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Export Certification Control Program Reference

Standard

5.1 Management Roles and Responsibilities

5.1.1 Person responsible

5.1.2 Management Commitment

5.2 Foreign Country Requirements

5.2.1 Fish and Seafood for Export

5.2.2 Foreign Certification Requirements

5.2.3 Foreign Establishment Eligibility Requirements

5.3 Product Compliance

5.3.1 Product Standards

5.3.2 Product Inspections to verify ECCP control measures

5.3.3 Product Inspections to verify the compliance of fish or seafood for

export

5.3.4 Supplier Quality Assurance Program

5.4 Certification

5.4.1 Certificate Requests

5.4.2 Replacement Certificates

5.5 Traceability

5.5.1 Lot accountability

5.5.2 Health and Safety Verification and Notification

5.6 Licensed Establishments of Live and/or Fresh fish and Seafood

5.6.1 Conveyances and Equipment

5.6.2 Establishment Requirements

5.6.3 Sanitation and Personnel Hygiene

5.6.4 Pest Control

5.6.5 Hazard Analysis

5.7 Consignment Storage and Transportation

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5.8 Verification & Maintenance of the ECCP Plan

5.8.1 Ongoing Maintenance

5.8.2 Annual Review

5.9 Maintenance of Records and Documents

5.9.1 Records relevant to the ECCP plan

5.9.2 Amendments to the ECCP plan

Appendix A: Protocol for Partially Completed Certificates Guidelines

1. Purpose

This standard outlines the requirements for the documentation and application of a

system-based export certification control program (ECCP) to ensure fish products for

export comply with the Fish Inspection Regulations (FIR) and with additional foreign

requirements which may apply.

2. Scope

This document applies:

1. In full, to persons or companies applying for, or which already have, a fish export

licence.

2. In part, to registered establishments participating in a system based certification

approach. Only elements 5.1, 5.2, 5.3, 5.4, 5.8 and 5.9 of this reference standard are

required to be incorporated into the establishment's existing Quality Management

Program (QMP).

Note: elements 5.5, 5.6, and 5.7 are already covered in the existing QMP plan but should

be reviewed to ensure completeness.

3. Definitions

Broker

an individual or party that purchases fish or seafood for resale without any further

transformation, including repackaging or labelling.

Certificate

is a paper or electronic document issued by the CFIA that describes and attests to

attributes of consignments of fish destined for international trade.

Certification

the procedure by which official certification bodies or officially recognized

certification bodies provide written or equivalent assurance that food or food

control systems conform to requirements. Certification of food may be, as

appropriate, based on a range of inspection activities which may include

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continuous on-line inspection, auditing of quality assurance systems, or product

inspection.

Consignment

a specific quantity of fish or seafood imported or exported on a single transport

carrier or vessel by one person.

Consignor

On an export certificate, the consignor is the owner or legally responsible party.

Note: If using partially completed certificates, only registered and licenced

establishments requiring partially completed export certificates for Canadian live and/or

fresh fish can be indicated as the consignor.

Control Measures

an action performed to maintain adherence to a standard or to eliminate a hazard

or reduce it to an acceptable level.

Corrective Actions

the procedure that is to be followed whenever the results of monitoring activities

show that there is a lack of compliance with the Fish Inspection Regulations.

Export Certification Control Program (ECCP) plan

the exporter's written description of the control measures and procedures

implemented to ensure that exported fish products comply with the FIR and with

additional foreign country requirements, if applicable.

Foreign country certification requirements

the conditions as outlined on a CFIA recognized certificate that must be met to

satisfy a foreign country's import requirements.

Licensed Establishment

an establishment licensed by the CFIA under the FIR that only washes, ices or

boxes live or fresh unfrozen fish or seafood, or stores finished fish products, for

export.

Lot by Lot Certification

certification that is based on the inspection of a defined lot of product.

Monitoring

a planned observation or measurement of a parameter, at a specified point or time,

which is compared to a standard or requirement.

