Selecting and Purchasing Product
Section 19.1 (Selecting/Purchasing and Receiving Harvested/Market Product) of the CanadaGAP Manuals states “The person responsible selects/purchases harvested/market product from operations that have successfully completed one of the options below and requests a copy of a current/valid certificate:
- CanadaGAP®
- Other industry recognized third party food safety audit/certification”.
Some exceptions apply for cucumbers and peppers sent for pickling AND repacking, wholesaling and brokerage of fiddleheads; see the CanadaGAP manual for details.
The program requires that the operation ONLY get either a copy of the operation’s CanadaGAP certificate or other industry recognized third party food safety audit/certification. It is expected that the operation has one current/valid certificate per season per supplier. This is the minimum. No other documents (e.g., CanadaGAP manuals, CanadaGAP audit reports), records (e.g., agricultural chemical applications), etc. are required by the program. Based on their own assessment of risk or customer expectations, operations may decide or may be required to ask for more from their suppliers (e.g., additional documents, records, etc.).
The CanadaGAP auditor will ask the operation about their product suppliers and check the approval systems/procedures they have in place. The operation will be responsible for showing and explaining how they source product from suppliers and how they manage those supplier certifications.
One aspect of this evaluation is reviewing the food safety certificates. In some cases, the auditor will be able to see all of the food safety certificates on file, but depending on the situation, a sampling of the certificates could also be appropriate. In these cases, there is not a set number of certificates that need to be reviewed by an auditor.
The number of certificates sampled depends on a wide variety of factors including:
- How robust the operation’s product supplier approval program is,
- The total number of suppliers that an operation has (i.e., an operation with more suppliers in total would generally require a greater number of certificates to be reviewed),
- The commodities that are being supplied to the operation (e.g., low risk products vs high risk products, one commodity from many suppliers vs 20 commodities from many suppliers),
- The location of the suppliers,
- Previous history of the suppliers (e.g., a supplier that did not have a food safety certificate the previous year, a new supplier, etc.),
- The food safety program the supplier is certified under (e.g., CanadaGAP, another GFSI third-party certification, another country’s food safety program’s certificate, a CFIA inspection audit report, etc.)
There are many different situations that auditors will encounter, but for example; an operation sourcing potatoes from 100 CanadaGAP suppliers may need to have fewer certificates sampled than an operation sourcing leafy greens from 100 suppliers that have a variety of food safety certificates.
The auditor is then expected to assess the food safety audit/certificate for accuracy and validity. Factors auditors may consider during the assessment include:
- What commodity is the certification for? Does it match the scope of what is being supplied?
- What activity is the supplier certified for? Does it make sense in terms of what is being supplied? For example, the supplier is certified for “production”. They are a producer who is growing apples and they supply to a packer
- Is the certificate/report valid (e.g., the expiry date has not elapsed)?
- Is it a food safety certification program? Is it a HACCP program? The intent is that the supplier is following a program that has food safety practices and processes in place (like the CanadaGAP program) in order to mitigate the risk of contamination
- Is it an inspection with an audit report? Conducted by a credible body? An industry recognized third-party? The intent is that the report will contain an overview of the assessment conducted and that the food safety practices and processes in place were assessed thoroughly.
If these factors are not clearly outlined on the audit/certificate and/or the auditor has questions about the certification, it is the responsibility of the operation to investigate further and be able to provide sufficient information/evidence to answer the auditor’s questions. The auditor does not need to research all of the food safety certification options available.
Yes. The operation would need the current/valid CanadaGAP or other third party industry recognized audit/certification from the operation providing the product.
Outside Service Providers
An outside service provider is someone who performs an activity that the operation would otherwise perform himself. “On behalf of” is the key phrase used and means in reference to the activities being provided by someone else, these are activities that the operation would otherwise be responsible for doing themselves within their certification scope.
For example, if an operation is certified for “Production”, the following activities would normally be included in the scope of their certification: growing, harvesting, putting harvested product into harvested product packaging materials, cooling, rinsing, storing, etc.
If the operation outsourced one of those activities, a certificate would be needed from the outside service provider.
Scopes of Certification:
Production: Activities (e.g., growing, harvesting, putting harvested product into harvested product packaging materials, cooling, rinsing, etc.) involved with harvested product. The production operation may or may not store and/or transport product.
Packing: Includes:
(i) The physical act of taking harvested product and putting it into market ready packaging materials for the first time (both in the production site and in the
packinghouse). This does not include re-packing. Note for the purposes of the certification scope, putting product into harvested product packaging materials at harvest is not considered “Packing”.
(ii) Activities (e.g., icing, labelling/coding, cooling, etc.) that occur once product is in the packaging materials.
The operation involved with packing may or may not store and/or transport packed product.
Repacking: Includes:
1) Removing market product from its market ready packaging materials, re-handling the product (e.g., re-sorting, re-grading, re-trimming, re-washing, re-fluming, etc.), and putting it into market ready packaging materials. Product may also be combined with other product that differs in some way (e.g., type, origin, timeframe, etc.).
2) Activities (e.g., icing, labelling/coding, cooling, etc.) that occur once product is in the packaging materials.
The operation involved with repacking may or may not store and/or transport product.
Wholesaling: Activity where operations are involved ONLY in storage of market product (see definition of “storage”). The operation may or may not transport product.
Brokerage: Activity where the operation is ONLY involved in arranging the transaction of product between a supplier and a buyer. The brokerage operation does NOT physically handle the product in any way. The person responsible for brokerage is the “broker”.
