CHAPTER 2 - ESTABLISHMENT INSPECTION METHODS
AND PROCEDURES
2.0
Introduction to the Multi-Commodity Activities Program (MCAP) . . . . . . . . . . . . . . . . . 1
2.1
Explanation of the inspection criteria in chapters 4 and 5 . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.1.1
2.1.2
2.1.3
2.1.4
2.2
Steps in the inspection of an establishment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2.2.1
2.2.2
2.2.3
2.2.4
2.2.5
2.2.6
2.2.7
2.2.8
2.2.9
2.2.10
2.2.11
2.2.12
2.2.13
2.2.14
2.2.15
2.2.16
2.3
Chapter 4: General Inspection Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Chapter 5: Manufacturing Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Table descriptions of Chapters 4 and 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Risk Categories I, II, III, Sa, N/A and N/I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Determining the type of inspection to be conducted . . . . . . . . . . . . . . . . . . . . . . . 5
Establishing inspection frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Creating the inspection team . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Determining the inspection date . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Notifying the establishment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Reviewing the establishment’s file and other documentation relevant to the
inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Preparing inspection material and equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Meeting with establishment management before the inspection . . . . . . . . . . . . . . 8
Determining the order of inspection with establishment representatives . . . . . . . 9
Conducting the in-depth inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Recording observations on the worksheets during the inspection . . . . . . . . . . . . 11
Collecting product samples during or after the in-depth or directed inspection . 11
Writing the inspection report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Discussing the inspection results with establishment management . . . . . . . . . . . 12
Discussing the action plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Providing the inspection report and receiving the action plan . . . . . . . . . . . . . . 13
Compliance levels, action plan and corrective action . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
2.3.1
2.3.2
2.3.3
2.3.4
2.3.5
2.3.6
Follow-up for Category I deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Follow-up for Category II deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Follow-up for Category III deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Follow-up for Category II and III deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Critical health and safety implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
Repetitive deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
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2.4
Safe work practices during an establishment inspection . . . . . . . . . . . . . . . . . . . . . . . . . 18
2.4.1
2.4.2
2.4.3
2.4.4
2.4.5
2.4.6
2.4.7
2.4.8
Manual material handling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Moving vehicles . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Personal protective equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Slip and fall prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Establishment premises hazards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Climbing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Emergency procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Right to refuse . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
ANNEX I
Method for Calculating Compliance Percentages (Overall Rating) . . . . . . . . . . . . . . . . 21
ANNEX II
Sample Covering Letter . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
ANNEX III
Health Canada Risk Assessment Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
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2.0
Introduction to the Multi-Commodity Activities Program (MCAP)
The CFIA’s Multi-Commodity Activities Program (MCAP) database is a computerized system
that compiles the inspection data used to produce the establishment inspection reports. The inspection
assessment criteria set out in Chapters 4 and 5 are found in the MCAP database. Should any criteria
not appear in the MCAP database, refer to Chapters 4 and 5 of this manual.
The inspection team must create a specific inspection worksheet that is customized for the type of
establishment and the processes used in this establishment. The preprinted inspection worksheet will
serve as the main reference during the inspection.
For information on how to create inspection worksheets, refer to the MCAP manual.
2.1
Explanation of the inspection criteria in Chapters 4 and 5
Chapters 4 and 5 contain the inspection criteria that apply to the areas in an establishment to be
inspected. In these chapters, we identify which task applies, depending to the establishment type, i.e.:
•
•
•
Sugar bush operator (MSB): SEE THE CHAPTER 4 ONLY DATED FEBRUARY 2012
Maple products packing plant (MP): SEE THE CHAPTERS 4 & 5 DATED JANUARY 2007
Maple syrup shipper (MSS): SEE THE CHAPTERS 4 & 5 DATED JANUARY 2007
These establishment types are described in Chapter 1.
2.1.1
Chapter 4: General Inspection Criteria
Chapter 4 sets out the general inspection criteria related to the prerequisite programs under the
CFIA’s Hazard Analysis Critical Control Point (HACCP) program. The chapter is divided into eight
major sections:
•
•
•
•
•
•
•
•
Premises
Transportation and storage
Equipment
Personnel
Cleaning and sanitation
Recalls
Written programs
Records
2.1.2
Chapter 5: Manufacturing Controls
Chapter 5 sets out the inspection criteria for the major steps involved in controlling maple products
preparation. The chapter is divided into ten major sections:
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•
•
•
•
•
•
•
•
•
•
Incoming materials
In-process packing and containers
Product preparation/blending
Filling
Container closure
Cooling
Labelling
Defective products and corrective action
Written programs
Records
2.1.3
Table descriptions of Chapters 4 and 5
The inspection criteria in Chapters 4 and 5 are presented in table format as follows:
Section
ö
Subsection
ö
Task & establishment type ö
4.1
PREMISES
BUILDING INTERIORS
4.1.4
Ventilation
MP
MSS
Principle
ö
PRINCIPLE
Adequate ventilation is provided to prevent excessive accumulation of heat, steam,
condensation and dust and to remove contaminated air.
Assessment criteria
ö
Assessment
criteria
-
Rating and examples
Ventilation provides sufficient air exchange to prevent excessive accumulation of
heat, steam, condensation or dust.
Ventilation openings are equipped with close-fitting screens to prevent the entry of
pests.
Rating
Examples
I
-
N/A
II
-
Inadequate ventilation, condensation/mould evident, and risk of final product
contamination.
Screens in ventilation openings not close-fitting.
ö
III
-
References
ö
References
Inadequate ventilation, condensation/mould evident, but product contamination
unlikely.
Condensation dripping on a food product that will undergo a further microorganism
kill step.
MPR
None
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Section
Major divisions of Chapters 4 and 5, as described in sections 2.1.1 and 2.1.2 above.
Subsection
Subdivisions of the sections of Chapters 4 and 5.
