Copyright © Global Coalition for Sustained Excellence in Food & Health Protection, 2011 and ALL subsequent years: Unauthorized use and/or duplication of this material without express and written permission from this blog’s authors and/or owners is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Global Coalition for Sustained Excellence in Food & Health Protection with appropriate and specific reference and/or link to the original content.

Saturday, 6 February 2016

Guarding Against Assumptive & Misleading Conclusions


Announcements of this sort are well and good but I would suggest that you carefully read the policy before assuming that CFIA will accept GFSI certification in lieu of its regulatory oversight. The term “private” used by CFIA to describe these certifications is with deliberate intent. GFSI schemes may be acknowledged by regulatory bodies. This does not necessarily mean that the regulatory bodies endorse or sanction the private certification schemes. It certainly does not mean that the regulators require food business to be certified to the schemes.

In the CFIA Policy for example, CFIA says it has enough confidence to “consider” GFSI certification. What must be understood about this consideration is explained in points that are clearly stated within the policy.
Here are some of the points in the policy statement:

"In determining the level of risk associated with a regulated party or their establishment, the CFIA may assess the requirements of a private certification scheme used by the regulated party against food safety regulatory requirements and factor the assessment results into its risk-based planning and prioritization."

Note, from this statement, that CFIA "may assess", i.e. CFIA is not committing to doing so. CFIA, in this statement, also clearly asserts the superiority of its food safety regulatory requirements over private certifications.

"It should be noted", the statement went on to say, "that there is no requirement by virtue of this policy for a regulated party to become certified to any private certification scheme nor does this negate regulatory oversight."

This point of note clearly and sufficiently states the stance that CFIA has taken with private certification schemes. Food businesses may have private certifications but they are still going to be subject to regulatory oversight (i.e. regulatory inspections or assessments with expected mandatory compliance).

Refer also to point #7 under the heading "Assessment Process". It states:
"Assessment outcomes will not constitute any formal approval, recognition or endorsement of the private certification schemes by the CFIA"

A policy notification email has also been sent out to subscribers by CFIA as provided below:

February 3, 2016

The Canadian Food Inspection Agency (CFIA) has published its Private Certification Policy (Food Safety) http://www.inspection.gc.ca/about-the-cfia/accountability/consultations/regulatory-risk-based-oversight/private-certification-policy/eng/1452808755126/1452808821799, which was developed based on stakeholder feedback. 

This policy will enable the CFIA to enhance its risk-based oversight by considering private certification schemes as one of several factors when planning its activities, and allow the Agency to target its inspection activities in areas of highest risk.  

Private certification schemes are formal, documented food safety systems that are developed and administered by the private sector. The policy does not require a change of regulations and does not replace regulatory oversight. The CFIA will continue to verify compliance with regulatory requirements. 

The CFIA will not recognize or endorse any private certification schemes. All private certification schemes will be assessed individually. An establishment certified by a private certification scheme that the CFIA has assessed may see adjustments in inspection frequencies as the Agency focuses on areas of greatest risk. Industry remains responsible for choosing certification schemes that suit their needs.       

For more information on the policy, please contact:

Program Policy Integration Division
Program Regulatory and Trade Policy Directorate Policy and Programs Branch, CFIA

The U.S FDA-FSMA takes a similar stance as is reflected in the Canadian (CFIA) policy. For example, FDA, under FSMA, recognizes the auditor qualification process of the GFSI schemes but it reserves the right to assess such auditors against expectations under FSMA. You may read the full post on “FSMA Comments Relating to GFSI Schemes 
Posted by Felix Amiri
___________________________________________________________
Felix Amiri is currently the chair of GCSE-Food & Health Protection

No comments:

Post a Comment