CHAPTER 2 - SAMPLING
Honey - Product Inspection Manual
Table of Contents
2.1
Objectives ...................................................................................................................................... 3
2.2
Scope ............................................................................................................................................. 3
2.3
Legislative Authority to Take Samples .......................................................................................... 3
2.4
References, Forms and Equipment ............................................................................................... 4
2.4.1
2.4.2
2.4.3
2.5
References ........................................................................................................................... 4
Forms ................................................................................................................................... 5
Equipment ............................................................................................................................ 5
Sampling Procedures .................................................................................................................... 5
2.5.1
Prepare for Sampling ........................................................................................................... 6
2.5.2
Select a Product to Sample .................................................................................................. 6
2.5.3
Define the Lot from Which to Draw the Samples ................................................................. 7
2.5.4
Determine the Number of Sample Units and Sizes Required .............................................. 7
2.5.5
Select Samples Randomly ................................................................................................... 8
2.5.6
Collect the Samples ............................................................................................................. 9
2.5.6.1
Bulk Honey Sampling Techniques ................................................................................... 9
2.5.6.1.1
Liquid Honey............................................................................................................ 9
2.5.6.1.2
Granulated Honey ................................................................................................... 9
2.5.6.2
Prepackaged Honey Sampling ........................................................................................ 9
2.5.7
Inspection Report ................................................................................................................. 9
2.6
Laboratory Sampling Modes .......................................................................................................... 10
2.6.1
2.6.2
2.6.3
2.6.4
2.7
Monitoring Sampling ............................................................................................................. 10
Directed Sampling ................................................................................................................ 10
Compliance Sampling .......................................................................................................... 11
Other Types of Sampling – Legal, Special or Pilot Survey .................................................. 11
Laboratory Sampling Activities and Regulatory Requirements ..................................................... 11
2.7.1
2.7.2
2.7.3
2.7.4
2.7.5
2.8
Use of Accredited Laboratories ............................................................................................ 11
Chemical Residues .............................................................................................................. 12
Composition.......................................................................................................................... 13
Microbiology ......................................................................................................................... 13
Harmful Extraneous Material ................................................................................................ 13
Laboratory Sample Submission Procedures ................................................................................. 13
2.8.1
2.8.2
2.8.3
Identify the Samples for Laboratory Analysis ....................................................................... 13
Complete the Food Product Sample Submission Form ....................................................... 14
Ship the Samples ................................................................................................................. 14
2.9
Laboratory Sample Result Assessment ........................................................................................ 15
2.10
Follow-up to Laboratory Sample Results ...................................................................................... 15
2.10.1
Satisfactory Results .............................................................................................................. 15
2.10.2
Investigative Results ............................................................................................................ 15
2.10.3
Unsatisfactory Results .......................................................................................................... 16
2.10.3.1
Unsatisfactory Monitoring Results ............................................................................... 16
2.10.3.2
Unsatisfactory Directed Results .................................................................................. 16
2.10.3.3
Product Disposition ...................................................................................................... 18
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List of Tables
Table 2.1 Product Dispositions ................................................................................................................. 18
Appendices
The following documents are intended for internal use. CFIA staff can access these documents using the
internal tools noted below.
Appendix 2.1A: Supplementary Guide for Chemical Residues in Honey [RDIMS # 2055039]
Appendix 2.1B: Specifications for Laboratory Testing of Honey [RDIMS #2075254]
Appendix 2.2 LSTS Food Product Sampling Submission Form
Appendix 2.3 Template Letters for Laboratory Results
Satisfactory Results [RDIMS # 2053376]
Unsatisfactory NCRMP Results [RDIMS #2053610]
Unsatisfactory CFIA Results [RDIMS #2053687]
Investigative Results - Domestic Producer with Honey within WRL [RDIMS #2054458]
Investigative Results - Domestic Packer/Pasteurizer with Honey within WRL [RDIMS #2054804]
Investigative Results - Importer with Honey within WRLs [RDIMS #2056364]
Repeat Investigative Results within WRLs - Example for Domestic Producer [RDIMS #2056453]
Unsatisfactory Results - Fumagillin [RDIMS #3224371]
Appendix 2.4 Procedure to Evaluate Corrective Action Plans (CAP) [RDIMS #1564862]
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2.1
Honey - Product Inspection Manual
Objectives
This chapter will provide Honey Program inspectors with the following:
2.2

An understanding of the types and purpose of sampling activities conducted within
the program.