Task and establishment type
Each task contains a single principle to which a number of assessment criteria are linked. The task
is the basis for the rating system, i.e. the inspector assigns a rating to each task. Once each task has
been rated, the inspector can calculate the establishment’s overall compliance level. Chapters 4 and
5 indicate the establishment type(s) to which each task applies:
MSB =
MP =
MSS =
Sugar bush operator: SEE THE CHAPTER 4 ONLY DATED FEBRUARY 2012
Maple products packing plant: SEE THE CHAPTERS 4 & 5 DATED JANUARY 2007
Maple syrup shipper: SEE THE CHAPTERS 4 & 5 DATED JANUARY 2007
Principle
A principle is a generic statement. A principle statement is broadly worded to allow a certain degree
of flexibility for the introduction of new technologies and food commodities. Each principle
statement has one or more assessment criteria.
The principles are similar to the Codex Alimentarius General Principles of Food Hygiene and the
International Organization for Standardization (ISO) standards. These statements imply that the
operator controls all factors affecting health and safety.
Assessment criteria
The assessment criteria are the various items that the inspector must evaluate in order to decide
whether there is compliance with the principle statement and to determine the rating for the task.
As new technologies and/or commodities become available, the addition of new criteria may become
necessary. For this reason, current assessment criteria should not be regarded as exhaustive.
Rating and examples
Examples are provided to guide inspectors in assessing the rating for each task, in accordance with
the level of risk (see section 2.1.4 above). These examples provide inspectors with benchmarks,
promoting uniformity of the level of risk in the assessment of the tasks. The examples are based on
the experience of CFIA personnel and are meant to be as realistic as possible. It must be noted that
they are examples only and not an exhaustive list of all possible deficiencies or situations.
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References
A list of regulatory and general references accompanies each task. The following abbreviations are
used:
CAP Act: Canada Agricultural Products Act
MPR:
Maple Products Regulations
2.1.4 Risk Categories I, II, III, Sa, N/A and N/I
The risk categories and rating system are based on the Health Risk Assessment Model, which is
found in Annex III to this chapter. The risk categories are as follows:
Category I – deficiencies entailing a risk with a high likelihood of occurrence and serious health
consequences.
Category II – deficiencies entailing a moderate health risk or a direct source of contamination or
adulteration. These can be direct sources of contamination or adulteration or repetitive regulatory
infractions (e.g. sensitive ingredients, foreign materials).
Category III – deficiencies entailing regulatory violations, a low health risk or an indirect source of
contamination or adulteration.
Satisfactory (Sa) – no health risks or risks of contamination or adulteration were observed.
If Not Applicable (N/A) is indicated for a category, this means that there generally cannot be any
deficiencies with this level of risk for this task.
The inspector assesses the task and assigns a single rating to it, no matter how many assessment
criteria the task has. The inspector must use the most severe deficiency as the basis for determining
the rating of the task. Each task will therefore be rated I, II, III, Sa, or one of the following:
Not Inspected (N/I) – the item cannot be assessed because the equipment is not available for
inspection or because the item to be assessed is related to a part of the establishment that is not
operational. In this case, the lack of assessment of the item will have no impact on the overall
establishment rating.
Not Available (N/A) – the task cannot be assessed because the item does not exist in the
establishment. In this case, the lack of assessment will have no impact on the overall establishment
rating.
The method for calculating the overall establishment rating is found in Annex I to this chapter.
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Override provision
During an inspection, conditions may be found to increase or decrease the likelihood of occurrence
of a hazard. In such cases, the inspector may choose to override the prescribed assigned rating.
Overrides, when used, must be clearly identified on the inspection worksheet together with a written
justification for the change. These unusual cases are evaluated against the Health Risk Assessment
Model, which is found in Annex III to this chapter.
2.2
Steps in the inspection of an establishment
2.2.1 Determining the type of inspection to be conducted
There are two types of inspection.
An in-depth inspection includes all general-type inspection criteria from Chapter 4, as well as all
process-specific criteria from Chapter 5, to the extent that they are applicable to the establishment.
A directed inspection draws selectively from Chapters 4 and 5. This type of inspection is often
referred to as a partial or Good Manufacturing Practices inspection. This inspection focusses on:
-
serious deficiencies noted during previous in-depth inspections. Prior to arriving at the
establishment, the inspector must review the establishment file to determine the outstanding
tasks for the directed inspection. The priority is to review the corrective action taken for
Category I and II deficiencies identified in the action plan.
-
product inspection as outlined in work plan requirements, such as verification of grade, net
quantity, ingredients and closure quality, as well as product sampling in accordance with the
laboratory analysis sampling plan. The Maple Products Inspection Manual provides more
details about product inspection.
2.2.2 Establishing inspection frequency
Each federally inspected establishment should be subject to an in-depth establishment inspection at
the following frequencies:
Type of establishment
Frequency of in-depth inspection
Sugar bush operator
Once every 2 years
Maple products packing plant
Once a year
Maple syrup shipper
Once a year
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2.2.3 Creating the inspection team
The inspection team concept is useful for the inspection of prepared maple products establishments,
particularly for larger, high-risk establishments. The decision on whether one or more inspectors are
required can be made at the area or regional level depending on the complexity of the preparation
processes, the size of the establishment and the time frame in which the in-depth inspection is to be
conducted.
The team approach is used for the following reasons:
a)
One inspector can remain to observe the operator’s processing activities, while the other
inspector may inspect the preparation activities. Inspectors may exchange places during the
inspection in order to provide a fresh perspective on a particular activity.
b)
Two inspectors with different experience and backgrounds have a broader experience base.
The inspection team will have more confidence when discussing critical deficiencies, and the
team approach is a good way to prevent intimidation by the company.
c)
The team concept greatly improves inspection uniformity, provided that the same two
inspectors do not always work together. Each inspector learns something from the other
inspector, making the Area more consistent in its identification and scoring of infractions.
d)
The inspection team size will vary depending on the type of inspection being conducted
(in-depth/directed).
e)
For specific safety purposes, it may be preferable for the inspection to be conducted by two
inspectors.
According to the situation, other government agencies may be involved and conduct inspections.
2.2.4 Determining the inspection date
Sugar bush establishments are in production on a seasonal basis, i.e. in early spring, and are therefore
inspected during this period. Inspections of packing and shipper establishments can generally be
conducted year-round.
