Introduction

Consumers expect food to be safe. And they expect to be protected from unfair or dishonest business practices.

Increasingly, foodservice and food retail/wholesale operations in North America and around the globe require food companies to have their food safety program:

  • audited by a third party
  • recognized by government
  • certified against one of the internationally recognized Global Food Safety Initiative (GFSI) benchmarked programs, for example, Safe Quality Food (SQF), British Retail Consortium (BRC), Canada GAP

An audit of your food safety program demonstrates to your buyers that your product has been processed, prepared, handled and distributed according to a recognized food safety program.

Other certifications are related to either sustainability (fair trade, organic) or religious requirements (kosher, halal) and not directly to food safety.

In this section you will learn:

  • Why be concerned about food safety?
  • Who is responsible for food safety?
  • Why implement a food safety program?
  • What is a food safety program?
  • Choosing the right food safety program for my business

Why be concerned about food safety?

Increasing consumer concern

Recently, not-so-common names of pathogens (micro-organisms that cause food-borne illness) have crept into the news as we hear stories about Salmonella in peanut butter and cantaloupe, E. coli O157:H7 in romaine and iceberg lettuce, and Listeria monocytogenes in ready-to-eat meats and cheese products. We are also hearing more about product recalls due to undeclared allergens. Outbreaks of food-borne illness and product recalls are gaining media attention. Recalls, in turn, increase public concern.

The growing attention to food safety is in part due to improved surveillance (for example, testing of food) and greater reporting of food-borne illness, but it is also due to changing circumstances such as:

  • Micro-organisms multiply and evolve very quickly. Pathogens are very effective at evolving into strains that are more dangerous.
  • Preferences are increasing for fresh and/or ready-to-eat foods, as well as highly processed products.
  • Foods that are not cooked by the consumer limit consumers’ ability to control hazards (for example, thorough cooking).
  • The more steps involved in production and processing, potentially the greater the risk of contamination.
  • Globalization of the food supply is also increasing with demands for year-round variety.
  • Demographic changes, such as an aging population and greater awareness of severe allergies.
  • More people are at risk and are more susceptible to becoming ill from contaminated products.

While many of these illnesses are short-lived and minor, some cost governments, the health sector and individuals, considerable resources to resolve. Illness and injuries due to food products are costly for us all.

Individual costs

For the lucky, a food-borne illness runs its course in a few days with mild symptoms such as vomiting and diarrhea, and perhaps a few days of lost work. For others, a food-borne illness can be more severe and, in some cases, turn into chronic disease, such as kidney disorders. The very young, elderly and immuno-compromised can even die from food-borne illness.

The costs of food-borne illness

Contaminated food is not safe to eat. Contaminated food products can cause a range of illnesses and injuries, such as:

  • mild to severe food poisoning
  • injuries to the digestive tract
  • ongoing health problems
  • death

The Public Health Agency of Canada estimates each year roughly one in eight Canadians (or four million people) get sick due to domestically acquired food-borne diseases. Learn more on the Government of Canada’s webpage.

Public costs

Days off work cost our economy in lost production. Our tax dollars pay for doctor visits, diagnostic tests, stays in the hospital and treatments for fighting illness. Food-borne illness is an unnecessary burden on our public health care system.

Business costs

Beyond costs to society, your company can suffer from severe business losses. If a contaminated product is linked back to your company, you will likely deal with recalls and wasted product. This can affect your reputation and lead to lost sales, lost customers and lost business opportunities. If the crisis is long lasting or far-reaching, unwanted publicity and lawsuits can lead to job losses and in extreme cases, bankruptcy or company closure.

Other impacts

Some processes required in food processing may trigger environmental and labour regulations as well as complicate where you can set up a food processing facility. Re-zoning takes a lot of time. Site plan approvals may be linked to an Environmental Compliance Agreement (ECA). All these processes can take time.

Who is responsible for food safety?

