The Three Pillars of SFCR
While there are many provisions in the Safe Food for Canadians Regulations (SFCR), the three fundamental new elements that are of particular interest to most food businesses are licencing, preventive controls, and traceability. Following are overviews of each and links for more information.
LICENSING. Under SFCR, food businesses need a licence based on the activities they conduct. The licence authorizes a food business to conduct an activity identified in the licence and enables the CFIA identify food businesses, collect information about the activities of food businesses, and take responsive action when non-compliant activities are found. Food businesses are required to obtain a licence if they:
Import food. (While most licenced companies will be Canadian businesses, U.S. business that export food to Canada also may hold an SFCR licence.)
Manufacture, process, treat, preserve, grade, package, or label food to be exported or sent across provincial or territorial borders.
Export food that requires an export certificate – even if not preparing the food.
Slaughter food animals from which meat products are derived for export or to be sent across provincial or territorial borders.
Store and handle a meat product in its imported condition for inspection by the Canadian Food Inspection Agency (CFIA).
To apply for a licence, a business must submit an application to the CFIA including activities for which a licence is being sought, location(s) of establishment(s) where the activities will be conducted, types of foods for which a licence is being sought, and attestation that they have preventive controls in place. For more information, see TAG’s SFCR Licensing article and the MyCFIA portal. You also can use CFIA’s interactive licensing tool to determine if and when you need a licence.
As the main regulatory framework for food safety systems, the Preventive Controls part contains the majority of the food safety provisions in the SFCR, the Preventive Controls part describes key food safety control principles that must be met by all food businesses. It also outlines the requirements for developing, implementing, and maintaining a written preventive control plan that documents how food businesses meet food safety, humane treatment and consumer protection requirements.
Defined as “a combination of measures that form a system to control risks to food and to humane treatment of food animals during slaughter activities,” the preventive controls related to food safety are based on the internationally accepted HACCP, as outlined in Codex Alimentarius General Principles of Food Hygiene CAC/RCP 1-1969. The preventive controls related to the humane treatment of food animals from which meat products are derived are aligned with the recommendations of the World Organization for Animal Health’s Terrestrial Animal Health Code – Slaughter of Animals.
Preventive Controls includes six sections:
Interpretation and Application. Provides the definitions specific to this part.
Biological, Chemical and Physical Hazards. Requires the determination and control of these hazards that present a risk of contamination to the food.
Treatments and Processes. Requires a scheduled process to be applied to a low-acid food packaged in a hermetically sealed container if it is not refrigerated or frozen after processing.
Maintenance and Operation of Establishment. Requires these in a way that meets the preventive control requirements, including operator responsibilities; sanitation, pest control and non-food agents; conveyances and equipment; establishment conditions; unloading, loading and storing; worker training/competency; and hygiene
Investigation, Notification, Complaints, and Recall. Requires an investigation if a potential non-compliance or food safety issue is identified; immediate CFIA notification and action when there is a risk to human health; written procedures to handle and investigate complaints; and written and tested recall procedures.
Preventive Control Plan (PCP). Under sections 86 to 89 of the SFCR, food businesses are required to prepare, keep and maintain a written PCP, with exceptions for some small businesses. The PCP must detail how risks to the food and to the humane treatment of food animals are identified and controlled, including elements relating to packaging, labelling, grading, and standards of identity.
TRACEABILITY. The traceability requirements are based on Codex Alimentarius principles, requiring that food be traced forward to the person to whom the food (the immediate customer) and backward to the immediate supplier (one step forward, one step back). Some of the traceability requirements also apply to retail (excluding restaurants or other similar enterprises) which are required to trace the food back to the immediate supplier, but not forward to the consumer. Traceability requirements include specifications on:
Who needs to comply with the traceability requirements.
What information must be set out in traceability documents to identify the food, such as common name of the food and lot code or other unique identifier, as applicable.
How long traceability documents must be kept, and when the documents must be provided.
Labelling requirements to enable traceability.
Overall, the SFCR generally applies to food for human consumption (including ingredients) that is imported, exported, or inter-provincially traded for commercial purposes. It also applies to the slaughter of food animals from which meat products to be exported or inter-provincially traded may be derived, along with some commodities that were not previously targeted by CFIA programs. These include non-meat, dairy, eggs, seafood, processed fruit and vegetables, and many common foods such as cereals, confections, baked goods etc.
About The Acheson Group (TAG) -
Led by Former FDA Associate Commissioner Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG's team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. Learn more at: www.AchesonGroup.com