2.2.5 Notifying the establishment
Under normal circumstances, the inspector must not notify the establishments’ management of the
date of the in-depth inspection. If production is irregular, the inspector can verify that the
establishment is operating on that date. It is helpful if an establishment representative accompanies
the inspection team. The owner or person in charge of a place and every person found in that place
shall give the inspector all reasonable assistance to enable the inspector to carry out the inspector’s
duties and functions and shall furnish the inspector with such information with respect to the
administration of the legislation as the inspector may reasonably require.
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2.2.6 Reviewing the establishment’s file and other documentation relevant to the inspection
Establishment’s file
The inspection team must review the establishment’s file and determine the type of process to
inspect, in order to:
-
identify establishment manager and key personnel by name;
review previous in-depth inspection reports, action plans and corrective action;
review directed inspection summaries;
review consumer and competitor complaints;
have an understanding of the size and age of the establishment as well as the products
prepared there;
consult the establishment’s flow diagram showing the general movement of raw, in-process,
and finished products within the establishment, if such a diagram is available;
take note of any unique features of the establishment, such as equipment, preparation
schedules, size or product lines; and
decide, if possible, where the inspection will begin and find out when operations, major
cleaning and sanitation, and a second shift (if applicable) can be observed.
Other documentation to be reviewed
-
Canada Agricultural Products Act; Maple Products Regulations; Food and Drugs Act and
Food and Drug Regulations; Consumer Packaging and Labelling Act (CPLA)
Maple Products Establishment Inspection Manual
Guide to Food Labelling and Advertising, CFIA
Any available technical and scientific information on the products being prepared, the
preparation methods and the equipment being used in the establishment.
2.2.7 Preparing inspection material and equipment
Each inspector must have the following equipment and must use or wear it where appropriate:
Identification
–
inspector’s CFIA identification card
–
business cards
Protective clothing
–
clean, Canadian Standards Association (CSA)-approved safety hat (white)
–
hairnet and beard net (if applicable) in good condition
–
nuisance dust mask
–
CSA-approved eye and hearing protection
–
clean, white lab coat with snap or velcro fasteners and with no pockets above the waist (or
equivalent, e.g. coveralls)
–
five-finger overgloves
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–
–
–
no jewellery or watches while performing the inspection (only unremovable plain wedding
bands are tolerated, provided they are covered by sanitary gloves)
sanitized rubber safety boots
clean, CSA-approved non-slip safety footwear
Inspection equipment
–
case
–
flashlight in good working order
–
light meter
–
accurate thermometer with a steel shaft
–
refractometer (portable)
–
colorimeter (portable)
–
sampling containers
–
box for transporting samples
–
dipper
–
pencil or pen (without a cap) for filling out inspection worksheets and reports, and clipboard
that can be easily sanitized
Forms
–
MCAP Inspection Worksheet
–
detention and release forms
–
sufficient quantity of self-adhesive CFIA detention tags
–
sampling form, if necessary
–
sufficient quantity of self-adhesive CFIA sample labels
–
CFIA-identified sealing tape
References
–
copy of the regulations
–
copy of the establishment inspection manual
2.2.8 Meeting with establishment management before the inspection
Opening Meeting
When meeting with establishment management, the inspection team must demonstrate courtesy and
professionalism by following these rules:
-
Ask for the establishment manager or person in charge.
Present identification cards or business cards and introduce the team members.
Explain what the team will do and agree on an inspection time frame.
Inform management that the results will be discussed once the inspection has been completed,
and arrange a time to meet and discuss the results.
Invite an establishment representative to accompany the inspection team.
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Professionalism
A well-organized, well-groomed, properly equipped inspector reflects the professional image
expected of the Agency. Demonstrating cleanliness and tidiness is way to practise what we preach
about sanitation. The inspector is an official representative of the Agency and must project a
professional image when dealing with establishment officials. This includes respect for establishment
policies and good interpersonal skills. All information discussed and obtained from a specific
company must remain confidential. However, the Access to Information and Privacy (ATIP) office,
may make the inspection reports available according to the requirements of the Access to Information
Act (including its exemptions and exclusions).
Establishment representative
Some establishment managers will insist on accompanying the inspection team or on having a
foreman or quality assurance person accompany the inspection team at all times. This is preferable
to being left on one’s own, because questions can be asked on the spot and serious deficiencies can
be pointed out as observed; this way, immediate action can be taken. Assistance is also needed in
reviewing records and programs, and some guidance may be required if the facility is a new
establishment. As well, establishment personnel are encouraged to carry out their own in-depth
inspections both with the inspection team and independently as required by their establishment.
However, inspectors must not allow accompanying plant personnel to rush the inspection or to lead
them away from the non-compliance.
Scheduling
The inspection team must determine what the establishment working schedule will be during the
course of inspection (i.e. shift work, hours of work, etc.). To ensure that the inspection goes as
smoothly as possible, the inspection team and establishment management must establish an
inspection schedule. Every effort must be made to assess the items in an operational condition. Where
applicable, it may also be desirable to examine the equipment during disassembly, washing and
sanitizing.
2.2.9 Determining the order of inspection with establishment representatives
The inspection team must make every effort to minimize the risk of cross-contamination.
The in-depth inspection usually must:
a)
b)
begin with the critical control factors preparing steps (e.g. packaging) and areas where major
problems were identified during the last inspection(s); and
finish with other areas, from the least contaminated to the most contaminated.
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2.2.10 Conducting the in-depth inspection
A basic set of rules is essential for carrying out an inspection at a food preparing establishment. When
these rules are followed, a meaningful inspection report will result, accurately reflecting the
conditions in the establishment.
a)
Before entering any preparing area, the inspection team must put on all necessary clean
protective clothing. As well, the inspectors must utilize hand washing/sanitizing facilities as
frequently as possible. The inspectors must also gather appropriate inspection aids, such as
clipboards, worksheets, flashlights, etc.
b)
All team members must write up their own worksheet and ratings.
c)
The inspection team must observe and record deficiencies as they are found and/or obtain
product samples as required. The team immediately brings deficiencies of a serious nature to
the attention of establishment management and ensures that corrective action is implemented.