Guidance on how to select and collect honey samples for inspection activities and
laboratory analysis.

Skills to help you verify the honey industry's compliance to the regulatory
requirements.
Scope
The Honey Program assesses the potential food safety and economic risks in domestic and
imported honey through inspection and sampling activities. The major risks associated with honey
are the presence of chemical residues, in particular veterinary drugs and adulteration with foreign
sugars. Other reasons for sampling honey are to verify its compositional standards, declared
grade and net quantity. Sampling may also be conducted to investigate complaints and as a
follow-up to unsatisfactory lab results, previous recalls or suspected problems that may have
become evident during a routine inspection.
Honey products such as comb honey and flavoured honey are not inspected and sampled by the
Honey Program unless a particular concern has been identified, as they are only regulated under
the Food and Drug Regulation (FDR) and not the Honey Regulations (HR).
The sampling procedures apply to products regulated by the HR sampled at federally registered
establishments (packers, pasteurizers and producer-graders) and importers according to the
frequencies outlined annually in the:

Honey Inspection Program Activities and Frequencies - National Standard Work
Plan [RDIMS # 2232734]

Honey Inspection Program - Sampling Plans and Guidelines [RDIMS # 1712580]
Honey non-compliant with the regulations is not eligible for sampling. Only once the
regulated party provides an acceptable written corrective action plan that includes a
draft label or corrects the non-compliance, the honey becomes eligible for sampling.
The ultimate goal is to sample honey that is believed to be compliant to the
requirements and destined for the Canadian market.
2.3
Legislative Authority to Take Samples
Section 21 (1) (b) of the Canada Agricultural Products Act provides the authority for an inspector
to take samples free of charge:
"21 (1) For the purpose of ensuring compliance with this Act and the regulations, an inspector
may, subject to section 22, enter and inspect any place, or stop any vehicle, in which the
inspector believes on reasonable grounds there is any agricultural product or other thing in
respect of which this Act or the regulations apply, and the inspector may:
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a) open any container that the inspector believes on reasonable grounds contains an agricultural
product;
b) inspect any agricultural product or other thing and take samples of it free of charge; and
c) require any person to produce for inspection or copying, in whole or in part, any record or other
document that the inspector believes on reasonable grounds contains any information relevant to
the administration of this Act or the regulations."
Honey samples must only be collected by those individuals who are designated
as an inspector under the Canada Agricultural Products Act (CAPA).
2.4
2.4.1
References, Forms and Equipment
References
a) Acts and Regulations

Honey Regulations (HR)

Canada Agricultural Products Act (CAPA)

Food and Drugs Act (FDA)

Food and Drug Regulations (FDR)
b) Honey Program References

Honey Inspection Program - Sampling Plans and Guidelines [RDIMS # 1712580]

Honey Inspection Program Activities and Frequencies - National Standard Work
Plan [RDIMS # 2232734]

Working Residue Levels (WRL) in Honey - CFIA's Questions and Answers
c) Other References

CFIA National Chemical Residue Monitoring Program (NCRMP)

CFIA-HC Food Sampling and Testing Terminology

Chemical Residues In Food

Codex Standard for Honey CODEX STAN 12

Health Canada’s Guidelines for the General Cleanliness of Foods

Health Canada's List of MRLs for Pesticides

Health Canada's Working Residue Levels (WRL) for Antimicrobial Residues in
Honey

Health Canada’s WRL Table

Issues Management System User Manual [RDIMS #1599661]

LSTS AgriFood / Consumer Protection / Food Safety Training Guide [RDIMS
#2291552]

LSTS User Services Guide [RDIMS #1857345]

Pest Management Regulatory Agency (PMRA)

Standards Council of Canada (SCC)
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
2.4.2
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Canadian Association for Laboratory Accreditation (CALA)
Forms
The following CFIA/ACIA forms and reports are required for sampling and most are available on
the internal Forms Catalogue (This document is intended for internal use). CFIA/ACIA Forms
used in the Honey Program.
2.4.3

Receipt for Samples Taken (CFIA/ACIA 4168)

Inspection Report (CFIA/ACIA 0992)