Quality Management Program (QMP)

a fish inspection and control management system implemented by a registered

establishment that includes procedures, inspections and records for the purpose of

verifying and documenting the processing of fish and the safety and quality of

fish processed in, exported from or imported into Canada (Section 2, FIR).

Registered Establishment

a freezer-factory vessel, barge, onshore plant, building or premise where fish are

processed or stored for export that is registered by the CFIA under the FIR.

System Based Certification

certification based on the exporter's compliance with its export certification

control program plan.

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4. Reference Tools

Fish Inspection Regulations

Export Information By Jurisdiction

5. Elements of the Export Certificate Control Program

(ECCP) Plan

Registered establishments may refer to their written Quality Management Program

(QMP) for certain ECCP elements addressed and develop the remainder of their ECCP

plan as a Standard Operating Procedure (SOP) or equivalent under the Regulatory Action

Point (RAP) component Minimum Acceptable Fish Products Standards.

Non-registered (licensed) establishments must develop a written ECCP plan and submit it

to CFIA for review prior to being issued an export license.

5.1 Management Roles and Responsibilities

Intent

Management must identify and support the person responsible for the design,

implementation and maintenance of the ECCP.

Management must be committed to and supportive of the development, implementation

and maintenance of the ECCP.

Requirements

5.1.1 Person responsible

The ECCP plan must identify the name(s) and/or position(s) of the person(s) or service

provider who developed the program.

The ECCP plan must identify the name or title of the person responsible for the

implementation and maintenance of the program, their business address, e-mail address

and a telephone number where they can be reached in Canada.

5.1.2 Management Commitment

Management must ensure that the ECCP plan is designed, implemented and maintained

by capable personnel. The ECCP must describe the monitoring procedures used to ensure

that the control measures are being correctly and consistently carried out. The monitoring

procedures must clearly specify what is being monitored, how it is being monitored, at

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what frequency, and by whom. The frequency identified for each monitoring activity

must be sufficient to ensure that the standard is being met.

The ECCP plan must include an attestation from management acknowledging their

responsibility for ensuring that the ECCP is designed and implemented in accordance to

the reference standard and acknowledging their commitment to and support for the

ECCP.

The ECCP must also be signed by a senior level manager or the owner of the business

and, if different, the person responsible for the implementation and maintenance of the

plan to acknowledge the commitment to and support for the plan.

5.2 Foreign Country Requirements

Intent

Foreign import requirements must be known in order to ensure the compliance of exports

with these requirements.

Requirements

Exporters must know the foreign import requirements which apply to the fish and

seafood they export.

5.2.1 Fish and Seafood for Export

The ECCP must describe the fish and/or seafood for export, and for which export

certificates are required. This must include (as applicable):

The scientific name of each species.

The production method (wild or farmed).

The descriptive common name.

The attributes and characteristics that are important in ensuring the safety of the

fish or seafood.

The ingredients.

The packaging.

The end use.

The shelf life.

The storage condition (refrigerated, frozen, shelf-stable).

The source of the fish or seafood.

The country of origin of the fish or seafood.

The name of the establishment where the fish or seafood was sourced from.

5.2.2 Certification Requirements

The ECCP must indicate, for each type of product for export:

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The foreign countries of export.

Foreign certification requirements.Footnote 1

The certificate(s) required (recognized by the CFIA).

Note: Though ECCP applies to certificates signed under the Fish Program only, exporters

may also include reference to animal health certificates issued under the National Aquatic

Animal Health Program (NAAHP), especially when those certificates are required in

addition to certificates under the Fish Program.

5.2.3 Establishment Eligibility Requirements

The ECCP plan must indicate, for each country of export, that country's fish and seafood

establishment eligibility requirements, as applicable. For example:

Sourcing of fish or seafood from a federally registered establishment or a licensed

establishment that holds a fish export licence (brokers only).