Role of industry

Each person in the food chain has a responsibility to do their part in ensuring food safety, whether you are a farmer, a transporter, a processor, a distributor, retailer or consumer. Every hand that handles food has the potential to improve food safety or cause contamination.

Food safety requires multiple layers of cooperation and intervention. If you produce or handle food, you need a system to minimize harmful effects to public health and your business. When employees do not follow food safety practices, contamination of the product can occur. This could lead to illness for the consumer and a crisis for the business.

Industry has a responsibility to:

  • commit to a food safety program over the long term
  • allocate necessary resources
  • meet the food safety program, by developing and implementing practical, effective procedures that are specific to and work within your facility
  • ensure all staff are trained
  • verify staff remain diligent in their activities

Why implement a food safety program?

Food safety assurance

The primary benefit of a food safety program is the reduction and elimination of potential food safety risks (biological, chemical and physical hazards) to your products.

Business advantages

Implementing a food safety program has helped Ontario companies increase sales, gain new customers and broaden their market reach.

Here are some other benefits to implementing a food safety program:

  • Increased customer confidence and open new markets
    • Processors with a food safety program demonstrate a greater degree of confidence that they are producing a safe food product.
    • Many buyers require food safety programs for their suppliers to maintain market share and/or gain access to new markets.
  • Operating more efficiently saving you time and money
    • Standardized procedures lead to improved product quality and consistency.
    • Preventing rather than reacting to problems leads to fewer recalls, returns and customer complaints.
    • Regular monitoring leads to anticipating problems earlier and the potential for less waste.
    • An analysis of your manufacturing process helps identify the potential for reduced production costs.
    • Food safety-related due diligence may result in reduced insurance costs.
  • Improved employees’ behaviours and attitudes
    • Employees are more aware of hazards, are more conscientious and take pride in their work which leads to decreased employee turnover.

What is a food safety program?

Good manufacturing practices (GMPs), also known as prerequisite programs or preventative control plans (PCPs) are:

  • food processing best practices implemented to create a safe and suitable environment for the manufacturing of food
  • the foundation of a food safety program, also known as Hazard Analysis Critical Control Points (GMPs need to be implemented before HACCP)

GMPs involve written rules, procedures, records, staff training and verification to ensure that people and premises do not present food safety hazards.

People controls are practices and rules that food handlers and others in the facility follow to prevent or control food safety hazards. Premise controls are requirements for the condition of the facility (inside and out) that prevent or control food safety hazards.

GMPs include but are not limited to:

  • premises — building exterior, interior, water supply and sanitary facilities
  • transportation, purchasing, receiving, shipping and storage
  • equipment — preventative maintenance and calibration
  • personnel and training — written policies and training for hygiene
  • sanitation and pest control — written programs for pest control and sanitation standard operating procedures (SSOPs)
  • allergen control — managing the use of allergens and ensuring your product is labelled correctly
  • process controls — written description of processing steps (for example, cooking) and associated control measures and critical limits
  • product recall — written program which includes a protocol for a mock recall to test systems effectiveness
  • traceability — tracking an identified product (and its attributes) as it moves between locations

Elements to consider when developing good manufacturing practices

The following elements are often included in GMPs which are the foundation of a food safety program. The specific requirements for GMP components can vary according to different food safety programs, however the basic principles are always the same. Below are guidelines to follow when developing your GMPs. If you have a specific food safety program in mind, be sure to check the standards for that program.

Premises — building exterior, interior, water supply and sanitary facilities

The food processing facility should be designed, constructed and operated to:

  • permit the operations to be performed under clean, sanitary and orderly conditions
  • permit the effective cleaning of all surfaces
  • prevent contamination of the food
  • ensure that water, ice and steam used as an ingredient for processing, sanitation and hand washing is potable

Transportation, purchasing, receiving, shipping and storage

Food should be received, stored and transported to avoid:

  • contamination of the food
  • rapid proliferation of micro-organisms in the food
  • deterioration of the food or damage to the package to maintain the safety of the product throughout the distribution system

Only approved ingredients, products and materials are purchased.