Laboratory Sample Tracking System (LSTS) Food Products Submission Form
Equipment
The equipment listed below is required for honey sampling:

sampling containers (e.g., plastic jars or tubs) that are clean, dry, inert and leak
proof;

sample numbers as provided by the area honey specialist - monitoring samples
numbers are provided annually and directed sample numbers as required;

stainless steel sampling tools (e.g., trier, long handled ladle, scoop, spoon, knives,
spatula, scraper);

clean white laboratory coat and hairnet;

disposable gloves (optional);

lint-free wipes;

sampling labels or permanent marker;

tape yellow - official seal (CFIA/ACIA 4561);

label - official seal (CFIA/ACIA 5112);

packing tape, packing material (bubble wrap, shredded paper);

shipping boxes/containers.
Please also refer to Chapter 1 Section 1.5.3 [RDIMS #2006991] for a listing of other equipment
that may be required and Appendix 1.1 Occupational Safe Work Practices, which provides a
listing of personal protective equipment.
2.5
Sampling Procedures
Whether samples are gathered for laboratory analysis or for other product inspection activities
(e.g., grade), sampling procedures or steps outlined in this section should be followed.
The results will be used to determine compliance with the Honey Regulations and any
other applicable legislation. Therefore, appropriate measures must be taken to prevent
contamination of the samples during handling, storage and transport to the laboratory, if
applicable. If samples are improperly collected or mishandled, or are not representative of
the sampled lot, the laboratory results may be inaccurate and inconclusive.
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2.5.1
Honey - Product Inspection Manual
Prepare for Sampling
The following in-office sampling preparations are to be performed:
2.5.2

Review the company's file described in Chapter 1 Section 1.7.2 [RDIMS #2006991]

Review annual work plans in order to be prepared for the types of product sampling
and other inspection activities.

Have a series of laboratory sample numbers, labels and writing tools.

Have appropriate supplies/equipment to clean sampling utensils in between
samples.

Have a clean white laboratory coat and appropriate hair covering (e.g., hairnet).

Bring Inspection Report (CFIA/ACIA 0992), Receipt for Samples Taken (CFIA/ACIA
4168), Inspector ID card/badge and Detention Book.
Select a Product to Sample
Choose products for sampling based on the:

criteria outlined in the annual Sampling Plans and Guidelines, and
 product inspection frequencies outlined in the annual National Standard Work Plan.
However, also consider the following factors:

compliance history of the product, country, establishment (registered establishment,
importer or exporter);

lot size;

availability of the lot;

import arrivals (on a regular basis, refer to the Import Retrieval System (IRS) and/or
the Import Control Tracking System (ICTS));

type of honey (e.g., new product or country of origin; different grades, floral sources,
container sizes);