When an establishment representative is present during an inspection, deficiencies are pointed
out to the representative as the inspection takes place. The deficiencies and corrective action
are documented and assessed even if they are addressed immediately.
d)
The inspection team must direct its questions to establishment management rather than to the
workers, except when the team wants to determine whether a worker understands what he or
she is doing or what procedures he or she has been directed to follow during regular
production or when there is a problem or deviation. If a worker gives problematic answers,
judgement must be exercised by assessing the background of the situation (e.g. potential
labour dispute).
e)
The inspection team must set a good example for workers (e.g. when a wash basin is present
in the inspection area, the team members must wash their hands).
f)
If possible, the inspection team must observe a major cleaning and sanitation before start-up
(pre-operation) or after shut-down (post-operation).
g)
If more than one shift is operating, the inspection team must try to observe the shift
change-over. The team must monitor the change-over operations, in comparison to normal
periods, between as many shifts as possible.
h)
In the storage, mixing and blending areas, the inspection team must make a note of all
ingredients, additives, and processing aids so they can be verified against the Maple Products
Regulations and the Food and Drug Regulations.
i)
In the labelling area(s), the inspection team must obtain a sample label of the product currently
being prepared. The team must review the label declarations while in the establishment and
attach the label to a worksheet so that it can be reviewed more closely back at the office. In
certain cases, a sample lithographed container or a document with the stamp that is applied
to the container must be obtained instead.
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j)
When in the boiler room, the inspection team must make a note of the boiler additives being
used, especially if live steam (direct contact) is being used on any product in the
establishment.
k)
During the inspection, the inspection team must locate the area where cleaning and
sanitizing chemicals are stored and note the cleaning compounds used so that they can be
reviewed against the establishment cleaning and sanitation program. It is recommended to
use products included on the CFIA’s Reference Listing of Accepted Construction
Materials, Packaging Materials and Non-Food Chemical Products (available on the CFIA
Web site) or otherwise recognized for food use (e.g., letter of guarantee, 3A standards, or
NSF), but it is not a registration requirement (not rated). These chemicals must be stored
centrally, away from the main traffic stream and from raw materials ingredients and
packaging materials. Other poisonous chemicals such as pesticides must be stored in a
separate area (preferably restricted) away from all cleaning chemicals and food products.
2.2.11 Recording observations on the worksheets during the inspection
The inspection results are recorded on the MCAP Inspection Worksheet. This a working
document in which the rating for each inspection task (principle statement) is recorded along with
a description of the deficiencies identified during the on-site inspection that were related to that
inspection task.
2.2.12 Collecting product samples during or after the in-depth or directed inspection
During or after an in-depth or directed inspection, product samples may be requested. The
inspection team must always notify establishment management of the exact nature of the samples
required and the purpose of sampling. The samples must be drawn randomly and according to the
sampling plans and the program directives. Wherever possible, the types of checks or analyses
carried out on those samples must reflect the deficiencies observed in the establishment.
2.2.13 Writing the inspection report
When the inspection is completely finished, the team of inspectors must meet behind closed doors
to discuss the inspection results. A suitable location is necessary to protect the confidentiality of
the information. For example, the meeting could be held in a meeting or training room with a door
that can be closed or in the establishment manager’s office. The meeting could also take place in a
nearby CFIA office.
All deficiencies found during the establishment inspection must be indicated in writing on the
worksheet. Together, the inspectors must review all the deficiencies and ratings recorded on their
worksheets and agree on a final rating for each task. They must then calculate the overall
establishment rating. It is important that establishment management understand the inspection
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findings and the reasons why certain items are unsatisfactory and require correction or
improvement.
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The manuals, legislation, regulations and guidelines identify some sanitation requirements and
references, and indicate some responsibilities, but many times a specific problem and the way to
address that problem are not specified. It is therefore necessary to exercise judgment and common
sense with respect to the health and safety implications of that situation within a specific context.
Inspection Report
It consists of:
•
the worksheet, that includes the non-compliances noted during the inspection;
•
the overall compliance percentage rating for the establishment (see Annex I, method for
calculating);
•
the sample covering letter (see Annex II, for the example)
2.2.14 Discussing the inspection results with establishment management
Closing Meeting
After the establishment inspection, the inspection team meets with the appropriate member(s) of
the establishment management team to review the inspection, highlight any unsatisfactory
conditions and discuss and decide on a time period or a date for the correction of unsatisfactory
conditions. The time and location must be carefully considered when discussing inspection
reports with plant management. Ample time must be set aside to discuss unsatisfactory
conditions. A quiet area, preferably within the establishment, would be an acceptable
environment for discussing the inspection results.
At the meeting with management, the senior inspector should take the lead, explaining the
purpose of the inspection, making the presentation as positive as possible, and giving the
establishment a third-party view of the status of the establishment and its operations from a
regulatory perspective. The session should begin with general remarks pointing out any positive
comments that are appropriate. The inspector explains that the report contains the infractions
observed during the inspection, while anything that was found to be satisfactory, good and in
compliance is not mentioned in the report. The inspector then presents the deficiencies recorded
in the inspection report. Finally, the inspector describes the follow-up action expected, which
constitutes the establishment’s action plan.
2.2.15 Discussing the action plan
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The inspector must plan the corrective action with front-line management so that the problems do
not recur. Each critical and major deficiency must be clearly identified with a correction date. The
action plan must include provisions for all deficiencies reported in the Inspection Report in
accordance with the time frames outlined in Table 1 in section 2.3 below. The urgency of
corrective action is always a function of the degree of existing hazard related to health and safety
issues. A responsible party from management must review, sign and keep a copy of the action
plan.
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2.2.16 Providing the inspection report and receiving the action plan
The inspector will leave a printed copy of the inspection report on site if the inspector carries a
laptop and printer. Otherwise, he will leave a hand-written copy with the operator and send a
complete printed report within 10 working days.
If the operator does not provide an action plan to the inspector on site, he must forward it as
requested in the sample covering letter (see Annex II). For professional reasons, we recommend
a written or verbal acknowledgment of receipt (with a note on file) be transmitted to the
establishment following reception of an acceptable action plan. The action plan must be kept on
the establishment's file.
