Agenda Item 4.4	Conference Room Document 45

second fao/who global forum of food safety regulators

Bangkok, Thailand, 12-14 October 2004

How Official Services Foster and Enforce the Implementation of Hazard Analysis Critical Control Point (HACCP) Methodology by Industry and Trade

(Prepared by Canada)

BACKGROUND

The responsibility for food safety in Canada lies in a multi jurisdictional setting involving the federal, provincial, territorial and municipal authorities. At the federal level, the responsibility for food safety is shared by Health Canada and the Canadian Food Inspection Agency (CFIA). Health Canada sets the standards and policies for food safety and nutrition. The CFIA is responsible for enforcing food safety standards set by Health Canada, and federally mandated food inspection, compliance and quarantine services. The CFIA designs, develops and manages inspection, enforcement, compliance and control programs and service standards.

Canada supports and has built its Hazard Analysis Critical Control Point (HACCP) food safety control programs on that promoted by the Codex Alimentarius Commission¹1. This science-based approach addresses biological, chemical and physical hazards through anticipation and prevention, rather than through finished production inspection. HACCP principles can potentially be applied to all sectors of the food continuum.

Canada's use and development of HACCP-based food safety programs date back to the late 1980s. Early initiatives were focussed in federally registered food manufacturing facilities. Introduction of these programs was accomplished by way of voluntary industry participation, supported by government-developed programs that provided funding, scientific advice, and support for program implementation.

There are several reasons for the government and the food industry to continue to provide the adoption of HACCP-based food safety programs:

• is a science-based approach, designed to assess and control food safety hazards.
• is recognized internationally and Canada has aligned its HACCP programs with those adopted by the Codex Alimentarius Commission.
• further clarifies the roles and responsibilities of industry and government, for example, the industry's accountability to meet regulatory requirements.
• can aid the government in using risk management techniques to focus activities on high-risk food safety areas.
• provides an avenue for incorporating food safety programs into broader quality assurance/management systems in use by industry.

Canada's federal government continues to support the development of HACCP-based food safety programs across the food continuum. Agriculture and Agri-Food Canada (AAFC), has developed a national policy strategy known as the Agricultural Policy Framework (APF), which has several objectives. One of these is to protect human health by reducing exposure to food-borne hazards, to increase consumer confidence in the safety of foods sold in and/or exported from Canada, and to increase the sector's ability to meet or exceed market specifications for safety. A key goal of the APF is the adoption of credible food safety systems and risk reduction strategies throughout the food continuum. The APF will directly influence the development of Canada's on-farm food safety recognition program and post farm food safety systems.

HACCP-Based Food Safety Programs

Canada's integrated approach to food safety extends across the food continuum, with participants from governments at all levels, from industry in terms of fishers, producers, processors, distributors and retailers and from consumers.

In Canada, change is being driven by industry-wide adoption of HACCP-based practices and by regulators adopting these same principles at the federal, provincial/territorial and municipal levels as a core element in inspection program design and intervention strategies. Canada has made considerable progress in the implementation of HACCP programs.

On-Farm Food Safety Recognition Program

Since 1997, Canada's federal government has supported national producer organizations in the development of strategies and tools to implement HACCP-based on-farm food safety programs. This support has been by way of sponsored, cost share funding and in the provision of scientific and technical advice by the government, in the development of these programs. The APF will continue this earlier work in support of on-farm food safety programs and will respond to industry's request for the government recognition of these programs.

The On-Farm Food Safety Recognition Program (OFFSRP) will provide government recognition for industry developed HACCP-based on-farm food safety systems. This voluntary program promotes the implementation of HACCP principles. Nineteen national producer organizations have expressed their intention to participate in this program and several are presently working toward obtaining government recognition of their on-farm food safety systems.

The recognition process of the OFFSRP involves a federal and provincial government examination of the technical soundness and administrative effectiveness of on-farm food safety programs. There are three defined stages leading to recognition: a government-led, technical review (includes review of HACCP-based documentation, and management system and associated documentation); an industry-led implementation and third-party audit, and a government-led implementation assessment. Recognition will be granted to successful applicants at the end of the third stage. Post recognition ongoing monitoring will determine if the national on-farm food safety program is maintaining its technical soundness and administrative effectiveness.

