There has been a great deal of discussion on CFIA’s inspection and enforcement crackdown, focused particularly on licensing compliance by food manufacturing establishments. With the effort having been underway for several months now, what changes have been made by CFIA – and what are they finding?
In a late April I.E. Canada meeting, Craig Price, CFIA Director of Operations, National Service Centres Division, discussed just that. Following are some of the key points from that presentation:
Domestic licensing
- Licence applicants are now required to complete an ERAM-FSSI questionnaire for their declared activities in order to apply for a new, amended, or renewed licence. This information will be reviewed to ensure it meets the expectations for each commodity.
- ERAM (Establishment-based Risk Assessment) – In the past, the risk of a product or facility was based on the voluntary submission of information from the licence holder, and the submission of an application was essentially akin to receiving a licence. Now the risk assessment is mandated and CFIA thoroughly reviews all information in the application.
- FSSI (Food Safety Supplemental Information) Food businesses that conduct domestic activities must also complete the FSSI (formerly the Additional Establishment Information (AEI)) questionnaire to provide information about the establishment’s operational activities and strategies.
- The applicant’s Preventive Control Plan (PCP) and preventive controls will be reviewed to confirm “a valid preventive control is in place, and that they understand their responsibility for food safety.”
- The implementation of these has led to stronger controls, better deployment of field personnel based on level of risk…and longer processing times.
- CFIA will no longer process any SFC licences (new, amended, or renewed) within 48 hours as it had in the past. Licences will only be issued after the above criteria has been validated.
- Length of time will thus depend on how many applications are ahead of yours and how thoroughly your application has been completed, with 70-day service being the standard.
- Although 70 days has always been the standard, 75% to 80% of applications did not previously undergo a review, so took only a few days for approval.
Importer Requirements
Importers are also subject to the changes, with the impacts particularly relevant in this space, as many importers don’t have a clear understanding of their accountabilities. Meeting one’s own country requirements is not good enough; importers must be able to show that the foods they are importing meet all CFIA standards.
In the last month alone, 15-20 importers were denied licence renewal, because they did not have appropriate supply chain controls in place. And the lack of a valid licence will cause rejection at the border.
CFIA Observations and Advice
Price provided some additional observations and advice for those seeking a licence:
- The confirmation of a valid PCP will involve a phone or video call with the applicant. So, it is important to have the right representative(s) on the call who can answer CFIA questions on the facility’s preventive controls, risk management, etc., “or the interview won’t go well.”
- With the longer processing in place, it is advised that businesses submit renewal applications at least 70 days ahead of their expiry date so there is no lapse in licensing.
- Note: If your licence expires by July and you’ve not yet applied, do so as soon as possible. CFIA is keeping an eye out for these and will prioritize them when possible. But after July 6, CFIA feels the word has been out long enough, so expiration dates will no longer be a consideration.
TAG’s Recommendations
In addition to the advice provided by CFIA, we would emphasize the need to thoroughly complete and submit licence applications as soon as possible whether renewing, amending, or applying for a new licence. Without a licence, you cannot operate; and we are already seeing long delays in licence approvals, which are particularly impacting those expecting that turnaround will still be a 48-hour process.
If you need assistance in completing your domestic or import licence application or in other licensing efforts, give us a call. With former CFIA officials on our team, we know how the system works and how to help you!
