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Requesting help with CFIA SFCR regulation

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rejahanwer

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Posted 19 October 2023 - 11:50 AM

Hi all,

Hope you all are well.

We are a food import startup in Canada dealing with prepackaged grains, spices and snacks. Glad to find an active food safety community online. We started importing and distributing prepackaged foods on small scale this year and was not required to have a preventative control plan as our annual sales have been under 100000 cad so far.

We are crossing the 100000 cad sales mark soon and preparing to implement all SFCR requirements so we are ready for an upcoming inspection. Would like any help with regards to this please. We want to:

1. Prepare a comprehensive Preventative control plan that meets the SFCR requirements.
2. Prepare and maintain documents, processes and records that helps with audits and inspections.

Scope of the inspection:

Sub-element 1.3: Import controls
Sub-element 7.1: Traceability and control
Sub-element 7.2: Complaints

Any help is appreciated. Thank you all.



Scampi

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Posted 19 October 2023 - 12:03 PM

Do you have a traceability/recall plan in place?


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rejahanwer

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Posted 19 October 2023 - 12:14 PM

No, We don’t at the moment.



Scampi

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Posted 19 October 2023 - 12:46 PM

So that is step one

 

Before you can write any programs --you need to first understand HOW you 

 

A) apply a code to each unit that you can follow through to your customers  AND back one step to the ingredient vendor

 

B) how you can then locate those codes in a timely manner (max 2 hours) in order to know where ALL of a particular batch OR ingredient OR packaging went

 

https://inspection.c...5/1535516168226

 

For import controls

 

A) how do you know you're buying from a reputable source?  Approved supplier program

https://inspection.c...4/1528208259725

https://inspection.c...4/1539966112700

 

B) verify that they are licensed to import into Canada or Export from country of origin

 

For complaints, you need to log them AND review them on a schedule  (this can be an excel sheet) and you should include an actionable threshold of similar complaints and what steps you might take


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rejahanwer

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Posted 20 October 2023 - 01:59 AM

Thanks @scampi for the reply. We are going through the link. We’re also looking at consultants who can help us with the documentation and audits/inspections. Kindly post references if you have any.

Thanks again.



Scampi

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Posted 20 October 2023 - 12:23 PM

I would caution you against consultants during the audit---it makes it look like you don't know your own process--and someone should take an in person HACCP course

 

NSF Canada can assist with documentation (but it's not cheap)---depending on where in Canada you are

 

https://fsl.nmsu.edu...nings2006-2.pdf

 

https://inspection.c...78402035?chap=2

 

https://www.astaspic...and-seasonings/

 

https://inspection.c...5/1379339596081


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millerjf

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Posted 24 October 2023 - 03:09 PM

We are a Canadian consulting firm located in Nova Scotia with specialization in SFCR PCPs.  If you would like more information, please let me know.  

 

James

Miller Quality Solutions Ltd.





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