The inspector will refuse an incomplete action plan and will request corrections. If the action plan
is not submitted within the appropriate time frame, the inspector should contact the responsible
person as a reminder. Further action, in consultation with the regional office, may be taken (see
Chapter 3).
The inspection team enters the Directed Inspection report into the MCAP database. A signed copy
of each report must be kept in the Region's file.
2.3
Compliance levels, action plan and corrective action
Table I
Category
Compliance Level
Action Plan Submission
Time Frame
Corrective Action
Time Frame
I
< 100%
Immediate *
Immediate *
II
$75%
Less than one month *
Less than two months * or
according to the action plan
< 75 %
Less than 2 weeks *
Less than one month *
$65%
Less than one month *
Less than one year * or
according to the action plan
< 65 %
Less than one month *
Less than one year *
III
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* After the closing meeting date of the inspection
An establishment meets the CFIA registration maple products program requirements when the
following overall rating is obtained : 100 % for category I, 75% or greater for category II, 65% or
greater for category III..
The ratings I, II and III used in the “Category” column of the above table is described in section
2.1.4 of this chapter.
The “Minimum Compliance” column is based on health risk and compliance with the legislation
and regulations. Adding up the ratings assigned to each of the tasks makes it possible to calculate
percentages that indicate an establishment’s compliance level. This calculation is explained in
Annex I to this chapter.
The “Action Plan Submission Time Frame” column indicates the time period given to the
establishment to submit its written corrective action plan.
The “Corrective Action Time Frame” column indicates the time frame given to the establishment
to take the corrective action.
2.3.1
Follow-up for Category I deficiencies
The compliance level required is 100%.
Compliance level less than 100%
CORRECTIVE ACTION TIME FRAME
When a Category I deficiency is identified during an inspection, the inspector must evaluate
product safety immediately and require the establishment to implement corrective action
immediately or as soon as possible, depending on the circumstances.
An inspection must be initiated, following the steps below.
–
Determine the potential cause of the deficiency.
–
Determine when the deficiency first appeared.
–
Evaluate the safety of the product.
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–
Determine appropriate corrective action and ensure it is implemented immediately, if
required.
–
Where an inspector believes on reasonable grounds that the Act or the regulations have been
contravened, the inspector may seize and detain any agricultural product or other thing by
means of or in relation to which the inspector believes on reasonable grounds the
contravention occurred; or that the inspector believes on reasonable grounds will afford
evidence in respect of a contravention of the Act or the regulations.
–
Recall should be considered if the products are on the retail market and if it poses a risk to
human health.
–
If the cause of the deficiency cannot be determined immediately or if product safety cannot be
evaluated, consider stopping production of the affected product until satisfactory corrective
action is established and implemented.
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ACTION PLAN SUBMISSION TIME FRAME
If corrective action is not required immediately, ensure that the establishment submits an action
plan in writing within 24 hours and implements corrective action. The corrective action must
meet the program requirements.
DIRECTED INSPECTION TIME FRAME
Further directed inspections, if required, will then be carried out to ensure that all deficiencies or
non-conformances are corrected. The procedures described in the program guidelines must be
used for follow-ups on seized and recalled products. If the establishment does not properly
implement its corrective action plan, the procedure indicated in section 3.7, Suspension of
Registration, must be followed.
2.3.2
Follow-up for Category II deficiencies
The compliance level required is 75% or more.
Compliance level equal to or greater than 75%
ACTION PLAN SUBMISSION TIME FRAME
The establishment must submit an action plan at the time of inspection or within a month of the
closing meeting date of the inspection (see section 2.2.16).
CORRECTIVE ACTION TIME FRAME
The establishment must implement corrective action within two months of the closing meeting
date of the inspection (as outlined in the above Table I) or within a longer delay in accordance
with the action plan, in such a way that the program requirements are met.
DIRECTED INSPECTION TIME FRAME
The decision to conduct a directed plant inspection for all Category II deficiencies is at the
inspector’s discretion (with the agreement of his or her supervisor).
Compliance level less than 75%
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ACTION PLAN SUBMISSION TIME FRAME
The establishment must submit an action plan at the time of inspection or within a month of the
closing meeting date of the inspection (see section 2.2.16).
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CORRECTIVE ACTION TIME FRAME
When an inspection reveals a compliance level of less than 75%, the inspector must immediately
evaluate product safety and require the establishment to take appropriate corrective action.
–
Nature of associated deficiencies having a cumulative effect on potential product safety/
contamination (e.g. calibration problems, equipment sanitation, equipment maintenance).
–
Actual Category II compliance level.
–
Overall situation, e.g. plant history, readiness to implement corrective action, Category III
deficiencies relating to Category II deficiencies.
DIRECTED INSPECTION TIME FRAME
A directed plant inspection must be performed for all Category II deficiencies within 30 days of
the closing meeting date of the inspection or in accordance with the date indicated in the action
plan. Follow-up could be a priority the following season for sugar bush establishments operating
late in the season.
If the establishment does not properly implement its corrective action plan, the inspector must
follow the guidelines in section 3.7, Suspension of Registration, or section 3.8, Cancellation of
Registration, as appropriate.
2.3.3
Follow-up for Category III deficiencies
The compliance level required is 65% or more.
Compliance level equal to or greater than 65%
CORRECTIVE ACTION TIME FRAME
The establishment must submit an action plan at the time of inspection or within a month of the
closing meeting date of the inspection (see section 2.2.16).
ACTION PLAN SUBMISSION TIME FRAME
The company must implement corrective action within a year of the closing meeting date of the
inspection (as outlined in the above Table I) or within a longer delay in accordance with the
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action plan, in such a way that the program requirements are met. Low-risk deficiencies may
require product assessment for quality or adulteration (refer to the Maple Products Inspection
Manual for procedures).
DIRECTED INSPECTION TIME FRAME
Category III deficiencies will be followed up through directed inspections at the inspector’s
discretion (with the agreement of his or her supervisor).
Compliance level less than 65%
CORRECTIVE ACTION TIME FRAME
The establishment must submit an action plan at the time of inspection or within a month of the
closing meeting date of the inspection (see section 2.2.16).
