only - or processed before the other product

- on finished product, of course labeling requirements met for inter-provincial trade - checklist any of similar, storage of the interprovincial product so that it does not mixed with the provincially sold product

 

These are just on top of my head.

 

My experience is in meat processing, so maybe its more stringent. But just to give you ideas.
 


"Whatever you do, do it well..." - Walt Disney


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#8 majoy

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Posted 11 May 2020 - 02:19 PM

Hi Majoy;

Sorry to contact you here as I'm not sure how to send this message directly to you.

The reason I was doubting is that one of my clients is an ice cream factory. They're selling part of their products inter-provincially, and other part's sold within Ontario. They're Federally and Provincially registered. However, they've never had any segregation of neither processes, nor products. Additionally, they've been regularly inspected by CFIA and never had comments RE: this. May be, it's different in meat industry.

I see, you're experienced Member:) Could you please assist me on how to communicate directly to the person from a thread?

Thanks a lot in advance!

I'm not expert by all means, so  maybe they are doing it correctly if CFIA has not called them out on this.

 

But they should still have something in place to show that these two products does not mixed up, the provincial product not ending up to be sold inter-provincially, so i think that's where segregation will be coming from in my opinion. Maybe just a narrative on the procedure saying that its controlled etc. etc.


"Whatever you do, do it well..." - Walt Disney


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#9 Jackobelly

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Posted 11 May 2020 - 04:32 PM

References to applicable Acts and Regulations:

SFCR 15, 47, 60, 61, 62, 86(1), 88, and 89

 

It is mostly toward inter provincial trade and export.

 

I mentioned segregation for domestic (province) to inter provincial because in my opinion this will be treated as incompatible activities in a licence establishment. Logically, If i am CFIA how will i know that you are only producing products bound for interprovincial if there is no segregation policy in place between products?

 

Atleast on meat plants, CFIA conducts segregation tasks

Task: 2.5.01     Segregation Requirements- Incompatible Activities and Separation of Licensed Food

 

So the title of the task itself will let you know what they're looking for when they do this task.

So the segregation you are referring to only seems to apply for meat products. It's about keeping meat from different species separate and isolating non edible meat products.

Part 6, Division 7, subdivision C 132  and Part 6, Division 7, Subdivision E 140.



#10 Jackobelly

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Posted 11 May 2020 - 04:34 PM

I'm not very familiar with provincial level, but i assume, they have same requirements for HACCP plan. So if these are two different processing and different end-product, you should maintain 2 HACCP Plan.

 

Just some ideas

- on your procedure, state that the RMs are approved for both use - this should show that specs are checked for provincial and federal requirement (if there exists any)

- on processing, when do you process the interprovincial? maybe say it is scheduled and specific day only - or processed before the other product

- on finished product, of course labeling requirements met for inter-provincial trade - checklist any of similar, storage of the interprovincial product so that it does not mixed with the provincially sold product

 

These are just on top of my head.

 

My experience is in meat processing, so maybe its more stringent. But just to give you ideas.
 

Thank you, very good ideas! I will include them for sure :-)







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