Equipment — preventative maintenance and calibration

Equipment should be designed, constructed, maintained, operated and arranged to:

  • permit effective cleaning
  • prevent food contamination of food by other food, dust and foreign material
  • permit operation in accordance with intended use

Measuring and monitoring devices used in a process critical to food safety, such as thermometers, are to be routinely calibrated.

Personnel and training — written policies and training for hygiene

Every person producing food should:

  • be trained to carry out the duties and responsibilities assigned
  • conform to hygienic practices while working in contact with food, food processing equipment and packaging materials to prevent contamination

Sanitation and pest control — written programs for pest control and sanitation standard operating procedures (SSOPs)

Cleanliness of the processing area, equipment and utensils is required to prevent contamination of the food and ensure food safety. Soil residues and films harbor micro-organisms and therefore must be regularly and effectively cleaned and sanitized.

Written SSOPs must be developed and put in place for every room and piece of equipment in the operation.

The design and construction of buildings should prevent entry of pests to prevent hazards that might adversely affect the safety of food.

Allergen control

Some people are allergic to certain ingredients in foods. By law, you must make sure the labels on your food give a complete and accurate listing of ingredients, so consumers know what they are eating.

The priority food allergens associated with severe allergic reactions are eggs, milk, peanuts, seafood (fish, crustaceans and shellfish), sesame, soy, sulphites, tree nuts, wheat and mustard. See Health Canada’s common food allergens webpage.

The Canadian Food Inspection Agency (CFIA) estimates that as many as 2.6 million Canadians may be affected by food allergies and these numbers are increasing, especially among children.

As part of your good manufacturing practices, you will want to manage your use of allergens during processing. If your product is not labelled correctly, or if your food accidentally becomes contaminated with an allergen, the results can be serious. You can find a list of ingredients and allergens on food labels from CFIA’s website.

If you export your products, check the list of priority allergens for that country/region. For example, one of the priority allergens in the European Union is celery.

For information on labelling allergens and your responsibilities as a processor, go to CFIA’s How to Label Allergens on Your Food Product webpage.

Process controls

Written procedures should be available and followed to ensure the product does not result in a health hazard. Inadequate process controls could lead to pathogenic organisms, toxins and other hazards contaminating the product.

Procedures should include:

  • identification of critical control points (CCPs)
  • critical limits for CCPs
  • monitoring programs for CCPs
  • corrective action in case CCP does not meet critical limits
  • verification procedures to confirm the food was produced in compliance with the written procedures

Product recalls and traceability product recalls

News of a product recall may not only have significant financial impacts for your business but may be devastating for your company’s reputation as well as that of the entire sector. This can jeopardize your current market share and put your company’s viability at risk.

Imagine this worst-case scenario: one of your products has been reported as potentially being unsafe or the cause of a food-borne illness outbreak. This report could have come from one of many sources, such as:

  • public health officials
  • consumer complaints
  • CFIA inspections, testing and sampling programs
  • other government departments
  • competitors
  • international governments
  • company-initiated concerns found by in-house sampling

There are several things you can do to reduce the impact of a product recall:

  • Have a food safety program in place to prevent or avoid risks to your product that could trigger a recall.
  • Have an effective traceability and recordkeeping system that collects information on your raw materials and ingredients, your production processes and your finished products (see Traceability).
  • Ensure you can remove your product from the marketplace as quickly as possible using a tested recall program. Preparing your recall program in advance and testing its effectiveness with regular mock recalls will put your business in a good position to reduce its risks and liabilities associated with a product recall. Health Canada’s guide for voluntary recall of consumer products or cosmetics will help you implement your recall program so that it works when you need it to.
  • Develop crisis management and communications plans for product recalls so that your company can react and respond quickly to your customers and the public.
  • Ensure your business has adequate insurance coverage to mitigate the potential effects and cost of product recalls. In Canada, there are Insurance companies that provide insurance to cover cost of product recalls. The coverage and cost can vary depending on the package the business owner chooses to purchase. In some cases, this coverage isn't included with general liability insurance, but it can be added as a condition.