date the product was last sampled at the premises; and

any other circumstance the inspector may be aware of.
Note: that it is recommended to take several samples per visit, especially at regulated
parties with large volumes.
For monitoring sampling, always choose products where there is no suspicion of noncompliance.
For directed sampling, choose targeted, suspect or specific products based on identified
problem(s). For example, during an in-depth inspection, a non-approved antibiotic is
observed in the establishment. In such a case, a directed sample should be taken and
analyzed for all veterinary drugs instead of taking a routine monitoring sample.
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2.5.3
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Define the Lot from Which to Draw the Samples
The Honey Regulations (HR) defines a lot as follows:
A lot is “a uniform blend of honey in a batch or in a storage tank from which honey is
drawn for processing or grading.”
A “lot” is also referred to as a "production lot". It implies that each unit in the lot comes from the
same blend of honey and is processed under essentially the same conditions. Therefore, each
unit has the same lot number or production code.
Lots are typically differentiated by logical breaks in production (e.g., different source of honey,
new storage tank), but should be no longer than one day’s production. Keep in mind though, that
smaller lot sizes may minimize the amount of product rejected when there are unsatisfactory test
results.
Note: that honey with the same lot number but packed in different container sizes are
still considered to be from the same lot and only one container size is to be sampled.
A shipping lot, on the other hand, may be comprised of more than one "lot number" or "production
code" and is therefore not considered to be uniform blend of honey. In these cases, it is important
to identify the production lots for sampling purposes.
The annual Sampling Plans and Guidelines [RDIMS #1712580] prescribe the number of lots to be
sampled. Each lot should be sampled separately and be prepared for sampling in such a way that
the sample(s) can be taken without hindrance. If a portion of the lot has already been distributed,
the remaining quantity of the lot is to be considered the sampling lot.
It is recommended to sample various lots per visit especially at large packers or
importers.
The HR section 36.(1)(f) requires the lot number to be identified on every package and bulk
container. However, if a lot number is not available on the containers, then the entire shipment or
part thereof, identified by the regulated party will be considered as the sampling lot(s).
Inspectors may need to educate the regulated party on lot identification to ensure that
subsequent shipments have each container properly labelled including the actual lot number.
It is the registered establishment’s or importer’s responsibility to demonstrate to the
inspector that the identified lot number refers to a unique production code or uniform
blend of honey. The best way to achieve this is to obtain the meaning of the lot number
from the regulated party.
2.5.4
Determine the Number of Sample Units and Sizes Required
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A sample is a quantity of honey taken from a lot and intended for analysis. The size of the sample
depends on the tests to be carried out. A sample may consist of one or more sample units.
Consult the annual Sampling Plans and Guidelines as it outlines the sample size required for the
various laboratory analyses. The following numbers of units usually apply:
Monitoring samples usually require 1 sample unit / lot.
Directed samples usually require 6 representative sample units across the lot.
 If the lot number refers to a unique production code, the 6 units are to be submitted
to the lab using one sample number. Indicate on the sample submission form that the
six individual units should be combined. The laboratory will composite the samples
for testing and retains them in case the result is suspicious and individual analysis is
required.
 For prepackaged honey labelled with a common lot number it can be
assumed that the lot number represents a unique production code and thus, it
can be submitted using one sample number.
 For bulk honey the meaning of the lot number should be known to ensure that it
represents a production code.
 If the lot number does not represent one production code or a lot number is not
available, then the 6 samples are to be submitted individually using 6 different
sample numbers.
If the container sizes available for sampling differ from the sample size required, adjust
the number of sample units accordingly.
For example, if the required sample size is 1 unit (500 g) but only 250 g containers are
available; two containers will be required from the same lot to meet the 500 g sample
size requirement. Conversely, if only larger containers are available, the entire
container can be sampled or a 500 g sample can be drawn by following the procedures
outlined for bulk containers under Section 2.7.6.1 Bulk Honey Sampling Techniques.
However, if the required sample size is 6 units x 250 g but only 500 g containers are
available, 6 units must still be taken.
For information on the number of sample units and size for other product inspection activities,
refer to the respective chapter.
2.5.5
Select Samples Randomly
To randomly select samples, each unit (container/package) in the lot has to have an equal
chance of being selected, thereby excluding bias. The inspector must select the samples as
randomly as possible within the lot, given the constraints of working in a production facility or
warehouse environment.
A true random selection of pallets, cases and/or individual packages can be achieved by using a
random sampling technique. A numbering system in combination with a random number
generator is one of several methods that can be used to ensure randomness. Please see section
2.4.5 of the Processed Products - Product Inspection Manual Chapter 2 for more information.
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2.5.6
Honey - Product Inspection Manual
Collect the Samples
When sampling products, request that a representative from the establishment assists you in
retrieving bulk containers/skids of honey in the warehouse and in opening/closing the barrels
/totes as required. Take all necessary steps to avoid product contamination.
2.5.6.1 Bulk Honey Sampling Techniques
The following procedures are to be followed when sampling bulk honey:

Wipe the top of the bulk honey barrels/totes/pails before opening. Care should be
taken when removing lids and/or plastic liners from bulk honey containers so as not
to contaminate the product.

Remove any debris (e.g., foam, wax, bee parts) from the immediate sampling. If
harmful extraneous material is found, detain product and contact your area honey
specialist.

Sample from below the surface and away from the side of the container to ensure
the sampling tool (e.g., trier) does not damage the container, and that the sample is
representative.

Take the sample about 15 cm (6 inches) from the side of the container and
approximately 15 cm (6 inches) deep, when possible.

Seal and label each sample unit with the lot code and the sample number.
2.5.6.1.1 Liquid Honey

Use a tool such as a long handled ladel for sampling;

Scoop up an appropriate amount of honey indicated in the sampling plan, into the
sampling container(s).
Samples may also be taken directly from the honey storage tanks, in which case this
should be indicated on the Sample Submission Form. Additionally, this information
should be reported on the Inspection Report (CFIA/ACIA 0992).
2.5.6.1.2
Granulated Honey

Remove foam and wax from the sampling surface.