The posting of the establishment on the list of establishments approved to export

to the foreign country, as applicable.

Sourcing of imported fish or seafood from an establishment eligible to export to

the foreign country, as applicable.

Control Measures

The ECCP plan must describe:

The person responsible to maintain accurate and up-to-date information on the

products exported.

The person responsible to determine and maintain accurate and up-to-date

information on the foreign import and certification requirements.

The measures taken to ensure the eligibility of the product for export (request for

addition to a list of establishments approved to export, review of lists of

establishments approved to export, etc.).

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address

situations where there is a failure to comply with the foreign country requirements. The

system must include corrective actions taken to get back into compliance with the

requirements and to prevent the situation from re-occurring.

5.3 Product Compliance

Intent

Exported fish and seafood comply with established Canadian and foreign standards.

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Compliance with Canadian requirements is assured through the implementation,

maintenance and verification of control measures for the processing, storage, handling

and transportation of fish and seafood in accordance with the Fish Inspection

Regulations.

Compliance with foreign certification requirements pertaining to fish or seafood

standards that exceed Canadian standards, or for which there is no Canadian standard, is

the responsibility of the exporter. A description of how the exporter will ensure product

compliance must be included in the ECCP.

Requirements

The exporter must ensure that all fish and seafood exported comply with Canadian and

foreign standards.

5.3.1 Product standardsFootnote 2

The ECCP plan must indicate the standards the fish or seafood must comply with:

1. Chemical and Microbiological standards, as applicable.

o The Canadian Guidelines for chemical contaminants and toxins and the

Canadian Bacteriological Guidelines, as applicable.

o The foreign standards that exceed Canadian standards, or for which there is no

Canadian standard, if applicable.

2. Labelling requirements.

o The applicable Canadian labelling requirements as outlined in chapter 15 of

the Guide to Food Labelling and Advertising.

o The foreign labelling requirements outlined in the attestations of the certificate

(e.g. registration number).

3. Sensory and Net Content standards.

5.3.2 Product Inspections to verify ECCP control measures

Fish and seafood are subject to inspection by the exporter in order to verify the

implementation and effectiveness of the control measures in place to assure the

compliance of fish and seafood with Canadian and foreign country requirements.

The inspection may be conducted in house when using procedures and methods accepted

by the CFIA and records must be kept of all inspections for all lots certified for export.

5.3.3 Product Inspections to verify the compliance of fish or seafood for export

Fish and seafood must be sampled for inspection in accordance to the procedures outlined

in the Fish Inspection Program Sampling Procedures or equivalent procedures.

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Physical tests such as sensory evaluation, container integrity and net content

determination must be conducted in accordance to the CFIA Fish Products Standards and

Methods Manual and Fish Products Inspection Manual or equivalent procedures.

Fish and seafood may need to be sampled for laboratory analysis when:

There are foreign standards which exceed Canadian standards, or for which a

Canadian standard does not exist;

The importing country has previously rejected product from the exporter

Microbiological and chemical analyses must be conducted by a laboratory accredited by

the Standards Council of Canada (SCC) or by the Canadian Association for Laboratory

Accreditation (CALA) for those analyses. Test results from SCC or CALA accredited

laboratories are recognized by the CFIA as official results.

Note: As per the FIR, fish or seafood found to have in or upon it a poisonous or harmful

substance cannot be re-inspected (the fish or seafood sample cannot be tested again nor

can new samples from the lot be tested).

5.3.4 Supplier Quality Assurance Agreement

Brokers may develop and implement a Supplier Quality Assurance Program (SQA)

agreement with each supplier (registered or licensed establishment) requiring them to

conduct any required product testing to assure compliance of the fish or seafood with

foreign standards.

The SQA must comply with the CFIA Criteria for an Acceptable Supplier Quality

Assurance Agreement.

Control Measures

The ECCP plan must include:

The person responsible for product compliance.

The sampling and inspection procedures followed.