ACTION PLAN SUBMISSION TIME FRAME
The company must implement corrective action within a year of the closing meeting date of the
inspection (as outlined in the above Table I). Low-risk deficiencies may require product
assessment for quality or adulteration (refer to the Maple Products Inspection Manual for
procedures).
DIRECTED INSPECTION TIME FRAME
A directed plant inspection must be performed to determine compliance with the action plan
within a year of the closing meeting date of the inspection or in accordance with the date
indicated in the action plan. Follow-up could be a priority the following season for sugar bush
establishments operating late in the season.
If the establishment does not properly implement its corrective action plan, the inspector must
follow the guidelines in section 3.8, Cancellation of Registration.
2.3.4 Follow-up for Category II and III deficiencies
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If the plant does not achieve the compliance levels for both Category II (75%) and Category III
(65%), the inspector must follow the guidelines applicable to Category II deficiencies
(section 2.3.2) and to Category III deficiencies (section 2.3.3).
2.3.5 Critical health and safety implications
An unsatisfactory evaluation for any Risk Category I or II items or direct contamination of the
product can have health and safety implications. In such a situation, the establishment takes
immediately or promptly the necessary corrective action to isolate the affected products while the
problem is still present. If the establishment has not demonstrated to the inspector that the product
is under control or safe, an inspector may seize, any agricultural product or other thing by means
of or in relation to which the inspector believes on reasonable grounds that the Act or the
regulations have been contravened; or that the inspector believes on reasonable grounds will
afford evidence in respect of a contravention of the Act or the regulations. Laboratory analysis of
the affected lots may be necessary to determine the product’s safety.
If a product potentially poses a risk to human health and has been distributed, the inspector must
immediately contact his or her supervisor and provide the relevant details, in order to determine if
a product recall is necessary as per the recall protocol.
Seizure of the equipment must be considered and implemented if by means of or in relation to
which the inspector believes on reasonable grounds that the Act or the regulations have been
contravened; or that the inspector believes on reasonable grounds will afford evidence in respect
of a contravention of the Act or the regulations. Suspension of the establishment’s registration
must be considered and implemented if necessary (refer to Chapter 3 for more details).
2.3.6
Repetitive deficiencies
There may be occasions when an establishment repeatedly fails to submit its action plan or to
carry out the necessary corrective action. Depending on the circumstances, the inspector can
determine with his or her supervisor (in consultation with the programs) that the establishment
does not meet the minimum requirements of the program. For example, in the case of repetitive
Category III deficiencies, follow-up may not be necessary. If discussion and monitoring have not
enabled the establishment to achieve the desired compliance level, an Area meeting should be
arranged with the appropriate establishment manager to explain the deficiencies in detail and the
reasons why they must be corrected. The meeting should end with the development of a mutually
agreed upon action plan and a commitment for its implementation.
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If subsequent directed inspections do not indicate satisfactory corrective action and it is felt that
compliance will not be forthcoming, the procedure for suspending or cancelling registration must
be initiated in consultation with a program specialist (refer to Chapter 3 for more details).
2.4
Safe work practices during an establishment inspection
All inspection staff must be aware of the hazards present in their working environment.
Pre-operational checks of the work area are essential to identify unsafe conditions or situations. If
such conditions or situations are identified, they must be corrected before the inspection or testing
activities begin. The inspection staff should not begin work at third-party premises until unsafe
conditions and situations are corrected.
Safe work practices combined with on-the-job training will help reduce the risk of injury to
inspectors. The following safe work practices are to be observed when performing the inspection
or testing tasks outlined in this manual.
2.4.1 Manual material handling
At the establishment, inspectors must plan their visit and notify the operator, as explained in
section 2.2. They can ask to have an operator representative assigned to assist them at all times
while selecting samples as per subsection 21(3) of the Canada Agricultural Products Act.
The proper lifting techniques when loading and unloading samples are as follows:
–
Size up the load before lifting.
–
Ensure that the travel way is clear of obstructions.
–
Keep your feet at least a foot apart to provide a stable base.
–
With a straight back, bend your knees to lift the load.
–
Keep the load as close to your body as possible.
–
Turn by pivoting at the feet, not by twisting at the waist.
–
Use a dolly.
Below are more guidelines for manual material handling (Canadian Centre for Occupational
Health and Safety):
–
Plan your lift.
–
Reduce the size of the load.
–
Reduce the distance a load is carried.
–
Make multiple trips with smaller load sizes.
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–
Assign more people to lift extra heavy loads.
–
Use more than one person or a mechanical device to move the load.
Before beginning an inspection at a workstation in the establishment, inspectors must ensure that
the table height is adequate for performing the inspection, lighting is at least 540 lux and a chair is
available.
2.4.2 Moving vehicles
Inspectors must watch for all moving vehicles (tow motors, forklifts, trucks, etc.) while travelling
around and within the operator’s establishment. Designated walkways must be used when
possible. It is important to bear in mind that pedestrians do not necessarily have the right of way.
Inspectors must try to remain visible to vehicle operators and be aware of the dangers associated
with vehicle exhaust fumes.
2.4.3 Personal protective equipment
Inspectors must wear and be trained in the use, care and maintenance of personal protective
equipment, in accordance with their scales of entitlement.
Personal protective equipment requirements and safety measures are often recommended and
listed on products or substances encountered in the workplace. The Workplace Hazardous
Materials Information System (WHMIS) is a nationwide system designed to provide information
on hazardous materials used in the workplace. There are three key elements to WHMIS: labels,
material safety data sheets (MSDS) and worker education. The WHMIS label and, in its absence,
the product label are sources of information on the relative toxicity (flammability, corrosivity,
etc.) of a substance, the first-aid measures that should be taken if and when exposure does occur,
recommended personal protective equipment that should be worn and a referral to the product
MSDS. A system of symbols and risk phrases indicates the toxicity of the substance. The MSDS
has more specific information about the product or substance and should be consulted if it is
available at the site. Under the Protective Clothing heading, section 2.2.7 contains a list of the
items that should be included as personal protective equipment.