If your product is identified as having undeclared ingredients (for example, allergens) being potentially unsafe or suspected as the cause of food-borne illness, you should initiate a product recall voluntarily. If there is a threat to public safety, CFIA has the power to recall and detail the product even if your business chooses not to initiate a product recall.

When CFIA issues recall notices they can be found on the CFIA’s Food recall warnings and allergy alerts webpage.

Additionally, the CFIA offers the How we decide to recall a food product fact sheet that you can review to learn more about the recall process.

Traceability

Traceability is the ability to follow products through all stages of the agri-food chain — from production to retail. Traceability allows your business to effectively track an identified product and its attributes as it moves between locations. It is important:

  • to help you meet your market requirements and access new market opportunities
  • for effective product recall
  • for planning, response and recovery efforts in the event of an animal disease outbreak
  • to ensure confidence in your products
  • for protection of your business and your customers

All businesses practice traceability to some degree through normal operations and sales transactions. Documents such as invoices, bills of lading, receiving logs and purchase orders can help you collect information about who you buy from (your suppliers), what you buy from them (such as raw materials or ingredients), how you use those goods (your processing steps) and to whom you sell your finished products. More often, it is food processors who are asked to provide records of these facts. For example, a foreign market may require documentation related to traceability as part of their regulatory requirements. Even local customers may want proof that your business keeps track of and knows the sources of raw materials, ingredients or products. Additionally, a processor may be asked to justify a claim (for example, fair trade, organic, kosher) on a product for branding or marketing purposes.

A traceability system needs to record three key elements:

Location identification (or premises)

Identifying your location or premises is a critical first step to building an effective traceability system by allowing you to know where your inputs are coming from, where your products are currently and where they were shipped. It involves obtaining a unique identifier associated with your agri-food operation such as a processing plant, abattoir, warehouses or other sites that handle your products. These unique identifiers can be incorporated directly into barcode information or used in business management software to identify locations, customers and suppliers.

In Ontario, agri-food businesses can voluntarily register premises in the Provincial Premises Registry (PPR). The PPR is an OMAFRA initiative and the only official provincial registry for obtaining a Premises Identification Number (PID) for Ontario agri-food businesses. The purpose of the PPR is to establish an accurate premises identification database by securely collecting, verifying and storing premises information and assigning unique PID to parcels of land in Ontario. Visit the PPR to obtain your PID.

Product identification (and related attributes)

It is easier to find and track products that have been assigned an identification number or code. Examples include lot or batch number and production date. The method of product identification for processed food may be determined by your commodity or market requirements.

Movement recording

Movement recording is a record of movement of your products from one location to another. Movement recording cannot occur without premises and product identification. At minimum, movement recording between premises (for example, from a processing facility to a retail store) requires product identification, premises identification (both for place of origin and destination), date shipped/received, quantity moved and the method of transportation. You may also want to collect other information about product movement for your food safety program, such as temperature during movement and cleanliness of transport vehicles.

A traceability system captures, stores and shares information about products received and internal production and operational processes all the way to when the finished goods are shipped and sold to the customer. To have an effective traceability system that maximizes your business processes and recall capabilities, you need to be collecting the right pieces of information about your incoming goods, your production processes and your finished product.

Traceability systems can range from simple paper-based recordkeeping to more sophisticated information management that uses automated and computerized components for efficient data capture and secure access to information. Whichever traceability system you choose, having accurate and complete records at critical stages in your operation are vital to collecting the information required to make the right decisions for your business.

Experts recommend that you trace the attributes of your product at least one level back and one level forward from your operation, called “one-up, one-down” traceability. One level back will require you to track your incoming goods back to your suppliers, while one level forward will require you to know who you sold your product to immediately after it left your facility.

To learn the basics to help you implement traceability for your business, visit the Agriculture and Food Education in Ontario webpage.