Use a sampling tool such as a trier to sample the product.

Insert the trier into the honey at a slight angle with steady and firm pressure until it is
submerged about half way.

Remove and scrape the honey with a spoon or knife from the trier into the sampling
container.
2.5.6.2 Prepackaged Honey Sampling
2.5.7

Ensure that the selected containers are sound and not leaking.

Clearly and permanently mark each sample unit with the lot code and sample
number.
Inspection Report
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Summarize the inspection results on the Inspection Report (CFIA/ACIA 0992) and indicate which
products and quantity were sampled for the various sampling activities. Leave a copy with the
company’s representative. A Receipt for Samples Taken (CFIA/ACIA 4168) can also be provided
if requested by the regulated party.
2.6
Laboratory Sampling Modes
Each year the CFIA develops national laboratory sampling plans for chemical, microbiological
and compositional analyses of both domestic and imported honey. To sample honey for these
different analyses, three different types of sampling modes are used: monitoring, directed and
compliance.
2.6.1
Monitoring Sampling
Monitoring is an unbiased sampling, where samples are taken at unannounced visits. The lots are
randomly selected from predefined normal-appearing populations (populations where there is no
suspicion of non-compliance). Monitoring sampling is conducted to:

assess human dietary exposure;

perform risk assessments;

monitor trends;

set standards and guidelines;

respond to international commitments;

identify potential problems and at-risk population groups for directed sampling
activities; and

evaluate the effectiveness of food safety programs.
The sampled lots are not held and the products are usually available to consumers before the
laboratory results are known to the CFIA. When monitoring samples are found to be in violation of
established limits, the issue is investigated and the honey may be subjected to further (directed)
sampling.
Monitoring is unbiased or random sampling designed to gather data.
2.6.2
Directed Sampling
Directed sampling is biased as it targets specific populations (e.g., honey lots of specific
geographical areas). Its purpose is to investigate and verify any suspected problems that may be
a potential health risk or economic fraud suggested in the monitoring program or from any other
sources (e.g., complaints, other government bodies).

Directed sampling is investigative in nature and triggers further inspection activities
in order to determine root causes of the problem.

If warranted, the product is detained until test results indicate the appropriate course
of action to take.

The requested analysis is specific to the concern in question.