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2.4.4 Slip and fall prevention
The risk of slipping, tripping and falling can be reduced by:
–
wearing CSA- approved protective footwear;
–
keeping footwear tread in good condition, replacing at 30% wear;
–
practising good housekeeping;
–
keeping work areas and walkways free from debris; and
–
following safe work practices.
2.4.5 Establishment premises hazards
During product sampling, inspectors must be aware of environmental conditions and any
structural concerns (e.g. unprotected transit holes in warehouses) and must inform the
manager/supervisor on duty of any hazards.
2.4.6 Climbing
Inspectors must not climb up on skids, equipment or materials or stand on platforms being hoisted
by a lift truck or on the lift truck forks. They must ask the establishment for assistance to obtain
samples or items beyond their reach.
2.4.7 Emergency procedures
Inspectors must be familiar with the emergency procedures of the establishment they are working
in. They must also:
–
know the emergency plan of the work site they are at;
–
if such a plan does not exist, ensure that they have their own plan of escape if an
emergency occurs;
–
be aware of the emergency exits in their immediate work area (these exits must remain
unlocked and unobstructed); and
–
refer to appropriate material safety data sheets when dealing with chemical hazards.
2.4.8 Right to refuse
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Inspectors always have the right to refuse to perform an inspection for occupational safety and
health reasons. If they have doubts about they safety or a co-worker’s safety, they must notify
their supervisor and identify the safety issue. The safety issue must be addressed and resolved
before inspectors can begin work.
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ANNEX I - METHOD FOR CALCULATING COMPLIANCE PERCENTAGES (OVERALL
RATING)
Method for Calculating the Overall Compliance Rating
The overall establishment rating is based on the calculation of the percentage of satisfactory tasks
for each of Categories I, II and III. The calculation is performed using the Chapters 4 and 5
calculation tables and the overall compliance table that follows the inspection report.
Calculation of compliance for each of Chapters 4 and 5
CALCULATION TABLE
For each of chapters 4 and 5
Tasks
Category I
Category II
Category III
Unsatisfactory
AI
A II
A III
To Be Rated minus (N/A + N/I)
BI
B II
B III
1.
For Category I, in cell A I, add the total number of unsatisfactory Category I tasks from
Chapter 4 (according to the inspection report) and write the result in A I.
Formula:
2.
Total Unsatisfactory Cat I = A I
For Category I, in cell B I , add the total number of tasks that could be rated Category I.
Then subtract from this total the number of tasks that could be rated Category I but were
not inspected (N/I) and not applicable (N/A). Write the result in BI.
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Formula:
3.
To Be Rated Cat I minus (N/A Cat I + N/I Cat I) = B I
Repeat operations 1 and 2 above for Categories II and III for each of Chapters 4 and 5, and
write the results in the cells A II, A III, B II and B III.
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Calculation of overall compliance rating
OVERALL COMPLIANCE CALCULATION TABLE
Chapters 4 and 5 combined
Establishment Name:
Tasks
Registration No.:
Category I
Category II
Total unsatisfactory
CI
C II
C III
Total to be rated
DI
D II
D III
Compliance % = (D ! C) / D x 100
EI
E II
E III
4.
For Category I, in cell C I, add the Category I unsatisfactory tasks from Chapters 4 and 5.
Write the result in C I.
Formula:
5.
Category III
A I (Chap 4) + A I (Chap 5) = C I
For Category I, in cell D I, add the total number of tasks that could be rated Category I
from Chapters 4 and 5. Write the result in D I.
Formula:
B I (Chap 4) + B I (Chap 5) = D I
6.
Repeat operations 4 and 5 for the Category II and III tasks respectively, and write the
results in the other cells C II, C III, D II and D III.
7.
To determine the overall compliance % for Category I, perform the following
calculation:
(Total Number of Tasks to Be Rated Cat I minus Total Number of Tasks Rated
Category I) ÷ Total Number of Tasks to Be Rated Cat I x 100. Write the result in E I.
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Formula:
(D I ! C I) x 100 = E I
DI
8.
Repeat operation 7 for Categories II and III respectively. Write the results in E II and E III.
9.
The overall establishment rating is E I, E II and E III.
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ANNEX II - SAMPLE COVERING LETTER
Canadian Food Inspection Agency
[DATE]
[NAME OF ESTABLISHMENT DIRECTOR]
[NAME AND ADDRESS OF ESTABLISHMENT]
Dear Sir/Madam:
Subject: Establishment inspection results
Please find enclosed the report on the in-depth inspection of your establishment that [INSPECTOR’S
NAME] and I conducted on [DATE]. During the exit interview at your establishment, all deficient
items observed during the inspection were discussed with you and your staff.
Deficient items in Health and Safety categories have resulted in ratings of ___% in Category I,
____% in Category II and ___% in Category III. You are reminded of sections 6 to 6.2 and/or 7 of
the Maple Products Regulations under the Canada Agricultural Products Act. [IF NECESSARY,
IDENTIFY THE CRITICAL DEFICIENCIES AND REFER TO THE APPROPRIATE SECTION OF THE
REGULATIONS.]
Attached to the report is a follow-up worksheet that may be used to indicate the dates on which
corrective action will be implemented to address those items found unsatisfactory. Please forward
your written and signed action plan to this office no later than [DATE: NOT MORE THAN ONE
MONTH AFTER THE DATE OF THE INSPECTION] .
We would like to thank you and your staff for your cooperation during the inspection. Please do not
hesitate to contact me if you have any questions.
Yours truly,
[INSPECTOR’S NAME]
Processed Products Inspector
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c.c.:
[PROGRAM SPECIALIST, REGIONAL OFFICER, SUPERVISOR AND/OR OTHERS AS
APPROPRIATE]
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ANNEX III - HEALTH CANADA RISK ASSESSMENT MODEL
I.
Risk Assessment
The rating guide examples are intended to guide inspectors in assessing risk. The Health Risk
Assessment Model may be used by the inspector when a more detailed assessment is required.
The Health Risk Assessment Model (Figure 1) was developed using the risk assessment principles
outlined in the Health Protection Branch document entitled Health Issues: Risk Assessment, dated
October 1, 1993. It is the basis for assessment of all health and safety risks in this standard.
