Each individual operation is expected to conduct its own mock recall to achieve certification.
Every operation is required to complete the allergen section (including Form S). The simplest way for operations to complete the requirements is to use Form S. They will begin by looking at all of the potential allergens listed in the left hand column in the Form and assess whether or not they are present in their operation. If the allergen is present, the person responsible should answer YES in the appropriate spot in Columns I – V (where applicable). If the allergen is not present, they should answer NO. It may be possible for an operation to end up with a NO answer for every box.
If an operation does answer YES in one of the boxes, they must keep product free from cross-contamination (if possible). This would mean keeping the product and potential allergen separate (not on top of, underneath, or touching). Any control measures being used should be recorded in the last row of Form S. The program does not require additional corrective measures at this time (e.g., stopping a certain practice etc. if it presents an allergen risk).
By completing Form S, the operation has done an assessment of potential allergens and shown their due diligence. Once Form S has been completed, the person responsible should then go to Section 23.6 (Allergens) and check off the boxes in that section. Auditors will be looking for a completed Form S and Section 23.6 when scoring this requirement in the Audit Checklist.
Some examples of potential allergen situations in operations could be:
- storing milk or dairy products in the same cooler as fruits and vegetables
- egg producer who is also a fruit and vegetable producer
- using peanut butter or cheese inside “tin cat” traps for rodent control
- soybeans grown in fields adjacent to fruit and vegetable production
- mustard/mustard seed grown in production sites in rotational years
It should be noted that these practices may still take place, but that they need to be noted on Form S, and where possible, measures should be taken to reduce cross contamination.
No, employees’ lunches and snacks do not need to be considered in the allergen assessment section of the manual. Hazards associated with employees eating in the lunchroom/break area have already been covered in the manuals with the requirement that a designated lunchroom/break area is provided that is separate from controlled access areas. Employees will also mitigate the risk as they are required to wash their hands before returning to work.
The science regarding allergens being present in agricultural chemicals and then remaining on the product is not well documented at this time. The CanadaGAP program requires only that operations show their due diligence by recording information for allergens on Form S. Beyond that, the program does not require that these agricultural chemicals not be used. This may change in the future if the science shows there is a need to. So, for now operations need to fill out Form S (Column I – present in production practice) and have the information documented. This also means that declaring these allergens on the product/packaging label is not required at this time.
No, latex gloves are not allowed (due to allergens). Forms C and D describe the types of gloves that may be used depending on if they are used in the production site, packinghouse or product storage.
Food fraud is the deliberate and intentional substitution, addition, tampering or misrepresentation of food, food ingredients or food packaging, labelling, product information or false or misleading statements made about a product for economic gain that could impact consumer health. The only types of food fraud that the CanadaGAP program is concerned with are those that impact food safety. Some examples of food fraud where food safety may be impacted include watermelons injected with forchlorfenuron to increase size, carbide used in fresh fruits to ripen them more quickly, oxytocin injected into produce to keep it looking fresh, bleaching mushrooms to improve appearance, replacing an agricultural chemical with a different chemical, dyeing soy beans green and selling them as green beans (i.e., an allergen risk), and harvesting toxic weeds with leafy greens.
The requirements for Food Fraud are outlined in Section 23.7 (Food Fraud). All operations must assess potential food fraud vulnerabilities by completing Form U and must implement any food fraud mitigation measures identified on this form. The questions on Form U are to be answered using a common sense approach. The operation needs to demonstrate that they are mindful of what is being asked about their product, company, suppliers and inputs. At this time, operations are not expected to provide any additional documentation. The completion of Form U shows an operation’s due diligence and awareness of food fraud.
More detailed information about Food Fraud can be found here.
Food Fraud differs from Food Defense; therefore, both are expected to be considered within the CanadaGAP program. Both involve intentionally adulterating product, but the motivation and risks differ. Refer to Section 23.7 (Food Fraud) and Section 23.5 (Food Defense) for specific requirements.