The turn around time for the laboratory test results is faster than for monitoring.
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The results are always communicated to the regulated party.
Directed sampling is biased, investigative in nature and usually leads to product
detention. Education is an important element in correcting identified problems.
2.6.3
Compliance Sampling
Compliance sampling is directed at specific samples suspected of not complying with regulations
and guidelines governing the sale and distribution of honey products. The product is detained
until the laboratory test results are available and the appropriate course of action is determined.
The approach to compliance testing is referred to as in-depth sampling and follows Codex
Alimentarious (latin for “food code”) specifications. The establishment of a chain of custody of the
sample is essential if legal proceedings are expected to ensue.
Compliance sampling and testing is a regulatory control measure to prevent the
marketing or the removal from a market, a product known to be contaminated or
adulterated.
2.6.4
Other Types of Sampling – Legal, Special or Pilot Survey
Legal sampling, often referred to as official sampling, is undertaken for specific conditions where
legal action is the anticipated follow-up action. Legal advice should be sought prior to initiating
this type of sampling, and it is essential to establish a chain of custody for the sample. Other
information and criteria are demanded during the collection, submission and laboratory testing of
legal samples. Contact your area Enforcement and Investigation Services (EIS) officer for the
correct procedures to follow when legal action is anticipated.
Special or pilot surveys are information gathering studies that do not meet the criteria of the
other types of sampling methods discussed above in that they are usually limited in scope and
duration. Additionally, special or pilot surveys are sometimes conducted to gather information
related to improving sample testing and/or collection methods, and operational activities
(information on time, costs, or sample size estimates).
2.7
Laboratory Sampling Activities and Regulatory Requirements
Both industry and the CFIA play an important role in preventing harmful substances (chemicals
and micro-organisms) from entering the food chain, and for ensuring these products are
compliant with the regulatory requirements. This section briefly covers the role of industry, the
Honey Program’s laboratory sampling activities and the regulatory requirements. For other
product inspection activities refer to their respective chapters for regulatory requirements.
2.7.1
Use of Accredited Laboratories
As stated in Chapter 1 of this manual, it is the responsibility of the regulated party to
ensure that all of the products they market are safe and meet the appropriate
regulations.
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As part of good manufacturing and importing practices for food, manufacturers and importers are
encouraged to implement a quality assurance program to help them ensure the products comply
with the Canadian regulatory requirements.
For laboratory testing, the CFIA recommends using laboratories accredited by the Standards
Council of Canada (SCC), Canadian Association for Laboratory Accrediation (CALA) or to
ISO/IEC 17025, General Requirements for the Competence of Testing and Calibration
Laboratories. The following factors must also be taken into consideration when selecting a
laboratory:
 that the analytical method applies to honey and is included in the laboratory's current
scope of accreditation; and
 the scope of the analytical method is at least equivalent to the CFIA’s current method.
Scopes of accredited laboratories showing test names, matrices and methods of analysis may be
found on the SCC or CALA websites. To assist in the determination of equivalent methods,
Appendix 2.1B Specifications for laboratory testing of honey [RDIMS #2075254] lists the
minimum testing specifications for the most common analysis carried out on honey by the CFIA.
2.7.2
Chemical Residues
The CFIA monitors the presence of chemical residues under the National Chemical Residue
Monitoring Program (NCRMP). The NCRMP is managed by the Chemical Evaluation Section and
supports Canada’s international agreements and obligations. It also assists the Honey Program in
the recognition of trends and the identification of potential problem areas that may require
directed and compliance activities. See the Chemical Residues in Food for more information.
As part of the CFIA’s NCRMP, honey is monitored for the presence of chemicals from an
extensive list of:

veterinary drugs;

pesticides and other agricultural chemicals; and

environmental contaminants including heavy metals.
The Honey Program also develops and conducts annual directed sampling plans for specific
chemical residues and targeted honey populations that have previously been identified as being a
concern. The monitoring and directed sampling plans are re-evaluated on an annual basis.
Chemical residue sampling is a priority inspection activity for the honey program.
Division 15 of the Food and Drug Regulations sets out the maximum residue limits (MRL)
permitted for veterinary drugs and heavy metals. In addition, Health Canada and the CFIA have
developed a joint policy on Working Residue Levels (WRLs) for Antimicrobial Residues in Honey
(see also the CFIA's WRL Questions and Answers). Maximum Residue Limits for pesticides are
prescribed by the Pest Control Products Act (PCPA) (see Health Canada's List of MRLs Required
under the PCPA).
For the definitions of WRLs and MRLs and further information on chemical residues please refer
to Appendix 2.1A Supplementary Guide for Chemical Residues in Honey [RDIMS # 2055039].
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2.7.3
Honey - Product Inspection Manual
Composition
The Honey Program conducts annual monitoring and directed sampling plans to verify that:
2.7.4

no sugars have been added to the honey (authenticity); and

that the honey meets the compositional standards as per the Codex Standard for
Honey CODEX STAN 12 and the Honey Regulations Section 8, and Tables III and
IV to Schedule I.
Microbiology
The Honey Program on occasion, monitors for the presence of micro-organisms namely, sugartolerant, osmophilic yeasts in prepackaged honey. The purpose of this is to determine the
effectiveness of the honey pasteurization process in registered pasteurizing establishments. As
per the Honey Regulations, Interpretation Section, “pasteurized, in relation to honey, means
treated in a registered pasteurizing establishment by the controlled application of heat so that the
honey is free of viable sugar-tolerant yeasts”. Pasteurization is done to maintain the quality of
liquid honey thereby extending its shelf-life and inhibiting yeast fermentation.
2.7.5
Harmful Extraneous Material
Extraneous material can include many different types of materials. Of concern are materials that
can be harmful because of their hardness, sharpness, size or shape. Examples of harmful
extraneous materials include glass, wood-chips, insulation, metal, or sharp plastic greater than 2
mm in size.
To help determine if the extraneous material is hazardous, background information should be
gathered on the type of material used in the facility, facility maintenance history, consumer
complaints and evidence of possible tampering.
When consumer complaints or inspection evidence indicates contamination by potentially harmful
extraneous material, the product may need to be detained and directed samples taken. Contact
the area honey specialist for more information. Special request sample numbers must be
obtained from your area honey specialist and contact the laboratory prior to submitting the
samples.
2.8
Laboratory Sample Submission Procedures
For samples submitted to a CFIA laboratory, the LSTS form is completed and submitted
electronically. For samples submitted to a private laboratory, the LSTS form can be completed
and saved electronically or an equivalent form can be used. A copy of this form should also be
placed in the company's file.
2.8.1
Identify the Samples for Laboratory Analysis
Each sampling plan provides the unique sample numbers to use to identify every sample. Be sure
to use these pre-assigned numbers when you label or identify your samples. Each of the letters
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and digits in the sample number has a meaning. For example, the meaning of the sample number
H8-13-CR-0001 is as follows:
H8
13
CR
0001
Program
Honey
Fiscal year
Activity
Chemical Residues
Sequential number from 0001 to 9999
In order to match the samples with the Food Product Sample Submission Form, clearly and
permanently label each sample (including all sample units) with the following information:
2.8.2