The model uses likelihood of occurrence and severity of consequences to determine the rating for all
deficiencies that have an impact on health and safety. The severity of consequences for a particular
concern is fixed (i.e. subclinical, temporary or permanent disability, death), whereas the likelihood
of occurrence varies with the degree of control exercised by the operator.
Population at risk and level of risk were not included in the model because they had little impact at
the section level except where sensitive populations are involved. Sensitive populations include
infants, the elderly, the immunocompromised and individuals consuming the product as a sole source
of nutrition.
Health Risk Assessment Model (Figure 1)
Likelihood of
Occurrence
Sa =
Satisfactory
High
Sa*
III
II
I
Medium
Sa
III
II
II
Low
Sa
III
III
III
Remote
Sa
Sa
Sa
Sa
Low
Medium
High
Severity of Consequences
Likelihood of occurrence relates to the level of control the establishment exercises to eliminate the
hazard that would exist if the principle statement were not adhered to. For example:
Remote -
The operator has well-established control measures.
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Low -
The operator has well-established control measures but commits minor infractions.
Medium -
The operator has control measures but they contain gaps or inconsistencies, and the
operator commits minor and major infractions.
High -
The operator has little or no control and commits major and critical infractions.
Severity of consequences relates to the type of hazard that would result if a particular principle
statement were not adhered to. The hazard could be a physical, chemical, or microbiological
contamination hazard resulting in health problems or serious illness, which would have very severe
consequences. The hazard could also be a physical, chemical, or microbiological contamination
hazard resulting in very minor or no consequences.
II.
Types of concerns or hazards
In general, concerns associated with a deficiency can be classified as:
-
health risks
-
potential contamination with aesthetically objectionable material
-
regulatory infractions resulting in adulteration to the consumer
-
regulatory infractions resulting in potential trade problems
The above concerns fall into three broad categories: biological, chemical, physical, and regulatory.
1. Biological hazards
Biological hazards are caused by spoilage or pathogenic microorganisms.
C
Moulds and yeasts
The terms “mould” and “yeast” are defined in the glossary at the beginning of Chapter 1 of this
manual. Moulds and yeasts can grow and spoil maple syrup, particularly if good manufacturing
practices are not followed. Some examples of those practices are:
- minimum sugar concentration of 66E Brix
- complete and hot fill
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- container or barrel type
- container or barrel cleanliness
- maintenance of container or barrel airtightness following filling
- storage time and conditions
a) Mycotoxins
Some moulds can produce mycotoxins. Given that maple syrup consumption is very limited and that
the growth of moulds results in a very unpleasant taste, it would appear unlikely that mycotoxins in
maple syrup pose any real health hazard over the short or long term. However, no studies have been
carried out along these lines and no cases have been documented. Mycotoxins are primarily
associated with grain products.
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b) Yeasts
In maple products, spoilage is caused mainly by Saccharomyces, a yeast that is responsible for
fermentation. Fermentation is a factor that affects the taste and organoleptic properties of the syrup.
The term “fermentation” is defined in the glossary at the beginning of Chapter 1 of this manual.
C
Pathogenic bacteria
The water activity (Aw) of maple syrup is about 0.87–0.88. This allows little possibility for
development of pathogenic bacteria, which require Aw values exceeding 0.90.
a) Botulism
Cases of infant botulism involving corn syrup and honey have been documented, but none have been
documented involving maple syrup products. The spores of Clostridium botulinum can survive
boiling for several hours but do not easily develop at Aw values below 0.93. The Aw of maple syrup
is about 0.87–0.88.
b) Staphylococci
No cases of poisoning by the Staphylococcus aureus enterotoxin have been documented in maple
syrup products, although this microorganism can produce enterotoxin at Aw values as low as 0.86.
That means that it could be it possible for the bacterium to develop in maple syrup, the Aw of which
is 0.87–0.88. However, maple syrup is a nutritive medium that is not very conducive to the growth
of this bacterium. Maple syrup consists mainly of sucrose and contains very few nitrogen compounds,
and staphylococci are more tolerant to salt than sugar. In addition, maple products are prepared in
a process involving high temperatures capable of destroying the microorganism.
c) Stringy syrup
A bacterium called Aerobacter aerogenes can spoil maple syrup by polymerizing the sugars it
contains. This bacterium causes the syrup to form strings and become gelatinous. The bacterium
develops optimally under certain conditions, including:
-
a solution that has a sugar concentration below 25% (such as maple sap)
-
a solution that is kept at temperatures between 24EC and 32EC for an extended time
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In maple syrup production, such conditions can develop during hot spring days, when the sap is left
for too long in the following places:
-
poorly sanitized tubing
-
an unrefrigerated tank
-
the evaporator, before the start of evaporation
2. Chemical Hazards
Chemical residue concentration must also be taken into account in the case of maple syrup. Maple
sap is concentrated at a volume ratio of 40 to 1 during the maple syrup production preparation.
Lead is known to be a source of maple product contamination. It comes from the use of old
equipment made of unsuitable materials. Chemical hazards related to undesirable effects, such as
lead, may be assigned a medium or high severity of consequences. However, modern equipment is
largely made of stainless steel, which limits contamination.
In addition, proper rinsing of equipment and pipelines after cleaning and sanitation is important to
ensure the purity of maple products.
3. Contamination
Contamination refers to the introduction or occurrence of objectionable material in a food or food
environment. Contamination risks are assigned Category I, II or III, depending on the likelihood of
occurrence.
The types of contamination that have an impact on health and safety are rated as health risks. An
example is a physical hazard, such as contamination with glass. The health risk could belong to
Category I, II or III, depending on the severity or nature of the hazard and the likelihood of
occurrence.
4. Regulatory
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Regulatory violations include deficiencies that contravene the legislation but that are not necessarily
associated with a health or contamination risk. Multiple repetitive regulatory violations may be
considered a medium level of concern (i.e. Category II), reflective of the degree of control.
The principle statements for each of the tasks are the focus of the inspection report. Focussing on
these principles instead of specific deficiencies means that the full impact of all risks related to a
given concern can be assessed.
Chapter 2 - Maple Products Establishment Inspection Manual - January 2007 - Revised May 2013 for external Web publication
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