The test methods and laboratories (if applicable) used and standards applied.

A copy of all signed SQAs.

The frequency and process for audit of each SQA.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address

situations where there is a failure to comply with the requirements. The system must

include corrective actions taken to get back into compliance with the requirements and to

prevent the situation from re-occurring.

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5.4 Certification

Intent

Exporters must ensure the accuracy of information provided when requesting a

certificate.

Requirements

Certificates must be requested prior to the product leaving Canada.

An eligible exporter may identify in their ECCP, and give written permission to, a third

party (i.e. freight forwarder) to request certificates on their behalf.

Certificates requested must be approved by the country of export and recognized by the

CFIA.

Certificates can only be issued when the fish or seafood are in compliance with all

applicable requirements of the importing country and the FIR.

The certification information provided must be complete and describe the consignment

accurately.

All lots identified in the consignment, for certification, must be available for inspection

by the CFIA, if necessary.

5.4.1 Certificate Requests

It is the exporter's responsibility to accurately complete the correct certificate(s) for each

consignment. Requests for certificates must be made by the consignor listed on the

certificate (unless a third party has been identified).

Note: Mastering of product from one certificate to another by a broker will no longer be

permitted. If the consignor is not a licensed exporter or a registered plant, then each lot

submitted for certification will be 100% inspected under cost recovery.

The following mandatory information is required on each certificate:

total units and unit size of each lot in the consignment;

product description (size, grade, type);

scientific name of the fish or seafood;

consignee name and address;

consignor name and address;

product identification marks (production code);

mode of transportation.

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The exporter must provide, in writing, the following details if they are not included or

clearly identified on the certificate:

country of export;

recognized certificate type(s);

location of the consignment;

date the consignment is available for inspection;

date the certificate is required (date of departure);

who is to be charged for the certificate (unless otherwise stated, the consignor

identified will be invoiced for the certificate).

5.4.2 Replacement Certificates

A replacement certificate can be requested when:

There is an administration error on a certificate.

A certificate is lost or damaged.

The consignee of the fish or seafood certified has changed.

There is a change in the quantity of product certified.

A replacement certificate can only be requested when the integrity of the consignment

has been maintained.

If the product has been imported into the foreign country, a replacement certificate can

only be issued if the information on the replacement certificate is identical to the original

and the new certificate is intended to replace a lost original. The exporter must also

provide a written explanation on why the replacement certificate is required and the

actions taken to prevent a reoccurrence.

The original certificate is considered void and must be returned to the CFIA. A written

explanation must be provided to the CFIA when a certificate cannot be returned.

A copy of the original certificate (or the original), the replacement certificate issued and a

written explanation of the event must be kept on file at the local CFIA office responsible

for issuing the replacement certificate.

Control Measures

The ECCP plan must describe:

The person responsible for requesting or cancelling certificates.

The person responsible for ensuring certificate requests are valid, complete, and

represent accurately the consignment.

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The person responsible for tracking export certificates received, cancelled,

replaced and the fish or seafood certified.

The process and controls to ensure that the correct certificate is completed and

submitted for signature; the information provided is true and accurate and all

certificates are tracked.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address

situations where there is a failure to comply with the requirements. The system must

include corrective actions taken to get back into compliance with the requirements and to

prevent the situation from re-occurring.

5.5 Traceability

This element is covered in the QMP plans for registered establishments.

Intent

The CFIA must be notified when an exporter receives information that exported fish or

seafood is determined to constitute a hazard to the public.

Information on the distribution of fish and seafood must be readily available to allow for

the rapid recall of fish or seafood determined to constitute a hazard to the public.

5.5.1 Lot Accountability

Requirements

Exporters must be able to identify all the certificates issued to them by the CFIA, the fish

or seafood certified by each certificate, and the status of the lots certified (in inventory or

exported). The distribution of the exported fish and seafood must be traceable to the first

shipping destination to allow for the rapid recall of fish or seafood determined to

constitute a hazard to the public.

