Law on safe food for canadians (SFCA)

As the world evolves with the ever changing preferences of consumers and as globalisation constantly amends international standards, Governments need to keep up and update their regulations to protect their population. That is why the Governments of Canada and the United-States of America (USA) have introduced two Acts in recent years, the Safe Food for Canadians Act (SFCA) and the Food Safety Modernization Act (FSMA),
respectively.

Both Acts take on similar stands on Food Safety and differ from previous ones because of their modern view on the industry and their emphasis on proactive actions. Undoubtedly, one of the key words found in both of those is ‘’prevention’’; prevention and validation are essential in modern Food businesses and are dominant ideas found in these regulations.

SFCA AND ITS REGULATIONS

La conformité exigée par la FSMA et la LSAC et son règlement associé (Règlement sur la salubrité des aliments au Canada [RSAC]) sont différents. D’une part, la première date de mise en conformité de la FSMA était le 19 septembre 2018. D’autre part, en ce qui concerne son équivalent canadien, la première date était le 15 janvier 2019.

Is your company compliant with the SFCA and SFCR?

The required compliance for both FSMA and the SFCA and its associated regulations (SFCR) differ. On one hand, FSMA had its earliest date of compliance on September 19, 2018. On the other hand, for its Canadian equivalent, the earliest date required was on January 15, 2019. The SFCR were made to institute new rules that are modern but still simple for food facilities to understand and apply. These regulations were made to protect consumers, with a better control of imported foodstuff and easier exports with partner countries such as the USA

Preventive control plan

Under the new SFCR, your business might have to develop a Preventative Control Plan (PCP).
To find out, if your business is eligible, use the interactive tool on the Government’s Website: https://na1se.voxco.com/SE/93/SFCR_PCP/?&lang=en.

Being eligible means that your company must comply with the PCP, and therefore that, hazards must be identified. Those hazards include everything that may present a risk of contamination for the food product. The control measures must prevent, eliminate and reduce them to acceptable levels. In that aspect, PCPs are very similar to Hazard Analysis and Critical Control Points (HACCP) plans since they both try to assess the critical control points (CCP) and prevent unwanted results and non-conformities during the process. The only difference is that the PCP includes measures to meet requirements of humane treatment of animals and consumer protection. On these grounds, if you already have a HACCP plan put in place you are already a step closer to getting licensed. However, if your company doesn’t have a thorough HACCP plan, it is important to start now since this is the basic aspect of all PCPs.

Biological hazard

A HACCP plan will focus on all 3 types of hazards; Biological, chemical and physical. Biological hazards are not to be taken lightly as it causes food products to be recalled, thus potentially damaging your brand and above all, causing serious illness or even death. Let us remember the Listeriosis outbreak that started in January 2017 and continued until July 2018 in South Africa, responsible for more than 200 deaths and an additional 1,000 patients harmed by the bacteria. This is a great example of what can happen when little to no regulation is applied in the business.

Different biological hazards exist and some foods may have a higher risk of contamination than others due to their characteristics. Therefore, a risk assessment should always be one of the first steps involved in a PCP. Hazards such as Listeria monocytogenes can be a big risk for many different products, since they can be found nearly anywhere and are known to form biofilms that are harder to remove from surfaces. Regular cleaning and sanitisation procedures might not be enough for their removal. For that reason, environmental sampling is one of the most effective ways of preventing the final product to be contaminated and avoid any outbreak.

Environmental sampling

Environmental sampling is useful to monitor the sites in which the product is being processed or stored. We have to understand that environmental sampling will consist of different testing which will include, but won’t be limited to, water or surface sampling. To do so, it is important to have the appropriate tools and not contaminate the sampling taken for analysis. Multiple tools can be found on the market.

For surface sampling you can find sampling wipes, sponges or sponges on a stick that are used with different kinds of neutralising solutions. Surfaces hidden from plain sight are usually the most at risk because of the fact that they are harder to reach and so harder to clean. In this case, sponges on a stick may be the most appropriate sampling tool to reach those areas.

Depending on the product or on the biological hazard to be analysed different procedures exist. The Government of Canada has put in place a guideline for ‘’Control measures for Listeria monocytogenes in ready-to-eat foods’’ and is available to the public. In this guideline, the Government talks about food contact surfaces (FCS – Zone 1) and non-food contact surfaces (NFCS – Zones 2, 3 and 4) where it is explained that at least 10 samples of both types of surfaces should be taken for each product line. This is essential in a world where cross-contamination can easily occur.

Cross-contamination which happens when a contaminated surface comes in contact with a person or material that is then transferred to a FCS and eventually transmitted to the end-product can readily occur in food facilities. A HACCP plan is implemented to avoid any critical contamination from happening. However, cross-contamination can happen very easily, simply by inattention; let’s never forget that any type of error may arise. These may be caused by an employee that forgets to wash their hands properly after their break or a truck driver that decides to walk on the facility with their contaminated boots without knowing. This might affect the final product in various ways. Consequently, NFCS are crucial surfaces to be analysed since they can avert huge crisis, similar to the outbreak currently happening in the United States and part of Canada with the Escherichia coli O157:H7 (E. coli O157:H7) in romaine lettuce. As such, testing NFCS is part of a proactive method of sampling since this could prevent biological hazards by identifying in advance potential sources of contamination before it reaches the FCS.

Let’s take the right direction

In conclusion, in today’s reality, companies have no choice but to be proactive in their approach. These actions, such as the ones described in the SFCR, help reduce any type of contamination including biological hazards and ensure that food lots are released much faster than before with complete peace of mind from the food facility. These regulations permit to have products that are safe for human or animal consumption and thus limiting product loss. That is why a PCP should be an important part of any business associated to the food industry including those not required to follow the SFCR by the Government of Canada especially considering the advantages for the company.

It’s time to be proactive!