pre-assigned unique sample number (e.g., H8-13-CR-0001);

lot number; and

sample unit number if more than one unit (e.g., sample 1 of 3, 2 of 3 and 3 of 3).
Complete the Food Product Sample Submission Form
To provide a detailed record of the product sampled and to enable trace back or follow-up
activities if need be, please ensure you record the following information on the form:
Submission Tab:

function (domestic or import), sampling plan, laboratory;

analysis information (load per plan or select tests required from list);

manufacturer / registration number or importer / country of origin;

responsible party;

name of the sampler, submitter and expediter;

exporter and foreign manufacturer for directed samples only (under ‘comment’ field);
Sample Tab:

sample information (sample no. and number of sample units),

product information (common name; brand name; grade and colour; pasteurized,
liquid or creamed; any other label claims);

lot information (lot number, total weight, unit size);
For more information on how to complete the LSTS submission form for the Honey Program,
please see Appendix 2.2 LSTS Submission Form and LSTS AgriFood Training Guide [RDIMS
#2291552].
2.8.3
Ship the Samples

Use clean, dry shipping containers and packing materials.

Ensure that each sample is identified with the sample number.

Seal and individually bag the sample containers as necessary and protect with
packing material to ensure the integrity of the sample is maintained during transport.

Ship the samples within a reasonable time period following sampling, using the most
direct and cost effective route possible.
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
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Send the samples to the attention of the Food Laboratory of Laboratory Services
Division in each lab. The addresses for all laboratories are listed in the annual
Sampling Plans and Guidelines [RDIMS #1712580].
Laboratory Sample Result Assessment
Except for the NCRMP samples, which are mainly contracted out to private accredited
laboratories, the samples are analyzed by the CFIA's laboratories.
Because the NCRMP is a monitoring program managed by the CFIA’s Chemical Evaluation
Section, the results from the private laboratories are sent directly to them and not to the Honey
Program or respective inspector. The Chemical Evaluation Section is responsible for assessing
the results and forwarding all unsatisfactory results to the appropriate program. Consequently,
only unsatisfactory NCRMP results are reported to the Honey Program and inspector for followup.
Results from the CFIA laboratories are reported electronically via LSTS PENMAN to the
respective inspector submitting the sample and anyone else subscribed to receive the results.
The bottom of the LSTS Report of Analysis will state the analytical method used, the results of
analysis and the assessment decision (satisfactory, investigative, no decision or unsatisfactory),
based on program assessment criteria outlined in the Annual Sampling Plans and Guidelines, for
the internal report only. An external report is also available to provide results back to regulated
parties.
2.10
Follow-up to Laboratory Sample Results
The following are general approaches to be taken to follow-up sample results. Inspectors are to
consult the annual Sampling Plans and Guidelines for more specific directions.
2.10.1 Satisfactory Results
A satisfactory laboratory result means that the lot of honey is considered to be in compliance with
Canadian requirements for the analysis conducted. For results from the CFIA laboratories, send a
"Satisfactory Results" letter and/or the external LSTS report of analysis, only if requested by the
regulated party. A template letter can be found by following the link in Appendix 2.3.
For private laboratory samples from the NCRMP, satisfactory results are not reported since these
results are not available to the Honey Program.
2.10.2 Investigative Results
Laboratory results are assessed as investigative when veterinary drugs have been detected in
honey below a recommended WRL.
Investigative laboratory results (e.g., usually from CFIA laboratories) are to be reported to the
establishment or importer using the appropriate template letter, which can be found by following
the link in Appendix 2.3.
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2.10.3 Unsatisfactory Results
A laboratory result will be assessed as unsatisfactory when the compositional requirements are
not met or one of the following is detected:

