2013 Her Majesty the Queen in Right of Canada (Canadian Food
Inspection Agency), all rights reserved. Use without permission is
prohibited. CMC Annual Conference May 8, 2014 International Trade
and Market Access - Is your company facing the new trade
challenges? Tom Graham Director, Domestic Inspection Division
CFIA
Slide 2
2 Definition: Re-opening, maintaining and expanding markets to
the Canadian industry. With almost half of Canada's total
agricultural and food production exported, the potential for growth
in these sectors lies in its ability to expand markets abroad,
making market access a key priority for both industry and
governments. Market Access
Slide 3
Industry 3 Increase Market Access: Govt & Industrys Role
Foreign Affairs, Trade and Development Canada Canadian Food
Inspection Agency Agriculture and Agri- Food Canada
Slide 4
4 Every year, the Government (helped by Industry) identifies
priority markets deemed to hold the most potential for Canadian
exports of agri-food. For example: 1. Established markets: European
Union (EU), Japan, Mexico, South Korea, Taiwan, United States (US),
etc. 2. Emerging markets: China, India, Indonesia, Russia, etc.
Identifying Priorities
Slide 5
5 Outcome of this Ambitious Trade Agenda As a result of the
intense promotion and negotiation work done abroad, importing
countries send foreign delegations to verify, audit, inspect and/or
gather information on Canadas food inspection system and/or on
regulated parties. The number of requests to host incoming foreign
missions has increased in recent years, and is anticipated to
increase even more in the future. In 20112012, the CFIA received 45
audit and inspection missions from more than 21 foreign entities.
In 20122013, 48 missions were scheduled.
Slide 6
6 Examples: 1. visits for new, expanded or to regain market
access 2. audits and/or inspections for ongoing market access 3.
technical assistance, cooperation, outreach, and capacity building
4. bilateral sanitary and phytosanitary (SPS) committees 5.
consultative committees on agriculture (CCAs) 6. other senior-level
meetings, working group meetings, and invitations and
relationship-building. Purpose of Foreign Missions
Slide 7
Foreign Audits CFIA Inspection System CFIA Field Staff Fed.
Regd Est 7 Audit Audits of the Canadian inspection systems are
conducted to maintain or expand Canadian access to an existing
market, or to obtain access to a new market. Audits encompass both
the: evaluation of a countrys regulatory system (i.e. CFIAs Meat
Inspection System) and; the inspection of Establishments as part of
the examination process. Foreign Audits
Slide 8
8 Incoming Foreign Audits Process 8
Slide 9
9 1. Government of Canada receives foreign audit requests. 2.
Sometimes we are notified as short as 2 weeks prior to the actual
audit date. 3. It is at this time that we are informed of
Establishments selection. It can be: 1. Chosen by the Foreign
Country; 2. Chosen by CFIA; 3. On a voluntary basis. 4. If
Establishments are chosen by the Foreign Country it is often based
on: violations at Point-of-Entry, volume exported, recall history,
etc. 5. Audit Itinerary is then drafted by both the Foreign Country
and CFIA. Foreign Audits Process - Preparation
Slide 10
10 5. The foreign country may share with CFIA a foreign country
requirements verification checklist and/or a questionnaire to be
filled out by Establishments and/or CFIA prior to the audit. Often
this questionnaire needs to be translated from foreign country
language into both French and English. 6. Once these documents are
translated they are forwarded to local CFIA staff for distribution
to Establishments. 7. Local CFIA staff, accompanied by Area and/or
National CFIA staff are then required to conduct a Pre-Audit
Verification Activity in each Establishment to verify compliance to
Canadian and foreign country requirements (as published in MOP).
Foreign Audits Process - Preparation
Slide 11
11 8. Preparation by Industry: If your Establishment is
selected for a foreign audit, as best practices the following
activities can be done ahead of time to help prepare: a) Ensure
your HACCP System is complete and up-to-date; b) Prepare ahead of
time an itinerary for the plant tour; c) Do several walks-around
and ensure interior and exteriors condition are in optimal
condition (no loose caulking, no dirt or build-up on overheads,
equipment in good condition, etc). If necessary re- prioritize
already issued work-orders to be completed prior to the audit; d)
Re-prioritize non-daily cleaning schedule so these items are
cleaned prior to the audit; e) Conduct an employee meeting and
provide a refresher GMP training; f) During the audit, ensure you
have reliable employees conducting operational sanitation tasks,
removing condensation, etc.. Foreign Audits Process -
Preparation
Slide 12
12 9. Once the Foreign Delegation arrive in Canada the CFIA
will host an opening meeting in Ottawa. 10. During this meeting
CFIA provide to the delegation information on the Canadian
Inspection System so they have a full understanding of our system
before they start auditing Establishments. Foreign Audits Process
Opening Meeting
Slide 13
13 11. During the foreign audits, the following Government of
Canadas staff may accompany the auditors: National Operations
and/or National Program staff Area Export Specialist Regional
Veterinary Officer Supervisor Veterinarian or Inspector In Charge
of your Establishment Translators AAFCs Market Access Secretariat
Officer 12. The Foreign Delegation may be composed of one to
several Auditors, however there is always a Lead Auditor. Foreign
Audits Process - Delivery
Slide 14
14 13. During plant tours, the Establishments highest official
(Quality Assurance or Production) should accompanying the Foreign
Lead Auditor during the tour. 14. During the tour, this company
representative should follow the Foreign Lead Auditor side-by-side
and take good notes of his or her observations. 15. If the Foreign
Lead Auditor seems to focus his or her gaze on a particular area of
the room that is a food safety issue or could potentially be a food
safety issue, the company representative should immediately take
charge and control of the situation and immediately correct the
issue. Ideally even before the Foreign Lead Auditor say anything.
