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The Guelph Food Safety Seminar Series Presents Beyond HACCP: How can present food safety systems be

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Title: The Guelph Food Safety Seminar Series Presents Beyond HACCP: How can present food safety systems be


1
The Guelph Food Safety Seminar Series
Presents… Beyond HACCP How can present food
safety systems be improved at all points along
the food chain? A One Day Symposium
HACCP - The CFIA experience
Dr. Claude Boissonneault Acting National Manager
Meat Program Food of Animal Origin
Division Canadian Food Inspection
Agency September 15, 2004
2
TODAYS PRESENTATION
  • Role of the Canadian Food Inspection Agency
    (CFIA)
  • CFIAs experience with HACCP systems
  • Proposed Mandatory implementation of HACCP
    systems in all establishments registered under
    the Meat Inspection Regulations, 1990
  • Beyond HACCP How can present food safety systems
    be improved at all points along the food chain ?

3
CFIAS ROLE IN FOOD SAFETY REGULATION
  • Administer inspection programs related to foods,
    plants and animals
  • Enforce food safety, labelling, nutrition and
    quality standards
  • Inspect activities in all federally registered
    food plants across Canada
  • Inspect imported foods

4
FOOD INSPECTION
INSPECTIONS
  • Establishment Product
  • Establishment Registration
  • Licensing of Operators
  • Products Certification
  • Enforcement of Regulations

5
HACCP, a science based system, has been adopted
by Codex Alimentarius, an international working
group which sets the reference for food safety
standards in the world community. HACCP
PRINCIPLES as outlined by Codex alimentarius 1-
Hazard analysis, conduct 2- CCP, determine 3-
Critical limits, establish 4- Monitoring
procedures, establish 5- Deviation procedures,
establish 6- Verification procedures,
establish 7- Record keeping procedures, establish
WHAT IS HACCP ?
6
The CFIA has an official mandate for three HACCP
programs HACCP is being implemented at the
farm level through the On-Farm Food Safety
Recognition Program (OFFSRP). HACCP is a
mandatory program for fish through the Quality
Management Program (QMP). HACCP is currently
voluntary through the Food Safety Enhancement
Program (FSEP) in federally registered meat,
dairy, processed fruit and vegetable, shell egg,
processed egg, honey, maple and hatchery
establishments.
CFIA AND HACCP
7
The On-Farm Food Safety Recognition Program
(OFFSRP) is a producer led on-farm food safety
program which is based on HACCP principles. CFIA
provides recognition services to National
Association's who have developed On-Farm Food
Safety programs. Funding through the Canadian
On-Farm Food Safety Program (COFFS).
OFFSRP COFFS
8
The Quality Management Program is a mandatory
HACCP based program which directly ties in
registration with implementation of a HACCP
system in over 500 registered fish processing
establishments. Implemented in 1992 (Fisheries
and Ocean Canada) the program was re-engineered
in 1997.
QMP
9
The Food Safety Enhancement Program (FSEP) is
CFIAs program designed to encourage the
establishment and maintenance of a HACCP system
in all federally-registered meat and poultry
establishments. Initiated in the early
1990's. Information on CFIA web site at
www.inspection.gc.ca
FSEP
10
Complete written program who does what, how,
when, records 1- Building (sound construction
and design (separation of incompatible
activities) garbage disposal potable water
…) 2- Transport and storage (transport
vehicules storage of received products,
chemicals …) 3- Equipment design, installation,
preventive maintenance calibration …) 4-
Personnel training in food hygiene technical
training employee hygienic practices 5-
Sanitation program pest control program 6-
Recall procedures product identification
records of distribution, complaints, efficient
recall procedures
FSEP COMPONENTS - Prerequisite programs
11
The implementation of a HACCP system requires 12
steps that includes the 7 principles established
by Codex 1- An implementation Team is put
together HACCP coordinator 2-
Product-ingredients description 3- Product
end-use description 4- Sequential production
description plants operation drawing 5-
On-site verification of Sequential production
description plants operation drawing 6- List
the Hazards (principle 1) associated with each
production step
FSEP COMPONENTS HACCP plans
12
7- Determine CCP (principle 2) 8- Establish
Critical Limits (principle 3) 9- Establish
Monitoring Procedures (principle 4) 10-
Establish Deviation Procedures (principle 5) 11-
Establish Verification Procedures (principle
6) 12- Establish Record Keeping Procedures
(principle 7) 13- Updating system of the
recognized HACCP system
FSEP COMPONENTS HACCP plans
13
The primary reason for implementing mandatory
FSEP is to enhance the safety of food produced in
and imported into Canada. Realizing this, the
Canadian food industry has been gradually
implementing FSEP on a voluntary
basis. Prompted largely by trade interests, the
meat sector has been leading the way, to the
extent that approximately 71 of the federally
registered meat establishments (including
registered storages) have completed or are in
the process of implementing FSEP.
MANDATORY FSEP
14
Under FSEP, CFIA inspectors use an audit
approach (based on ISO 10011 audit guidelines) to
verify that prerequisite programs and HACCP plans
are being implemented as planned and that they
are effective. The audit system is based on
scientific information utilized to assess the
risk of processes and products. All regulatory
requirements and inspection authorities are still
be applicable.
VERIFYING COMPLIANCE UNDER FSEP
15
Mandatory FSEP in establishments registered under
the Meat Inspection Regulations Proposed
regulatory amendments
16
Governor in Council (GIC) Regulations
THROUGH SCC
RECOMMENDS GIC REGULATIONS
GIC REGULATIONS
17
REGULATORY PROCESS OVERVIEW - GIC
Regulations 1. Problem Identification 2.
Regulatory Policy Development 3. Regulatory
Policy Approval 4. Regulations and Supporting
Documentation (e.g. RIAS, communications plan)
Drafted 5. Regulations Reviewed by Department of
Justice 6. Agency Approval 7. Ministerial
Approval 8. SCC Approval 9. Prepublication -
Canada Gazette Part I 10. Final
Regulations/RIAS 11. Agency Approval 12.
Ministerial Approval 13. SCC Approval 13. Final
Publication - Canada Gazette Part II
18
Mandatory FSEP
  • Gazette I August 23th, 2003
  • Gazette II Published N.B. Nov 2004?
  • Implementation
  • Phase in period (Nov 2004 Nov 2005)
  • Full implementation (Nov 2005)