Examples:
Below are some examples where an outside service provider would need to provide the operation with a certificate:
a) If the operation is certified for “Production” – harvesting is an activity the producer would complete themselves. If they use an outside service provider for harvesting, they must follow the requirement.
b) If an operation is certified for “Production” – storing is an activity the producer would complete themselves. If they use an outside service provider to store product, they must follow the requirement.
c) If an operation is certified for “Packing” – icing is an activity the packer would complete themselves. If they use an outside service provider to ice the product, they must follow the requirement.
d) If an operation is certified for “Packing” – labelling is an activity the packer would complete themselves. If they use an outside service provider to label the product, they must follow the requirement.
Therefore, activities that are certifiable within a CanadaGAP scope that are conducted “on behalf” of the operation would need the outside service provider to provide a certificate.
Service providers that carry out activities that are beyond of the certified operation’s CanadaGAP scope would NOT be considered as an “outside service provider”.
Examples:
- For an operation certified for only “Production”: since packing is an activity a producer would NOT complete as part of his scope, as operation that sends product to a packer would not have to get a certificate from the packer. (Note: production site packing is considered “packing”).
- For an operation certified for only “Packing”: since wholesaling (as defined by CanadaGAP) is an activity a packer would NOT complete as part of his scope, an operation who uses a wholesaler to distribute product would not have to get a certificate from the wholesaler.
Therefore, a producer certified for Production (only) would not consider his packer, wholesaler, repacker or broker as an “outside service provider” conducting activities on his behalf. A packer certified for Packing (only) would not consider his wholesaler or broker an “outside service provider”. A wholesaler certified for Wholesaling (only) would not consider his broker an “outside service provider”.
Yes. An operation can use an outside service provider to perform activities on their behalf (e.g., harvesting, packing, icing, washing, storing in a standalone storage operation, etc.).
The outside service provider must have either CanadaGAP certification, or another industry recognized third party food safety audit/certification. This would be the case regardless of whether or not the product ever comes back from the outside service provider.
Examples:
- Producer receives a certificate from a standalone storage operation.
- Producer receives a certificate from a harvesting operation.
- Packer receives a certificate from an “icing” operation.
- Packer receives a certificate from another packer.
- Wholesaler receives a certificate from another wholesaler.
The program requires that the operation get either a copy of the CanadaGAP certificate or other third party food safety audit/certification from every service provider.
The certificate alone may not contain all of the necessary information that is required nor be clear enough to ensure that the outside provider is performing the intended service. Therefore, it may be necessary to have the entire audit report or other supporting documentation available for review during an audit.
Section 19.1 (Selecting/Purchasing and Receiving Harvested/Market Product)
- If services are selected/purchased from an outside service provider to perform activities on behalf of the person responsible (e.g., harvesting, packing, icing, washing, storing in a standalone storage operation), regardless of whether product comes back from the service provider, the person responsible obtains a copy of a current/valid certificate (one certificate per season per service provider) (File under Tab: Letters of Assurance/Certificates):
- CanadaGAP
- Other industry recognized third party food safety audit/certification
The auditee would be scored in Question P2 of the CanadaGAP audit checklist. If ANY certificate is missing for any service(s) being outsourced, the most the operation can receive during an audit is 5/10 for this question. The auditee must have a valid food safety certificate/third party report from ALL outside service providers for EACH service provided.
In addition, if the auditee does not have a certificate from an outside service provider performing an activity, then the Certification Body must be informed after the audit, and the relevant activity will be excluded from the operation’s certificate. An operation that is using the services of an uncertified/unaudited service provider will have a certificate that states that the outsourced activity is excluded from the scope of certification.
If operations in Options A1 or A2 indicate during the completion of their self-declaration and self-assessment checklist that they are not meeting the requirements for outside service providers, the Certification Body will be informed, and that activity will be excluded from the scope of their certificate.
Environmental Monitoring Programs (EMPs)
An environmental monitoring program (EMP) is an operation-specific program that helps to assess the effectiveness of sanitation practices and provides information for preventing potential microbial contamination of product.
An EMP risk assessment must be completed by all operations who:
- Are enrolled in certification options B, C, D, E or F
AND
- Handle or store market product, which is produce that is in market ready packaging materials. It may be packed in the production site or packed/repacked in the packinghouse.
Step 1: The operation should read the risk assessment criteria carefully and check off the appropriate boxes as the assessment is carried out for each of the items, areas, etc. that pertain to their operation. The assessment is site-specific as it is dependent on factors such as commodity, equipment, facility, and the operation’s procedures.
Step 2: Once the operation’s risks have been determined, each listed section of the manual will be assessed to determine if the procedures that are already in place, are adequately controlling the identified risk. During the audit, the auditor will verify the provided documentation through observation of the premises and records and by interviewing the person responsible for the operation and for the EMP (risk assessment).
Based on the risk assessment, each operation will determine whether there is a need to take further measures (e.g., swabbing, testing) to confirm the cleanliness of the environment or the effectiveness of sanitation. It may be possible to conclude from the risk assessment that a sampling plan is NOT necessary. In that case, the auditor will verify the justification for this decision during the audit through interviewing, observation and review of records.
The operation can follow the guidance in Appendix X as well as utilize the many resources listed as a source of help to improve the operation’s sanitation practices. Remember, an EMP is used to assess the effectiveness of sanitation practices. During the audit, the auditor will review the sampling plan developed and any applicable results. If the results had indicated that further action was required, those will also be evaluated along with the relevant documentation.