For this purpose, a copy of each certificate issued by the CFIA, or the following

information must be maintained for each consignment certified by the CFIA:

the country of export;

the certificate type(s) received;

the certificate number(s);

description of the lots;

the scientific and common names of the fish or seafood;

the method of production (wild caught or farmed)

the name and registration/licence number of the establishment from which the fish

was sourced, if applicable;

processing/packing date(s)/codes;

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the net weight of each unit;

the total net weight of the lots

the storage conditions of the product;

the name and address of each person/company (consignee) receiving the fish or

seafood;

the date the CFIA signed the certificate;

the date the consignment was exported;

the mode of transportation and container number (e.g. by air, by ship).

Replacement certificates received from the CFIA must be linked to the original certificate

which was cancelled.

5.5.2 Health and Safety Verification and Notification

Requirement

When information or a complaint is received that questions the safety of fish or seafood

exported, the validity of the information must be verified to determine whether the fish or

seafood constitutes a hazard to the public.

When the verification indicates that the fish or seafood constitutes a hazard to the public,

the CFIA must be notified within 24 hours.

The following information must be kept on file and provided to the CFIA when the fish

or seafood is determined to constitute a hazard to the public:

the date and time the information was received;

the name, address and telephone number of the person who provided the

information;

the date and time the information was determined to be valid or not;

the date and time the CFIA was notified about valid information;

a description of the investigation conducted;

a description of the results of the investigation;

the actions taken by the exporter in response to a confirmed health and safety

issue.

Control Measures

The ECCP plan must describe:

The person responsible to investigate the information received that questions the

safety of fish or seafood exported.

The person responsible to notify the CFIA within 24 hours when the investigation

indicates that the fish or seafood constitutes a hazard to the public.

The record-keeping process for the information received, the investigation and

CFIA notification.

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A description of the recall process – including the investigation, communication

and recall procedures.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address

situations where there is a failure to comply with the requirements. The system must

include corrective actions taken to get back into compliance with the requirements and to

prevent the situation from re-occurring.

5.6 Licensed Establishments of Live and/or Fresh fish and SeafoodFootnote 3

This element is covered in the QMP plans for registered establishments.

Intent

Establishments must protect from contamination and preserve the quality and safety of

the fish and seafood they export.

Requirements

The fish or seafood must be protected from contamination and cross-contamination from

the equipment, water, air, personnel and any other sources of contamination, including

insect and animal pests. The quality and safety of the fish or seafood must also be

preserved.

5.6.1 Conveyances and Equipment

Conveyances and equipment used to unload and handle live or fresh fish must be

constructed and maintained in such a way that it will not become a potential source of

contaminations. Equipment must be made of materials that are non-corrosive and non-

porous to allow it to be cleaned and disinfected and meet the following requirements:

The equipment and handling practices used during the unloading and handling of

fresh or live fish or seafood must be smooth with no sharp corners or projections

that could pierce, tear or otherwise damage or contaminate the edible portions.

Fish handling equipment or containers and surfaces which come in contact with

fresh or live fish or seafood must be of smooth, non-absorbent, non-corrodible

material free from cracks and crevices that can be easily cleaned and maintained

in a sound condition for ease of cleaning and disinfection.

5.6.2 Establishment Requirements

The establishment must be constructed in a manner that:

Permits adequate cleaning and disinfection (where applicable) of all areas.

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Prevents the accumulation of dirt, contact of the fish or seafood with toxic

materials and floor surfaces, the shedding of foreign particles into fish and the

formation of condensation or mould on surfaces.

Prevents contamination from the equipment, water, air or personnel and any other

sources of contamination, including insect and animal pests.

Provides, if necessary, suitable temperature conditions for the handling and

storage of fish and seafood.

Provide for the orderly and rapid movement of fish and seafood into and out of

the establishment.

