Canadian Food Safety and Quality Program:
Food Safety Initiative
Traceability Program

Traceability Grant Program and Traceability Pilot Project
Program Guidelines

1.0 Definitions:

• Program: refers to both the traceability grant program and the traceability pilot project, as components of the Food Safety Initiative.
• Minister: the Ontario Minister of Agriculture, Food and Rural Affairs (OMAFRA) and the Minister's authorized representative(s).
• Program Administrator: a representative of the Ontario Ministry of Agriculture, Food and Rural Affairs designated by the Minister to administer the Program.
• Facility Level Traceability System: a system that supports one level up/one level down traceability information at a specific Facility.
• Can-Trace Data Standards: the minimum data required to support a one-up/one-down traceability system. They are shown in Schedule A and can also be found at www.can-trace.org (report: Canadian Food Traceability Data Standard, version 2.0)
• Facility: small or medium sized enterprise and/or operation that has less than one hundred employees, counting both full and part time personnel.
• Applicant: the Facility that is applying to the Program.
• Eligible Costs: expenditures that are eligible for cost-shared payment under the Program. Eligible Costs are listed in Section 3.3 of the guidelines.
• Primary Packaging Manufacturer: manufacturers who produce packaging material that comes into direct contact with food or beverage.

2.0 Applicants:

To apply to the Program, an Applicant must meet all of the following criteria:

• be an Ontario grower, primary producer, processor, distributor, transporter, supplier of inputs to production, or Primary Packaging Manufacturer of food or drink for human consumption (e.g. farm, livestock carrier, grain elevator, auction barn, fairs, processing facility, rendering facility, source of soil amendments);
• be a small or medium sized Facility;
• have a valid Revenue Canada Business Number (GST Number);
• licensed to operate in Ontario if required (e.g. meat, poultry and dairy).
• notwithstanding the first four bullets of section 2.0, processors of pet food, fish or shellfish
  are not eligible to apply.
• an applicant must remain in compliance with traceability national/provincial program standards where they exist when implementing this Program. (e.g. cattle, sheep) Only equipment that has been tested and approved for use in Canada will be considered as an eligible cost under this Program.

Section 3 - Applies to traceability grant program ONLY

3.0 Traceability grant program:

3.1 Objective: The purpose of the traceability grant program is to increase the implementation of Facility Level Traceability Systems along the food industry, from farm to processing, and all points in between. Under this component of the Program, successful Applicants will be expected to develop a Facility Level Traceability System following the Can-Trace Data Standards (see Schedule A).

3.2 Obligations of successful Applicants: Applicants will be required to provide proof of
implementation of the Facility Level Traceability System by submitting the required
documentation as outlined in Schedule B, using Can-Trace Data Standards (Schedule A).

3.3 Eligible Costs:

• consultant fees for development and implementation of the Facility Level Traceability System;
• staff costs directly related to development of the Facility Level Traceability System (e.g., wages for traceability coordinator during development and implementation);
• materials and supplies for traceability plans and/or manuals;
• labour costs directly associated with the implementation of the Facility Level Traceability System;
• equipment purchases and software costs required for the implementation of the Facility Level Traceability System;
• infrastructure changes, as strictly required for the implementation of the Facility Level Traceability System;
• related staff training costs; and
• without prior notification to applicants, Eligible Costs may be added to or deleted by the Program Administrator over the course of the Program to better reflect the objectives of the Program. Items previously approved will be honoured as per outlined in an Applicant's eligibility letter.

3.4 Ineligible Costs:

• federal and provincial taxes, including the non-refundable portion of GST;
• costs being reimbursed under an existing government program;
• costs for the purchase/rental/lease of buildings related to the facility level traceability system;
• product identifiers (e.g. ear tags); and,
• any other expense, which at the discretion of OMAFRA, is deemed to be ineligible.