Hazard Analysis and Critical Control Point (HACCP)

HACCP is a science-based food safety program recognized worldwide as the primary means for enhancing food safety. For a complete and proper HACCP system, you first need to implement GMPs. Remember that GMPs take care of hazards associated with personnel and your premises environment. HACCP controls hazards associated with your ingredients, products and processing steps.

HACCP system = GMPs + HACCP plans

Developing your HACCP plan(s) involves two key concepts and associated actions:

  • Conducting a Hazard Analysis — involves looking at all your ingredients, products and processing steps to determine where hazards are likely to occur.
  • Determining Critical Control Points — a CCP is a point, step, or procedure where a control measure can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level. An example of a CCP is cooking temperature.

To get practical resources and support to help you develop GMP and HACCP programs for your business, as well as general information on food safety for food processors, contract OMAFRA’s Agricultural Information Contact Centre at 1-877-424-1300.

A HACCP plan is a document (or set of documents) that you develop to control hazards that are important for food safety and associated with your specific ingredients, products and processing steps. The details of your HACCP plan will be unique to your facility.

Choosing the right food safety program

When implementing a food safety program, you have the choice of several different programs to follow that fall into one of two categories — public and private.

All programs, whether public or private, set standards for safe food production for the agri-food industry. The programs almost always include:

  • GMPs, also known as prerequisite programs or PCPs
  • HACCP plans

Programs may also include additional requirements such as:

  • traceability
  • food defense
  • management commitment

Public programs

Public food safety programs are offered by the government. The federal Government of Canada offers the Food Safety Enhancement Program (FSEP) for federally registered facilities. For some federally registered facilities, FSEP is mandatory by law for example, meat. The CFIA audits these facilities.

Please see CFIA’s Safe Food for Canadians Regulations webpage.

Private programs

Private food safety programs are offered by private companies. Some examples of private programs are American Institute of Bakers (AIB), British Retail Consortium (BRC), Food Safety System Certification (FSSC 22000) and Safe Quality Food (SQF). Some private programs have been around for a long time and have built up reputations as rigorous and thorough programs.

All food safety programs are based on principles developed by the Codex Alimentarius, which is part of the World Health Organization. Many food safety programs have been created all over the world, based on the Codex principles. However, there is no universally accepted food safety program that has prevailed over the others.

In 2000, many large retailers from across the globe came together to find a consistent food safety program to accept. This was an attempt to reduce the number of different food safety programs and reduce the number of food safety audits that processors must undergo, and to improve consistency between food safety programs. What resulted was the Global Food Safety Initiative (GFSI). GFSI is an organization that “benchmarks” food safety programs by putting the programs through a rigorous analysis. There is now a list of food safety programs that have been benchmarked under GFSI. As a result, there has been a drastic increase of retailers demanding their suppliers be certified to a GFSI benchmarked program (the Global Food Safety Initiative).

You should choose a food safety program that meets your food safety needs and requirements of your buyers. All programs, if adopted and maintained properly, will increase food safety protection and improve marketability for your products. The program you choose may depend on your market reach, buyer demand and level of food safety risk in your facility. The best place to start when choosing a program to adopt is to find out what your buyers require.

Choosing a food safety program

If you intend to pay to have an audit of your food safety program, you will have to decide which one you would like to be audited against (or which program you will follow).

To make that decision, ask yourself a few questions:

What can you afford?

Maybe you just want to adopt the program but not pay for audit/certification. Maybe you have some problem areas in your facility and only want to implement the GMPs that address the problems (for example, personnel and sanitation).

What are your customers requiring?

Assurance that you have GMPs and/or HACCP? They may not require a certificate. GMPs and/or HACCP audited by a third party? There are many auditing bodies that will audit and provide a general HACCP certificate and audit report. A public/government food safety program (for example, FSEP). What is the certification in the specific food safety program? (for example, SQF, BRC).

Checklist

  • I understand food safety concerns and the impact of unsafe food.
  • I understand Good Manufacturing Practices (GMPs) and have devised ways to implement them into my plant operations.
  • I plan to implement a food recall and traceability system.