The construction and packaging materials and non-food chemical products used in the

construction and operation of establishments and their equipment must be suitable for

their intended use. All non-food chemicals must be clearly labeled, stored in an

appropriate location and only used by a person trained to use or apply it in a manner that

prevents contamination of fish or contact surfaces.

The enclosed establishment must meet the following construction and equipment

requirements:

Floors: Must be constructed of smooth, impervious, non-absorbent and non-toxic

materials, be sloped for drainage and maintained in a sound condition for ease of

cleaning and disinfection.

Drains: Must allow effluent and water to pass though quickly without

accumulation, be covered with non-corrodible covers or grates constructed in a

manner that prevents the entry of pests (insects and animals).

Walls and ceilings: of processing and package storage areas must be constructed

of smooth, non-absorbent, non-toxic washable materials and have sealed joints.

They must be maintained in a sound condition for ease of cleaning and sanitation.

Note: walls and ceilings in a dedicated tank room are exempt from these

requirements.

Overhead fixtures: Must not be a source of contamination.

Tables and other surfaces which come in contact with the fish or seafood: Must be

made of an approved material, resistant to corrosion, smooth and easily cleaned.

Facilities: Must have tightfitting doors and windows and be constructed so as to

prevent the entrance of rodents.

Windows that are capable of being opened, and any other openings to the outside:

Must be constructed so as to prevent the accumulation of dirt and be fitted with

non-corrodible insect-proof and animal-proof screens or other similar devices.

Condensation, in rooms other than live tank rooms: Must be controlled to prevent

contamination of walls, equipment and products from ceilings and overhead

fixtures.

Toilet facilities: Must be available in the establishment adjacent to the fish or

seafood handling area in the establishment, maintained in good operating order

and be properly equipped with toilet tissue.

Hand-washing facilities: Must be located adjacent to the toilet facilities, and must

be equipped with hot and cold running water, soap and single-service towels.

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Water: an adequate supply of fresh water and/or sea water from an acceptable

source must be available for employee hygiene and establishment clean-up.

Water used for unloading, washing, storing or transporting fresh fish: Must be

from an acceptable source.

Ice: Must be made with acceptable water, handled and transported, both inside

and outside the establishment, in a manner that prevents its contamination.

Offal Receptacles: Must be clearly identified as "For Offal Only", and be

constructed of an approved material.

Lighting: Adequate lighting must be available in the processing areas. Lighting

fixtures must have covers to prevent breakage and be designed to be easily

cleaned and disinfected to prevent contamination of work surfaces and products.

Coolers must maintain fish and seafood at a temperature from 4°C to -1°C.

The construction and equipment requirements are applicable to all new licensed

establishments (excluding LLCP holders).

Note: for existing facilities that only hold live fish (e.g. lobster and crab).

Wood floors, open wall studding and wood tables will be tolerated provided they

are in good repair and can be kept clean.

Toilets do not have to be in the establishment but must be readily available.

Hand wash facilities must be available (hot water and pressurized water is

recommended), maintained in good operating order, and properly equipped with

single service towels.

Even though these conditions will be tolerated for existing live fish facilities, as

equipment is replaced or facility repairs and renovations are made, compliant materials

and construction must be used to bring the establishment into compliance with the FIR.

5.6.3 Sanitation and Personnel Hygiene

Establishments must develop and implement a sanitation and hygiene program to ensure

that the employees of the establishment or the users of the conveyance or equipment use

proper sanitation and hygiene practices, and that the establishment, grounds, equipment

or conveyances are maintained in a clean and sanitary condition and free from serious

contamination and insect and animal pests.

Cleaning/disinfecting equipment and supplies must be available to ensure that the

sanitation program can be carried out as written. Chemical products for use in cleaning

and disinfecting must not be allowed to contaminate the live animals or food products.

No person who is a known carrier of a disease that is likely to be transmitted through

food or who is afflicted with an infected wound, skin infection, sore, diarrhea or any

communicable disease, can work in the handling areas if there is a possibility of

contaminating fish with pathogenic organisms.