a banned substance (e.g., chloramphenicol, nitrofuran);

a substance unapproved for use in beekeeping (e.g., fluoroquinolones);

a chemical residue above the MRL or WRL; or

foreign sugars.
For all unsatisfactory results, the inspector must inform the regulated party, the area
honey specialist and open an Issues Management System (IMS) as outlined in the
business rules to track all follow-up activities. For instructions on opening an IMS,
please refer to the IMS User Manual [RDIMS #1599661].
2.10.3.1 Unsatisfactory Monitoring Results

Open an IMS.

Bring unsatisfactory monitoring results to the attention of the responsible party.
Template letters for unsatisfactory NCRMP or CFIA results are available by following
the link in Appendix 2.3.

Conduct a directed inspection to investigate possible root causes of the noncompliance.

If any product from the same or similar lot is available, it is recommended to take
directed samples and to control the product.

If no similar lot is available, use the findings from the directed inspection to
determine whether directed samples are required from next lots.
2.10.3.2 Unsatisfactory Directed Results
Always inform the regulated party of the directed results and take appropriate action as per the
annual Sampling Plans and Guidelines.
All unsatisfactory results are to be brought to the attention of your area honey specialist to
determine if a health risk assessment is required. Control the product and conduct an
investigation as required.
If the affected product is in distribution, contact the Area Recall Coordinator and follow
established protocols for potential health risk situations.
As part of the follow-up activities:

Send a letter to the regulated party requesting appropriate product disposition and a
corrective action plan (CAP). Template letters can be found by following the link in
Appendix 2.3.

Once you receive the CAP, review it to determine if there are any missing
components or if further clarification is required. For further information please refer
to Appendix 2.4 Procedures to Evaluate Corrective Action Plans [RDIMS #1564862].
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
Conduct a follow-up inspection within a reasonable time frame based on the
estimated risk or next visit (e.g., GMP, Product Inspection) to determine if any effort
has been made to implement the CAP and its effectiveness.

Log all of your activities in the IMS.
When repeat non-compliances from the same company have been identified, stricter
enforcement actions need to be considered. Contact your supervisor and area honey
specialist for direction to control the risk.
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2.10.3.3 Product Disposition
Product detained for an unsatisfactory result is not allowed to be sold in the Canadian
marketplace. Each situation however, will be evaluated on its own merit (case by case).
Table 2.1 outlines suggested options.
Table 2.1 Product Dispositions
Reason for Violation
Suggested Options
Considerations
Chemical Residues
Voluntary Destruction (HR 4.3)
Meets provincial environmental
requirements.
Not allowed to be sold as
food in Canada (HR 4.1(2),
CAPA 17)
If imported; return or remove from
Canada (CAPA 30)
Proof from customs (E15).
Foreign government notification.
Use in animal food (HR 4.2)
Consult with animal health / feed
/ pet food program.
Use for non-food applications
Meets applicable requirements.
Voluntary Destruction (HR 4.3)
Meets provincial environmental
requirements.
Authenticity ─ C4 Sugars
Not allowed to be sold as
food in Canada (HR 4.1(2),
CAPA 17)
Composition ─ Grade
Requirements
If imported; return or remove from
(CAPA 30)
Use in animal food (HR 4.2)
Consult with animal health / feed
/ pet food program.
Use for non-food applications
Meets applicable requirements.
Voluntary Destruction (HR 4.3)
Meets provincial environmental
requirements.
If imported; return or remove from
Canada (CAPA 30)
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Proof from customs (E15).
Proof from customs (E15).
Use in animal food (HR 4.2)
Consult with animal health / feed
/ pet food program.
Use for non-food applications
Meets applicable requirements.
Correction prior to sale
Meets applicable requirements.
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