In 2012, the Government of Canada passed new legislation affecting all food businesses in Canada. Called the Safe Food for Canadians Act (SFCA), this legislation introduces new requirements for traceability, inspection, oversight, and registration of food products with the intention of increasing safety and credibility of Canadian food products. The SFCA consolidates the previously separate guidelines of the Fish Inspection Act, the Meat Inspection Act, the Canada Agricultural Products Act, and the food provisions in the Consumer Packaging and Labelling Act under one umbrella, which the Government of Canada hopes will simplify and strengthen food regulation in our country. Originally slated for coming into force by 2015, but delayed by the federal election, the SFCA gives rise to the Safe Foods for Canadians Regulations (SFCR), which are expected in Gazette I by the end of 2016. We highly recommend all food businesses get educated and involved prior to this date, since the imminent changes will affect you.
The SFCA and SFCR will affect the food system in three major ways:
Identification and Registration: All food manufacturers, importers, and exporters will have to be registered with the Canadian Food Inspection Agency (CFIA). The current proposed cost of an application and license is $250, and the license needs to be renewed every two years. The CFIA will have the authority to suspend and cancel licenses if compliance issues are detected within a business.
Traceability: All food manufacturers and importers will be required to follow regulations related to tracing and recalling food. It will be expected that all entities handling food have the ability to trace a food’s path one step forward (i.e. who you sell to) and one step back (i.e. who you buy from) to increase the efficiency of any necessary recall. With the exception of retailers (who only need to trace one step back, but not forward to the consumer), this requirement will apply throughout all stages of production, processing and distribution of food. Your records have to be maintained for two years, and should include the food’s name and lot code, the names/address of businesses involved, and the dates on which purchase and sale occurred.
Preventative controls for food safety: Appropriate safety controls in areas like employee hygiene, equipment maintenance, and complaint management, among others, reduce the likelihood of unsafe food products entering the market and risking the health of Canadians. What is more, preventative controls help businesses identify and address safety concerns proactively, which which reduces recalls and brings Canadian food businesses in line with international partners who require similar proactive food safety measures. Under the SFCA, each food business will have to have a written Preventative Control Plan (PCP), such as Hazard Analysis Critical Control Points (HACCP) or equivalent, in place to demonstrate they understand the potential hazards inherent to their business and follow appropriate measures to ensure the safety of the food they produce.
The Canadian Food Inspection Agency (CFIA) will work with industry to explore approaches for specific operational needs of different businesses and assist in achieving compliance with the SFCR. They already have a number of tools available on their website, including an assessment worksheet to determine whether your business already has a PCP in place and a step-by-step guide to preparing a PCP. Also of interest to the CFIA is avoidance of undue regulatory burden on microbusinesses (less than $30K). Some proposals for minimizing negative impact to microbusinesses are exemptions from the registration application fee and the requirement for a written preventative control plan (it is expected that microbusinesses would still observe preventative control measures, they just don’t need to write them down).
So, where is the benefit to industry? The changes required under the SFCA will bring the Canadian system more in line with the food system in the United States, which the government hopes will facilitate business with our Southern neighbour and other international partners who have similar systems in place. Under the new system, the CFIA will also have the authority to certify foods for export, a benefit to exporters, since certified food products are becoming the norm in international trade. Of course the proposed benefits to safety of our food supply and the lessened probability of a recall are also appealing to food businesses.
Hand-in-hand with the SFCA is the Food Labelling Modernization Initiative (FLMI), which will prescribe labelling changes required to align with new SFCA. Already posted in Gazette I, the FLMI proposes a number of changes to Canadian food labels, including a standardization of serving sizes, grouping of sugars together in the ingredient lists, and a new footnote at the bottom of the nutrition facts table letting a consumer know that 5% or less of a nutrient is “a little” and 15% or more of a nutrient is “a lot,” among other changes. A long run-in period of 5 years is currently proposed to come in line with the FLMI, when it is instated, and you can read about the proposed changes in more detail here.
NHP Consulting Inc. can assist in the evaluation and preparation of PCPs, including hazard analysis and creating custom standard operating procedures (SOPs) for control measures to minimize risk within your food business. We can also advise on when and how to update your food label to come in line with the changes ultimately dictated by the FLMI. Contact us to learn more.