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The sanitation and hygiene program must describe:

The person(s) or positions responsible for the program.

The frequencies of cleaning and sanitizing.

The disassembly/reassembly of equipment required for cleaning, disinfecting,

lubrication, if applicable.

The procedures for cleaning, disinfecting, and rinsing.

The lubricants used if applicable.

The cleaning/disinfecting equipment and chemicals used (must be suitable for

their intended use).

The instructions for the use and application of cleaning/disinfecting chemicals

(concentrations, temperature of use, duration of application in accordance with the

manufacturer's instructions).

5.6.4 Pest Control

The establishment must be free of pests:

The grounds in proximity to the establishment must be kept clean, free from

debris and unnecessary material and be maintained to minimize harborages for

insect and animal pests.

It is recommended that the surrounding area be surfaced and adequately sloped to

prevent accumulated pools of water.

Areas where fish is loaded, unloaded or handled and other high traffic areas

should be paved with asphalt, covered with concrete or other impervious material

and equipped with appropriate drains.

The establishment and the immediate vicinity must be monitored for the presence

of pests, including insects and rodents. The monitoring procedures and persons

responsible to monitor for pest activity must be documented.

Pesticides or any other animal control products must be applied in a manner that

prevents the contamination of the consignment.

Pest control procedures must be implemented when pests are detected.

Where a pest management program is contracted to a third party, documentation

provided by the pest control company as to the activities conducted and types of

pest control used including a map of rodent traps, bait stations, and other control

devices, must be maintained.

Documentation related to the approval and application of insecticides must be

maintained.

5.6.5 Hazard Analysis

A hazard analysis of each process step, from the time the fish or seafood is caught or

received to the time it is transported for export must be conducted. A Hazard Analysis

Worksheet, or equivalent, must be used to document the hazard analysis.

All potential hazards (biological, chemical, physical) which may be present or introduced

must be identified for each step and the significance of the hazard determined (i.e.

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consideration of its severity, the likelihood of its occurrence or increase to an

unacceptable level). Justification must be provided when a hazard is identified but

determined to not be significant.

Where a hazard has been identified to be of significance, a Hazard Analysis Critical

Control Plan (HACCP) must be developed and documented identifying each hazard

determined to be of significance and the process step where it was identified as a Critical

Control Point (CCP). For each CCP:

Preventive measures must be implemented to prevent or eliminate the hazard or

reduce it to an acceptable level.

Critical limits must be established (i.e. the maximum or minimum value to which

a hazard must be controlled). The critical limits must be validated to demonstrate

that they are effective and the validation documented.

Monitoring procedures must be implemented to verify the application and

effectiveness of preventative measures.

Verification procedures such as the review of records or additional testing must be

established to verify the implementation of the HACCP plan.

Records of the CCP monitoring activities, corrective actions and verifications completed

must be maintained. These records must be initialed or signed and dated by the person

responsible for them.

Corrective Action Requirements

Corrective action procedures must be established to address deviations, from the critical

limits, identified during the monitoring of a CCP. The corrective actions must identify

and correct the deficiency that resulted in the deviation, identify and segregate any

product affected and prevent or reduce the likelihood that the deficiency will reoccur.

5.7 Consignment Storage and Transportation

This element is covered in the QMP plans for registered establishments.

Intent

Consignments must be protected from contamination and their quality and safety

preserved during storage and transportation.

Consignments must be stored and transported under secure conditions to prevent product

loss or substitution.

Requirements

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Consignments must be stored and transported under conditions that comply with the Fish

Inspection Regulations.

The walls, floors and ceilings of storage and transport facilities, where appropriate, must

be of a suitable corrosion-resistant material with smooth non-absorbent surfaces that can

be adequately drained and cleaned.

Consignments must be protected from contamination, exposure to extreme temperatures,

the sun and wind.

Live fish are to be stored and transported at temperatures appropriate for the species.

