I need to do WHAT?!
Canada’s new food regulations and Traceability
Starting July 2020, anyone who makes food that is shipped across provincial boundaries, is exported, or is imported, including the ingredients that are used for further processing, will need a written and tested traceability program.
Importers responsible for importing food must have written and tested traceability programs.
And while food additives are NOT generally included in the requirements under the new regulations, traceability programs are one big exception. Manufacturers and Importers of food additives will have to have a written and tested traceability program in place.
Under the new rules, traceability is a very simple concept – know who you purchased an item from and know who you sold it to, and keep this information in writing (records).
Records for traceability must include:
- Common name of the product
- Lot code or other unique identifier
- Name and principal place of business of the supplier
- Name and principal place of business of the customer
- This does not apply at retail level to the consumer
These records must be kept for 2 years from the date of receipt of a product and for 2 years from the date of the sale of a product. Documents must be readily accessible in Canada.
You also have to test your system to make sure it works, including checking your contact information for suppliers, customers, and the Canadian Food Inspection Agency (CFIA) to ensure it is all up-to-date. There are some excellent subscription services that can help with keeping notification lists current.
As part of your systems test, you must carefully record:
- The dates when you tested your system,
- Any shortcomings identified in the test,
- Fixes for those shortcomings, and
- That the fixes worked.
There are a number of products which are exempt from some of these requirements such as fresh fruits and vegetables that are sold loose in a display. CFIA has provided detailed charts to identify which of the traceability requirements are required by activity (like importing) or by commodity (like fruits and vegetables). https://www.inspection.gc.ca/food-safety-for-industry/traceability/traceability/eng/1522294721005/1522294781171
At any time, the CFIA can ask for traceability information about a product. The most likely reason why is a food safety issue they have discovered that may be affecting the food you import, or a food similar to the food you import.
Traceability Information for the CFIA can be given in English or French. Information must be presented within 24 hours of the request or may be asked for in less time if there is a serious health risk involved.
Information can be provided either on paper or electronically, but electronic files must be in plain text that can be imported into standard software, like a spreadsheet.
Traceability can generally be built into a business’s financial accounting system, so long as that system is capable of generating reports, including reports in spreadsheet format or in plain text format. Even fairly basic accounting software is now capable of this kind of report generation. Making sure that information about incoming shipments is correct is critically important to the success of a traceability program.
Should you need help developing or improving your traceability program, please be sure to contact Food Safety at Chemical Compliance.ca
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