More information on the program can be found at:

http://www.inspection.gc.ca/english/fssa/polstrat/reco/processe.shtml

Quality Management Program

The Quality Management Program (QMP) was established as a mandatory program in 1992 requiring, as a condition of license, that all federally registered fish processing establishments develop and implement processing control programs using HACCP principles. QMP also deals with non food safety issues, including fish quality and federal regulatory requirements such as labelling.

In 1998, the QMP was re-engineered to be fully consistent with the application of HACCP as per Codex Alimentarius guidelines. QMP regulations were amended in 1999. QMP has evolved over time; this stepwise approach responded to industry needs and to consumer requirements for a high level of assurance that fish and seafood products produced in Canada are safe and wholesome to eat.

More information on the program can be found at:

http://www.inspection.gc.ca/english/anima/fispoi/qmp/polclae.shtml

Food Safety Enhancement Program

The Food Safety Enhancement Program (FSEP) is directed at all federally registered establishments of the meat, dairy, honey, maple syrup, processed fruit and vegetable, shell egg, processed egg, and poultry hatchery sectors.

The FSEP recognition process is well established and involves: a request from the individual establishment for a government review of their HACCP system; a government review of the establishment's HACCP documentation package, including prerequisite programs; and an on-site recognition audit of the establishment's prerequisite programs and HACCP plans. If deemed satisfactory, the process concludes with recognition of the HACCP system. Post-recognition ongoing audits are conducted periodically by the CFIA in order for the individual establishment to maintain FSEP recognition.

Implementation of FSEP was initially voluntary-based with the intention of eventually applying a regulatory requirement to individual program sectors when deemed necessary or desirable. Today, the majority of federally registered meat and storage establishments have implemented, or are in the process of implementing FSEP. This high degree of participation by the meat industry has resulted in a decision by the CFIA to move toward the development of a regulatory requirement for FSEP in these establishments. The regulatory amendment necessary to mandate HACCP-based systems in all federally registered meat and poultry establishments is in the final stages of approval. For other sectors, mandatory FSEP, as a condition of federal registration, will be considered as demand/need emerges.

More information on the program can be found at:

http://www.inspection.gc.ca/english/fssa/polstrat/haccp/manu/manue.shtml

Post-Farm Food Safety Systems

For the purpose of this paper, the term 'post farm' is used to identify that segment of the food continuum beyond the primary producer for whom the previously described FSEP and the QMP programs do not apply. This segment includes packers, transportation, processing, handling, food storage, distribution, bakery, marketing groups, food service facilities and wholesale-retail. Industry is encouraged to participate, on a voluntary basis and in partnership with government, in the expansion and creation of sector-specific HACCP-based food safety control systems. The government will provide specialized technical advice and support to nationally-based industry organizations in the development of these HACCP-based food safety systems.

Lessons Learned

• must be based on science, and internationally accepted standards in order to promote and gain acceptance from all stakeholders.
• primary role of the government is to provide encouragement, direction, and scientific and expert advice, for program development/implementation. Government involvement is useful to industry in terms of sharing expertise and experience in the development of HACCP-based food safety control programs in sectors lacking in these food safety systems.
• implementation of HACCP programs needs to be carefully considered, planned and introduced over a reasonable period. Step-wise approaches to the implementation of HACCP have provided time for industries/sectors to adjust and have contributed to greater ownership of the results.
• development, expansion, and acceptance of HACCP-based food safety control programs are best achieved through partnerships amongst all levels of governments and stakeholders.
• provision of government funding to support the development and implementation of HACCP-based food safety control programs has proven useful in facilitating participation by industry and in aiding sectors lacking in the necessary expertise and resources.
• benefits of HACCP are significant and include:
• industry knowledge of food safety controls, record keeping and corrective actions;
• effectiveness of regulatory inspection systems;
• effective and efficient use of resources by both government and industry;
• consistency/harmonization with the international marketplace; and increased stakeholder confidence in the food safety system.

¹ CAC/RCP 1-1969, Rev. 3-1997, Amd. (1999) - Recommended International Code of Practice General Principles of Food Hygiene; Annex to CAC/RCP 1-1969 (Rev. 3-1997) Hazard Analysis and Critical Control Point (HACCP) System and Guidelines for Its Application