As of the first of this month (April 1, 2024), CFIA’s Importer Risk Assessment model for food importers (IRA-Food) is now in effect. The model was developed to counter the sweeping increase of international food trade and the related increase in potential food safety risks for imported foods.
Following the scientific and transparent approach CFIA has used since 2019 in the Establishment-based Risk Assessment (ERA)-Food model to inform inspection frequency in domestic food establishments, the IRA-Food model aligns consistency on assessing risk for regulated parties and addresses requests from both domestic and import industry sectors. With this implementation, risk assessment becomes consistent and transparent across both.
A quantitative, science-based risk assessment to estimate the risk associated with SFCR-licenced food importers, the IRA-Food allows for comparison within and across food commodities, with similar risks treated with similar rigor. The goal is to help inform the allocation of CFIA inspection resources and other activities (e.g., frequency of inspection, sampling) according to food safety risk. Subject to the new IRA-Food are SFCR-licenced importers with no domestic food establishment (as depicted in the graphic below).
As further defined by CFIA, to ensure inspection resources ARE NOT double-allocated:
- If an establishment or Regulated Party (RP) conducts domestic activities and also imports, inspection will be planned considering the ERA-Food risk category.
- If a RP has multiple import licenses, the IRA model will generate only one risk result, by considering all transactions associated with those licenses. If the same RP also conducts domestic activities at an establishment, the ERA-Food model will be used to inform the inspection.
Through the established portal, importers subject to the IRA-Food are required to identify imported commodities on their SFC licence(s) reflecting their current situation, providing the information to support their transaction (e.g., identification of product type using the Automated Import Reference System). Each importer is accountable for the information provided, as any incorrect or missing information will affect the accuracy of the IRA-Food model in performing risk assessment, leading to incorrect importer risk results; and thereby, will impact the allocation of inspection resources based on risk.
With the model going live this month, CFIA’s intention is to run risk profiles on an annual basis until an automated IT solution is built. The risk factors on which the profiles are based include:
- Inherent risk: Commodity, product type, volume, product targeted to vulnerable population, intended use.
- Mitigation: Country of origin’s national food safety system recognition, food safety control program recognition and/or food inspection system recognition; use of suppliers with Private Certification Schemes.
- Compliance: Last 4 inspection results (within the last 3 years), recalls of the last 5 years, enforcement actions of the last 2 years, and food safety confirmed complaints of the last year.
Those who are newly licenced or unassessed will be assigned a “temporary” IRA risk category based on the average risk for importers bringing the same main commodity. It is important to note, though the IRA Food risk results are just one piece of information that is considered along with other factors (e.g., type of product, specific import conditions, etc.). Currently the risk profiles are available from the inspector, but a future enhancement will enable direct access through My CFIA.
How does this benefit the industry? Primarily the system enables all regulated domestic establishments and importers to be assessed consistently and uniformly with similar risks treated with similar rigor, so industry will be better able to understand and anticipate inspection oversight. Additionally, industry risk mitigation, compliance, and improvements will be acknowledged, and individual risk profiles can be accessed by establishments and importers.
TAG Canada sees the overarching intention of the IRA-Food Model as being of benefit to both CFIA, enabling the agency to better apply resources to the greatest risks, and to the industry, providing a consistency and uniformity in assessments and enabling establishments and importer to better understand assessments and improve their operations.
Having based the system on the ERA-Food model which has been in place since 2019, the roll out should occur smoothly with few hitches, although it is certainly a system to which industry will need to adapt. TAG Canada can use the principals and methods of the IRA to assist companies identify where their import control program would rank under this system and how much CFIA inspection oversight they could expect. Give us a call today to ensure you are compliant!
