7 replies to this topic

[KR2447]

Hello everybody,

 

I have a question regarding enclosed shipping area. Is it mandatory or preferably?

 

I have worked in 3 different food processors and all of the them had enclosed shipping areas.

This time around, we are talking about a RAW meat company, small size, federally registered but not BRC or SQF, grandfathered shipping from non- enclosed area, with logistically and financially impossibility of building an enclosed area.

 

Short of investing millions of dollars, we took every precaution we could think of to address this request. But it seems to be not enough and the CFIA VIC is giving us lots of grief and a deadline to fix the ‘problem’.

To fight the fight I am going to need some ammunition: do you happen to have a link to Canadian or USA regulations clearly stating that the shipping area MUST be enclosed?

 

Thank you!

 

[Aartisharma98]

Hello everybody,

 

I have a question regarding enclosed shipping area. Is it mandatory or preferably?

 

I have worked in 3 different food processors and all of the them had enclosed shipping areas.

This time around, we are talking about a RAW meat company, small size, federally registered but not BRC or SQF, grandfathered shipping from non- enclosed area, with logistically and financially impossibility of building an enclosed area.

 

Short of investing millions of dollars, we took every precaution we could think of to address this request. But it seems to be not enough and the CFIA VIC is giving us lots of grief and a deadline to fix the ‘problem’.

To fight the fight I am going to need some ammunition: do you happen to have a link to Canadian or USA regulations clearly stating that the shipping area MUST be enclosed?

 

Thank you!

is your company a export facility? if not why are you asking regulations from usa

 

you are challenging cfia maybe cfia might be wrong but what if they are right. Also, why aren't you challenging your own company. 

 

if your company is not listening doesnt that put you at risk as well?

 

https://inspection.c...3/1297965645317

Edited by Aartisharma98, 09 May 2024 - 02:27 PM.

[KR2447]

With all due respect, it's not about right or wrong. It's about regulation. Is it stated clearly anywhere that the shipping must be enclosed?

 

I checked the literature/guidelines from Canada, USA, EU and I could not find any information. Hence, my post asking for help, not arguing if the company is right or wrong, or if VIC is right or wrong.

[kfromNE]

With all due respect, it's not about right or wrong. It's about regulation. Is it stated clearly anywhere that the shipping must be enclosed?

 

I checked the literature/guidelines from Canada, USA, EU and I could not find any information. Hence, my post asking for help, not arguing if the company is right or wrong, or if VIC is right or wrong.

 

You're missing regulations you need to look at. If by shipping area, you mean open dock doors. Then that's the problem - if your processing areas are open to the outside. 

Edited by kfromNE, 09 May 2024 - 02:45 PM.

[G M]

... It's about regulation. Is it stated clearly anywhere that the shipping must be enclosed?

...

 

 

It will become a matter of whether or not you can meet all of the other explicitly stated requirements without enclosing it.  For pest control how would you ever keep mice, fling insects or birds out without an enclosure?  How you keep deleterious contaminants like dust out without an enclosure?

 

The burden of proving all of those things will rapidly pile up.  "We don't want to spend money" is unlikely to be a convincing argument.

[MDaleDDF]

Why not just put clear curtains around it.   Boom.  Enclosed shipping area.

[Aartisharma98]

Why not just put clear curtains around it.   Boom.  Enclosed shipping area.

or enclosed area with vinyl/plastic/etc,. like how they have for quarantine

Edited by Aartisharma98, 09 May 2024 - 03:10 PM.

[Scampi]

Ok, you've raised a couple of points worth discussing

 

A) the plant is grandfathered-------that generally means the you will be given an extension to come into compliance---it could just be that deadline has arrived

B) it usually comes with an effort on behalf of the operator to come into compliance by showing POs or something for work to be done

C) By continuing to apply for a license each year, the company is AGREEING to the requirements

 

Subparagraph 89(1)©(i) and paragraph 89(1)(e): PCP content for hazard control

• As a result of the hazard identification and analysis conducted under section 47 of the SFCR, subparagraph 89(1)©(i) requires that for each food, including the food that you import or export, and food animals that you slaughter, your PCP includes a description of the:
  • biological, chemical and physical hazards you identified as presenting a risk of contamination to the food;
  • control measures you use to prevent, eliminate or reduce the hazards to an acceptable level; and
  • evidence that the control measures are effective
• Paragraph 89(1)(e) requires that your PCP also includes the documents you used to
  • identify the hazards; and
  • determine the appropriate control measures
• Following all of that, how exactly are you controlling the hazard of not having proper docks?   Pests, dirt, climate control etc? This is probably where your VIC is getting frustrated 

 

Out of curiosity have they always been federally regulated, or is this new because of SFCR?

Edited by Scampi, 09 May 2024 - 03:59 PM.