Foreign Audits Process - Delivery
Slide 15
15 16. Each Foreign Auditor has different audit style. For
example, some will remain silent and point with their flashlight
and if no-one is there to see those findings, these findings will
remain undocumented until found in the foreign country final
report. 17. Always show respect to the Auditors work, do not have a
confrontational attitude. This will not help your Establishment and
the industry as a whole. 18. Remember the true purpose of these
audits is to either: a) Open new markets to Canadian products,
expand existing market to more products or maintain actual market
to Canadian products. b) Convince that your Establishment meets all
necessary requirements and should be allowed to be on the list of
Establishments eligible to export to this Country. Foreign Audits
Process - Delivery
Slide 16
16 19. Good audit practices requires Foreign Auditors to
discuss audit findings at the Establishments closing meeting but
they do not always do. 20. All audit findings will be documented by
the CFIA inspector on CVS Task 3.3.01 Foreign Audit. This task has
just been revised and will be published shortly: On this new task,
all Audit Findings made by Foreign Auditors will be sorted into 4
categories of findings. Foreign Audits Process Audit Findings
Slide 17
17 Audit Findings Canadian Requirements Items noted by the
foreign auditor CFIA method of documentationExamples Audit finding
related to Canadian domestic requirements (MOP & FSEP). 1-
According to Chapter 18, a CAR must be issued when there are
deviations to the regulatory requirements or HACCP system which:
could cause or have caused product contamination or adulteration;
affect the integrity of the HACCP system or other control programs;
represent fraudulent practices; affect animal welfare or health;
and/ or, contravene requirements related to CFIA Inspector
facilities and/or stations. A CAR will then be issued under CVS
Task 3.3.01 Foreign Audit Large cracks and/or flaking cement on
floor of a cooler; Meat residues from previous days production
found on equipment; Housekeeping issues throughout the
Establishment; Refrigeration units in production room with slime on
coils; Thermal process critical limit not met and no action taken
by the operator; and Fecal residues found on carcasses in the
cooler; inhumane stunning or bleeding of animals.
Slide 18
18 Audit Findings Canadian Requirements Items noted by the
foreign auditor CFIA method of documentationExamples Audit finding
related to Canadian domestic requirements (MOP & FSEP). 2- If
the audit finding is considered a minor item that have no impact on
food safety and/or do not compromise the intent of applicable
legislation, the level of compliance is considered Acceptable and
the CVS Task 3.3.01 Foreign Audit Is then rated "A. These items
will be followed up in 30 days. Dust on shelves in box storage
room; Small cracks on floor in production room; Minor ice
accumulation in the freezer.
Slide 19
19 Audit Findings Foreign Requirements Items noted by the
foreign auditor CFIA method of documentationExamples Audit Finding
related to foreign countrys requirements published in the MOP
(Chapter 11 requirements) 3- According to Chapter 18, when the
audit finding is a deviation to export requirements published in
Chapter 11, a CAR must be issued under CVS Task 3.3.01 Foreign
Audit During a Russia audit, no segregation policy in place for
Russian products; During a Korea audit, pork products for Korea
were found to be derived from USA pork products.
Slide 20
20 Audit Findings Foreign Requirements Items noted by the
foreign auditor CFIA method of documentation Examples Audit Finding
generated from the auditors opinion and/or a possible foreign
country requirement which is currently NOT published in MOP
(Chapter 11) 4- These audit findings will not generate a CAR or
will not become a A with comments. They will be documented by CFIA
staff and will become points of discussion during the closing
meeting in Ottawa. The Auditor notes that the establishment parking
lot is not paved; The Auditor asks that live cattle be washed prior
to slaughter; Auditor mentions that employee should wear red smock
in raw areas; Auditor wants Establishment to have access to
employees medical information despite privacy laws; Condensation in
raw plant should be tested for listeria.
Slide 21
21 21. As per Chapter 18, when a CAR is issued under CVS Task
3.3.01 Foreign Audit the Operator must provide an acceptable
written action plan to CFIA. 22. In addition, the applicable CVS
task related to an audit finding that has generated a CAR under CVS
Task 3.3.01 Foreign Audit will be prioritized by local staff and
delivered within the next month following an audit (for example if
condensation was observed during a foreign audit in the cutting
room and a CAR was issued under task 3.3.01 for that reason, the
condensation task will be delivered in your entire Establishment
within the next month). Foreign Audits Follow Up
Slide 22
22 23. CFIA cannot predict what the Foreign Audit Final Report
will contain until it is sent to the CFIA. At the time of the
audit, what appears to be an isolated observation in your
Establishment may be re- occurring in other Establishments and
become an equivalency item in the Foreign Audit Final Report. As a
result, no audit observation should be taken lightly and thus be
properly documented by the local CFIA inspection staff. Foreign
Audit Final Report
Slide 23
23 Upcoming Foreign Audits CountryBusiness LineDates EUMeatMay
2-15 2014 FSIS (USA)MeatMay 27 to June 13, 2014