Having been the former editor and primary writer of Quality Assurance & Food Safety magazine for more than 15 years, and science and regulatory writer for The Acheson Group (TAG) since 2010, I have been fully immersed in everything Food Safety Modernization Act (FSMA), from the causes for its enactment to the decades-long publication of its rules. But as so often happens, just as you feel you have something fairly well down pat, something changes.
In this case, it wasn’t the regulation that changed, it was my focus. That is, although TAG has long had a presence in Canada, it was just this year that TAG Canada became a fully Canadian business entity. So, as director of communications, one of my roles is now to expand our focus on Canada-specific communications — including that of its regulations. Although the Safe Food for Canadians Regulations (SFCR), which came into force Jan. 15, 2019, has the same essential goals as FSMA — to update, improve and enhance food safety — there are significant differences between the two regulations, their enforcement bodies and the countries in which they operate.
Add the fact that I, along with the rest of the industry, has had 10 years to absorb, understand and communicate the gradually evolving food safety regulations of the United States, where I’ve spent my life. In contrast, having visited only three of Canada’s 10 provinces for a grand total of perhaps two weeks throughout my adult life, I have now been striving to learn, understand and communicate not only Canada’s regulations, but its governing agencies (Health Canada and the Canadian Food Inspection Agency [CFIA]), the country and its people, and even its terminology and spellings — in as short a time as possible.
While I have the advantage of having in-house TAG Canada resident experts on whom to call, the experience is enabling me to more closely identify with food producers who are new to the industry, are just beginning to import to Canada or don’t have the in-house resources or a strong science background to assimilate and apply the many intricacies of the regulations — on either side of the border.
So what are the key takeaways that I would pass along for anyone doing business in or with Canada? Most importantly, though likely as one would expect, the SFCR applies to both food that is manufactured in Canada and that which is imported into the country. Additionally:
• All domestic and imported foods are regulated in Canada through the CFIA and Health Canada (but in a much different way than the Food and Drug Administration and U.S. Department of Agriculture regulate U.S. foods). CFIA is responsible for assessing, administering and enforcing the federal food safety and quality policies, regulations, standards and guidelines that are set by Health Canada.
• While FSMA has seven major rules, the SFCR has four key elements: Preventive Controls, Licencing, Traceability and Importing/Exporting.
• Although both FSMA and the SFCR Preventive Controls provisions have written plan requirements, the FSMA Food Safety Plan and SFCR Preventive Controls Plan requirements are not identical.
• SFCR brought in new regulations for licensing, with specific licences required for specific activities (e.g., importing, manufacturing, processing, treating, packaging).
• Speaking of licences — the above spellings are correct. In Canada license is a verb; licence is the noun.
• Similar to the requirements of the Bioterrorism Act in the U.S., SFCR requires one-forward, one-back traceability for most food businesses except foodservice establishments.
• The SFCR also carries new requirements for any business or individual importing food into Canada, including that of licensing.
If you ask me this same question a few months down the road, I will likely have a great deal more to relate. Meanwhile, I will continue my studies of Canadian food, regulations and people with the goal of having as firm a grasp on these as I do on those of the U.S. — although I’m unlikely to schedule a Reddit AMA (ask me anything) on either any time in the foreseeable future!