In mid-January, the Canadian Food Inspection Agency (CFIA) ushered in the new Safe Food for Canadians Regulations (SFCR), introducing licensing, preventive control, and traceability obligations for food preparation companies and importers. Over the coming 12 to 30 months, various requirements will be phased in slowly.
Cameron Prince, VP regulatory affairs for food safety consultancy Acheson Group, explains to Food Quality & Safety, “The big thing is that almost everyone doing business in food in Canada or trading in food with Canada will need a CFIA Safe Food for Canadians licence. This applies to importers, exporters, processors, and some brokers/distributors. Also, traceability is now mandatory—one step forward and one step back—plus retailers of food will have to keep records of the foods they receive. The third key element is that all licence holders will have to have written preventive control plans (PCPs) that are not only food safety but also cover consumer protection requirements such as weights and labels.”
For Alan Grant, senior manager for consulting and technical services at Public Health/Safety Group NSF, the SFCR is a positive move that will level the playing field. Under the new regulations, Grant tells Food Quality & Safety, “There are no longer federally ‘registered’ and ‘non-registered’ sectors, but rather the majority of food businesses now require a licence (e.g. for import, interprovincial trade, export) and are required to have documented food safety, consumer protection/market fairness, and traceability plans in place as set out in the SFCR. The new regulations more clearly identify the responsibility of importers to ensure that the product they import in Canada meets Canadian requirements through having their own PCPs in place.”
The challenge, of course, is implementation, and that will vary depending on how developed any company’s food safety program actually is. Prince says companies who have not been routinely inspected by the CFIA and don’t have a program in place will be starting from scratch under the new regs, and will likely need to hire outside assistance with food safety experience.
“Many importers will fall into this category [with] some commodities such as baked goods, cereals, and confections, which are seldom inspected by CFIA,” Prince explains. “These types of companies need to start now to get ready.”
It is up to each company to decide how it will go about being licensed, Prince says, and this allows for multiple sites or operations to function under a single license. However, it is wiser to license each site/operation individually. Prince says this “reduces risk of having multiple operations suspended if CFIA suspends a licence.”
There has been some confusion brought about by new terminology introduced in the SFCR, says Grant, particularly around terms like “preventive controls” and “preventive control plan.”
“Industry has been more familiar with the terms HACCP, HACCP-based, and Critical Control Points,” he notes, adding another challenge is that, “Industry is also now required to document their process for compliance with consumer protection/market fairness requirements (e.g. labelling).”
The regulations will have differing effects on companies working in the sector based on how familiar they are with the territory.
The SFCR “will have the biggest impact on importers for whom this is new territory that they are unfamiliar with,” Prince says. “Some distributors in Canada who have imported products themselves may choose to have brokers or the producer to become the licenced importer in order to avoid extra costs and paperwork associated with the CFIA licence. Overall, this will not greatly affect trade in food between Canada and U.S. but it may put more requirements on non-U.S. foreign suppliers.”
For Canadian companies, Grant stresses, the need to comply with Canadian food safety and market-fairness regulations is not something everyone will be experienced in.
“The regulatory requirement to be licensed and have a documented PCP in place may be new to some,” Grant says, “but generally speaking industry has had in place, or has been moving toward, third-party food safety certification (e.g. certification to a GFSI [Global Food-Safety Initiative] benchmarked scheme) or company specific food safety audits for many years.”
For some time, Grant says, companies both inside and outside of Canada have been gradually embracing third-party certification in the form of the GFSI program.
“In Canada, for the previously federally ‘registered’ sector as well as those in the previously ‘non-registered’ sector who are certified to GFSI benchmarked scheme, there will be little change other than the documentation of their process(es) for complying with consumer protection/market fairness requirements. Something that the majority will have in place but may not have formally documented as part of written plan.”
These changes, Grant says, build on an existing foundation, but he notes that this process is ongoing and continues to expand.
“Many of Canada’s trading partners have modernized, or are in the process of modernizing, their regulations (e.g. U.S. FSMA),” he says. “It is anticipated that food safety regulations, both domestically and internationally, will continue to evolve as new science becomes available.”
Prince, too, is confident the SFCR will have a ripple-effect on food safety approaches worldwide.