19
Consultation process
  • Proposed regulatory amendments were published in
    the Canada Gazette Part I on Saturday August 23,
    2003 Regulatory Impact Analysis Statement
    (RIAS) Proposed regulatory text.
  • The comment period was established at 75 days
    from the date of publication in the Canada
    Gazette part 1 - extended by 30 days (US
    request). The final date for comments was 12
    December 2003.

20
Consultation process
  • 1990 extensive consultation FSEP implementation
  • 1998 consultation on Mandatory FSEP proposal
  • 1999 information to stakeholders intention to
    proceed with mandatory implementation of FSEP
  • 2001 consultation strategy and activities
  • Explore issues of concerns
  • Information to stakeholders on proposed
    regulatory text
  • Encourage dialogue

21
Consultation process
  • National Mandatory FSEP Developmental Team
  • Readiness Survey
  • Presentations to Federal/Provincial/Territorial
    Agri-Food Inspection Committee and the Canadian
    Food Inspection System Implementation Group
  • Industry Information Days
  • Consultation letter describing the proposed
    regulatory changes
  • Presentations to National processors associations

22
Consultation process
  • National Mandatory FSEP Developmental Team …
  • Performance Criteria Committee
    government/industry
  • Meetings with CFIA staff and unions
  • Web site all relevant documents
  • http//www.inspection.gc.ca/english/anima/meavia/h
    accpcome.shtml
  • Electronic mail notification service (Listserv)

23
Regulations amending the Meat Inspection
Regulations, 1990 Gazette 1, Vol. 137, No. 34
  • For more details on this proposed amendment,
    refer to the Canadian Food Inspection Agency
    (CFIA) web site
  • http//www.inspection.gc.ca/english/reg/consultati
    on/reginite.shtml
  • http//www.inspection.gc.ca/francais/reg/consultat
    ion/reginitf.shtml

24
Proposed mandatory FSEP Components of regulatory
proposal
  • All meat ( poultry) registered establishments
    and storages
  • Condition of licence
  • Performance Criteria
  • Equivalency for imported meat products

25
Performance criteria
  • Generic E. coli as indicator of hygiene control
  • Salmonella as target pathogen
  • Others under discussion
  • Campylobacter spp.
  • Micro. Performance criteria for sanitation
  • Listeria spp. for environment of Ready-to-Eat
    products

26
Performance criteria
  • Over time, criteria (pathogen levels) will be
    reduced
  • Governments will have objective mean to evaluate
    industries HACCP systems
  • Industry will be able to evaluate their HACCP
    system against the national level and self
    improve.

27
How can present food safety systems be improved
at all points along the food chain?
HACCP based principles have the potential to be
applied to all segments of the food continuum
from the field to the plate. "First and formal
all food service operators must have a food
safety system based on the principles of HACCP,
... it is an internationally recognized food
safety system that basically does a risk analysis
and a science control measures to make sure that
all treats or risks are properly managed it is
recognized as the pre-emminent food safety
system." E. coli Summit in San Antonio, Dave
Theno, vice president of food safety at Jack in
the Box Restaurants, January 2003
28
FOOD SAFETY IS A SHARED RESPONSIBILITY
How can present food safety systems be improved
at all points along the food chain?
Beyond HACCP
Multi-hurdle approach Producers Farmers Food
processors Distributors Retailers Consumers Regula
tory Autorities
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