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April 16, 2019

Canada’s New Safe Food for Canadian Regulations (SFCR)? – An Update

At Berkshire, we know we have discerning readers. An audience well versed in the mission, vision, and technologies of our industry. Readers with a broad range of interests outside of products used in cleanrooms or updates on protocols, and who thrill at learning how our industry is contributing to missions to Mars, creating innovative technologies, or defining the latest standards in food safety. And we also love to hear from you, to know which articles have inspired a development, touched a nerve, or sparked a vision.

And so it was with no small amount of excitement that we opened a message from Lynette Lamondin in response to our article “Can Canada’s New SFCR Really Make Food Safer? Undeclared Allergens, Hidden Dangers” (February 20, 2019). Lamondin is the Executive Director of the Food Safety and Consumer Protection Directorate with the Canadian Food Inspection Agency (CFIA) and was keen to contribute her unique perspective to our discussion of Hazard Analysis and Critical Control Points (HACCP) protocols in the Canadian food industries. Lamondin emphasized that while the terminology is different between Canada and the U. S. the former does, of course, require strict regulation. And, while we are grateful for the elucidation, we do stand by our initial assertion. Where we stated that HACCP is not required for all sectors of the food manufacturing arenas – solely in federally-regulated meat and poultry facilities – we did note that it is nonetheless recommended. However, with that said, a Preventative Control Plan (PCP) is mandated for all establishments and this document is markedly similar to the internationally recognized HACCP. How? Let’s take a closer look…

Under Canadian guidelines, a PCP is ‘a written document that demonstrates how risks to food and food animals are identified and controlled. The controls are based on internationally recognized Hazard Analysis Critical Control Point (HACCP) principles. The PCP also includes a description of measures taken related to packaging, labelling, grades and standards of identity.’ In other words, it mirrors HACCP directives in the description of potential hazards and contaminants, the control points and limits of each, and the corrective actions to be pursued in the event of hazard identification. Moreover it also lays out procedures regarding the later verification of mitigation and the documentation thereof, making it a significantly robust, ‘soup-to-nuts’ set of protocols for food safety.

What is also important is that PCPs apply not only to domestic food products but also to those imported from outside Canada and, as Lamondin notes, to those ‘prepared for interprovincial trade or export.’

As we highlighted in our article, the new legislation introduced by our neighbors to the north consolidates and further refines an already reputedly world leading system of food safety checks and balances, creating a system to guide businesses in early identification and correction of production problems, and to diminish the number of recalls by ensuring the safety of food reaching Canadian consumers.

Lamondin referred us to additional information available on the CFIA’s website and we were especially interested in the breakdown of the Safe Food for Canadians Regulations (SFCR) and the PCP guidelines which were both comprehensive and clearly explained. While at the site, we also perused some of the available resources for businesses of all sizes, including an interactive tool that allows companies to determine the need for a formal preventative control plan. Additionally, we were most impressed by the CFIA’s infographic explaining international best practices in food safety, which is an asset that should be included in any food manufacturer or processor’s toolkit.

We must thank Lyzette Lamondin and the CFIA for reaching out and creating a space for us to further examine the differences and similarities between our two national systems of food safety.

In addition, her note afforded us the opportunity to reflect on the importance of demystifying the differing nomenclature and terminology adopted by different countries. Where we use ‘HACCP’ as the internationally recognized standard, Canada’s’PCP’ protocols are equally robust, if not more so, but are just known by a different name.   

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