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Where are the PRPs now that SFCR has replaced FSEP?


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#1 schnitzelman

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Posted 28 June 2020 - 03:11 AM

I really don't get what's going on? I thought this was a consolidated regulation? Sorry for the dumb question, I've been out of the game for a while now.



#2 Charles.C

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Posted 28 June 2020 - 03:14 AM

I really don't get what's going on? I thought this was a consolidated regulation? Sorry for the dumb question, I've been out of the game for a while now.

3 acronyms in one title. Must be a record. :thumbup:

 

Unfortunately not a Canadian so cannot help. Sorry.


Kind Regards,

 

Charles.C


#3 schnitzelman

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Posted 28 June 2020 - 01:58 PM

Well, at least I got the record. Thanks anyway!



#4 olenazh

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Posted 28 June 2020 - 03:03 PM

Hey schnitzelman! Now, CFIA requires food companies to have Preventive Control Plans, and FSEP is one example of a type of PCP. Basically, you don't have to change your existing PRPs (that's what I was told by CFIA inspectors), you just need to make sure they reflect PCP requirements. Please, see attached PCP Elements document for your reference. Also, nowadays it's very critical to do what's written in your PRPs (I got some comments from CFIA inspector last year: you must have a proof that whatever's written in your program is actually done. For instance, if you say in your Shipping/Receiving program that you review ingredient specs regularly, you must have a proof record)

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#5 schnitzelman

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Posted 28 June 2020 - 03:42 PM

Thank you olenazh! Is it just my lack of familiarity with the changes, or has this actually become more confusing? How is this a simplification or improvement over the old system? It's basically just the PRPs but disassembled and reassembled in a different configuration....



#6 olenazh

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Posted 30 June 2020 - 01:24 PM

As far as I know, it's more for new inspection design rather than to simplify/improve old system. Now, CFIA inspects only 2-3 elements, not the whole system as before. They let you know in advance what particular elements they'll be inspecting.



#7 majoy

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Posted 17 July 2020 - 06:18 PM

CFIA wants manufacturer to interpret the regulations on our own, to be more creative and to not "tell us what to do" apparently, so all the previous guidance became incorporated by reference - not mandatory but nice to have.

 

Double edge sword, in my opinion.

 

In meat establishments, its felt like nothing changed. Inspectors review all pre-requisite requirements based on their tasks, however, they can always use the "as triggered" for any additional inspection depending on what they observe in your facility. The only thing that didn't happen this year for us is Section 4 audit, we went through with it for 2 consecutive years.


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