Fresh fish and seafood must be maintained chilled at a temperature at or below 4°C.

Frozen fish must be kept frozen to at least -18 °C and protected to ensure that the

temperature of the fish does not increase by more than 5.5°C during loading, transport

and unloading.

Control Measures

The ECCP plan must describe the process and the person responsible for ensuring the

integrity, quality and safety of the fish or seafood is maintained during loading, storage

and transportation.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address

situations where there is a failure to comply with the requirements. The system must

include corrective actions taken to get back into compliance with the requirements and to

prevent the situation from re-occurring.

5.8 Verification & Maintenance of the ECCP Plan

Intent

The ECCP plan must be maintained up-to-date and be effective in ensuring the

compliance of the fish or seafood exported and the export certificates issued.

Requirement

The ECCP plan must be verified to ensure the controls are up-to-date, comply with the

requirements and are effective in ensuring the integrity of the certification of fish or

seafood.

5.8.1 Ongoing Maintenance

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The plan must be updated when:

There is a change to the ECCP reference standard or the export profile (e.g.

foreign markets, foreign requirements, export certificates, fish or seafood for

export).

There is a change in the control measures or monitoring procedures.

5.8.2 Annual Review

All the elements of the ECCP plan must be reviewed annually to verify that the plan

continues to comply with the requirements and is effective in ensuring the compliance of

the fish or seafood exported and the export certificates issued.

Control Measures

The ECCP plan must describe the process and the person responsible for the ongoing

maintenance of the plan.

The ECCP plan must describe the process and person responsible for the annual review

of the plan to ensure that it is up-to-date, complies with the requirements and is effective.

Corrective Action Requirements

The ECCP plan must describe the corrective action system to be followed to address

situations where there is a failure to comply with the requirements. The system must

include corrective actions taken to get back into compliance with the requirements and to

prevent the situation from re-occurring.

5.9 Maintenance of Records and Documents

Intent

Records must be maintained to demonstrate that the ECCP plan is effective, implemented

as designed, can identify issues, and is up-to-date.

5.9.1 Records relevant to the ECCP plan

Requirements

Records relevant to the implementation, monitoring and verification of the ECCP plan

must be maintained.

Records must be up-to-date, legible, comprehensible, easily accessible, and stored in one

location in a manner which protects their integrity.

The record maintained should provide evidence that the ECCP plan is effective,

implemented as designed, can identify issues and is up-to-date.

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When electronic records are used, specific controls must be developed for the creation

and maintenance of electronic signatures that meet the requirements of CFIA's Guidelines

for the Use of Electronic Records and Signatures.

Records must be retained for at least three years.

5.9.2 Amendments to the ECCP plan

Requirements

A log of all amendments to the ECCP Plan must be maintained to ensure that documents

are up-to-date and accurate.

Note: Amendments to an acceptable ECCP do not have to be submitted to the CFIA prior

to implementation.

The amendment log must identify any changes for the last three years.

Control Measures

The ECCP plan must describe the process and person responsible for amending and

recording amendments to the plan.

The ECCP plan must identify the address in Canada where all records and documents

relevant to the ECCP plan are maintained.

Appendix A: Protocol for Partially Completed Certificates Guidelines

Footnotes

Footnote 1

When the CFIA is not aware of any specific foreign certification requirements, it

is the primary responsibility of the exporter to obtain and provide information to

the CFIA on the foreign country requirements. The CFIA then determines if the

requirements can be met and may negotiate a mutually acceptable certificate with

the foreign authorities, as applicable.

Return to footnote 1 referrer

Footnote 2

An exemption permit under the authority of section 18 of the FIR may be required

for the exporting to another country of fish or containers that do not meet the

applicable requirements of the Act or these Regulations (e.g. labelling

requirements) but that comply with the requirements of the importing country.

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Return to footnote 2 referrer

Footnote 3

Wash, ice, box live or fresh unfrozen fish or seafood.