9 replies to this topic

[Rae Kell]

Greetings - Any guidance is appreciated.  

 

Our company puts on endurance events in the U.S. and Canada. We have partners/sponsors that provide food products that we bring to the events and give to the participants that pay to do these events. We are being audited this year, and one of our canned beverage products is an ultrafiltered dairy product. We were not aware that we should have been doing a PCP for this product. 

 

For the audit we have been asked to do a PCI on 2 products, and a PCP on the dairy product. The PCI is lengthy, including a mock recall. (Through this forum I think I've found some good resources to help do a recall).  

 

I'm curious if there is anyone else on here that has had to do audits or PCP's for similar reasons? We do not manufacturer food, we just bring in the products, which we don't sell, but just give away.  

 

It seems like they want us to do a PCP as if we are actually the manufacturer, could that be right? Including an in-person audit of the manufacturing facility?  https://inspection.c...ns/importers#a2

 

Again, any insight or guidance is appreciated. I do plan on asking our auditor for clarification, but wanted to see what I could figure out on my own first.  Thank you!

 

[TimG]

These food products never enter commerce and are only used as part of a 'giveaway'? No money changes hands? Your company does not manufacture or import goods that enter commerce?

[Scampi]

Canada under went a massive regulatory change in 2018-19 

 

It does not matter WHY you are importing food, it's still required to go through the proper permitting and licensing process particularly that you are "giving" it away to potentially hundreds of people.  

 

The link you provided is the correct one

 

I would add a caveat---dairy has it's own set of rules they can be found here  

 

https://inspection.c...uirements/dairy

[Scampi]

You may also want to review this article

 

https://www.pcb.ca/i...cessed-food#FAQ

[TimG]

Huh, that's weird to me.

Off topic big time, but what would they do to enforce it? Stateside FDA can fine and ultimately pull a food facility license (which is BAD for a food facility) but since there is no food facility/manufacturer in this case I wonder how they enforce it.

[Scampi]

@TimG

 

CFIA is posted at the border and works in conjunction with border patrol

 

The items would be disposed of at the border and the importer license revoked and/or fines imposed

 

https://www.cbsa-asf...rigine-eng.html

 

Failure to comply can result in seizure of offending food products, and for each offence, the imposition of fines ranging to $250,000 to $5 million and/or imprisonment terms of six months to five years.

[TimG]

@TimG

 

CFIA is posted at the border and works in conjunction with border patrol

 

The items would be disposed of at the border and the importer license revoked and/or fines imposed

 

https://www.cbsa-asf...rigine-eng.html

 

Failure to comply can result in seizure of offending food products, and for each offence, the imposition of fines ranging to $250,000 to $5 million and/or imprisonment terms of six months to five years.

 

Well, they certainly got some teeth. Sometimes I wish FDA had a bit more oomph (as long as they had the training required to match the authority).

[Scampi]

I would agree

 

It's most likely the difference in our parliamentary systems

 

Our inspectors MUST go to a 6 week primary training session, they are permitted 1 trip home during that time. They are mentored under senior staff until they are ready to inspect themselves

 

CFIA has VERY sharp teeth, and uses them

[GMO]

Off topic slightly but while I'm dismissive of some of the behaviours of EHOs in the UK (Environmental Health Officers) who have remit for food safety here, and I certainly worry at the infrequency of their auditing, what they do have is far more power than US food competent authorities.  The US always feels like the hands of lobbyists get their sticky mitts into food safety legislation before it can really get teeth.

[rae.kell29029]

Thanks for the responses and links...very helpful!   

 

To answer the question from TimG - Correct...we don't sell any of the products, either at the event or outside of the event. They are put out at our Aid Stations for our participants to have as much as they want during the 36-hour endurance event.  

 

We want to be 100% compliant. We have amazing relationships with our hosts at our event sites in Canada and appreciate the opportunities to share the beautiful locations with the participants. CFIA has not been difficult to work with, it's just that some of the parameters, such as with dairy, are confusing. From what I can interpret, they are requesting a complete PCP. If this is the situation, our best bet is to just drop the shelf-stable dairy product.  

 

I'll dig a little more, I appreciate the discussion. I'm glad I found this forum in my searches as I've found a lot of help so far.

 

Cheers!   Rae