The Canadian Food Inspection Agency (CFIA) has issued a draft food inspection model as part of its Inspection Modernization: Optimizing Confidence in Food Safety plan. According to CFIA, the modernized approach to food inspection will apply to both imported and domestic commodities and, in addition to the inspection model, rely on modern science, improved data collection and better training and tools for CFIA inspectors.
The new draft model apparently favors a risk-based approach to regulatory oversight and covers the following components: (i) licensing and registration, (ii) CFIA oversight, (iii) inspection, (iv) compliance and enforcement, and (v) system performance. In particular, food and beverage manufacturers would need to develop “preventative control plans scalable to the size and complexity of their operation” that “mitigate all sources of food safety risk and demonstrate that the measures effectively meet regulatory requirements.” CFIA would in turn determine the level of required oversight—enhanced, normal or reduced—based on risk factors in the domestic- and imported-food sectors, as well as implement a systems approach to inspection that “assesses the regulated parties’ plans and processes to ensure that food is prepared safely and complies with regulations.”
Under these proposed measures, CFIA would ultimately be responsible for communicating industry requirements and “using risk and science-based tools to determine that industry’s controls are effective and acceptable,” while regulated parties would need to demonstrate compliance and provide evidence “that their controls and operating processes result in safe food.” In the event of non-compliance, CFIA would determine “the most appropriate response” based on the circumstances, potential for harm, intent of the regulated party, and previous performance. Such responses could include the issuance of corrective action requests, letters of non-compliance or import alerts; the detainment, forfeiture, disposal, or recall of products; a refusal to certify a product; suspension of licensing; or prosecution. The agency has also proposed a system performance review designed to “assess [the] overall effectiveness of the food inspection system,” “identify gaps and trends,” and “create accountability and provide feedback to support continuous improvement.” Additional details about the inspection modernization plan appear in Issue 442 of this Update.