3.5 Payments:

• payments under the Program may be provided to eligible Applicants to cover seventy five percent (75%) of their Eligible Costs (section 3.3) up to a maximum payment of $20,000.
• Eligible Costs incurred from January 15, 2007 up to the receipt/documentation deadline indicated in Section 3.7, will be considered for cost sharing;
• payments may be provided to eligible Applicants after Eligible Costs have been incurred; appropriate sufficient documentation for proof of payment (such as receipts, copies of cancelled cheques, bank records, etc.) to establish the sufficiency of the payment and supporting documents for proof of implementation of the Facility Level Traceability System (see Schedule B) have been submitted;
• prior to any payment being made, the Program Administrator may require a review/audit (evaluation) of the application and of the Applicant's Facility for eligibility of costs incurred and applied for under the Program to determine sufficiency for payment;
• Applicants will provide estimated costs in the application form. Payments for cost sharing may be made based on the actual costs incurred subject to the maximum amounts; and,
• Applicants may assign any payments to which they are entitled under this Program. Payment pursuant to any assignment will be made jointly to the Applicant and assignee(s).

3.6 Application Deadline: applications for the traceability grant program to be received no later than Monday April 30, 2007. This is a first come, first served program. Traceability grant program funds are limited to $2 million; maximum of $20,000 per application. OMAFRA reserves the right to extend the deadline.

3.7 Receipt/Documentation Deadline: The deadline for submitting receipts and supporting documents is March 1, 2008. Submit your Supporting Documents by fax to (519) 826-4466 or by mail to: Food Safety Initiative -Traceability, OMAFRA, 1 Stone Road West, Guelph, ON N1G 4Y2

3.8 Applicants can apply to the traceability grant program once per Facility.

3.9 Eligibility Letters: Following receipt of a completed application form for the grant component of the Program by the application deadline, Applicants will be advised in writing of their eligibility to receive payments under this component. If eligible, prior to any payments being made, the Applicant will receive an eligibility letter which will outline the terms and conditions of the payment for Eligible Costs, including events of default under which the Applicant would be required to repay all, or a portion of, the payment. Prior to any payments being made, Applicants will be required to return a signed copy of the eligibility letter to the Program Administrator.

Section 4 - Applies to traceability pilot project ONLY

4.0 Traceability pilot project:

4.1 Objectives:

• increasing industry understanding and adoption of a Facility Level Traceability System;
• demonstrating the implementation of a Facility Level Traceability System in a wide
  range of settings, from farm to processing and all points in between;
• implementing Can-Trace Data Standards;
• collecting data on the operational and economic benefits to businesses by implementing a Facility Level Traceability System;
• collecting data on the outcomes of implementing a Facility Level Traceability System;
• developing educational materials and tools for other food settings;
• using the cost-benefit analysis tool developed by Can-Trace
  (refer to www.can-trace.org under reports: Can-Trace Decision Support Template); and,
• providing training opportunities and tours for industry members to observe and learn
  on-site about operating a Facility Level Traceability System.

4.2 Industry Outcomes: In addition to supporting food safety, by implementing a Facility Level Traceability System, companies may realize a number of benefits such as:

• sustained or increased market access;
• reduced impact of a product recall and improved ability to respond;
• reduced cost of liability protection;
• improved business performance through supply chain optimization (i.e. reduced
  inventories, shipping costs);
• reduced operational costs;
• reduced product returns and wastage;
• increased buyer and consumer confidence;
• improved marketing and branding of specialty products (e.g. organics, kosher, non-GMO); and,
• efficient oversight - maintaining control over the Facility and the products.

4.3 Selection Criteria: The selection of pilot project Facilities will be based on pre-established criteria. The selection criteria are the following:

• demonstrated management commitment to the implementation of a Facility Level
  Traceability System;
• the Facility's ability to successfully meet the traceability pilot project's objectives;
• outcome and completeness of Part D of the application form: Proposed Traceability Work Plan and Budget;
• complexity and number of products/processes at the Facility; and,
• commodity sector - OMAFRA will ensure that a cross-section of facilities representing commodity sectors from farm to fork is being represented;
• OMAFRA may require additional information which may be used to evaluate facilities for selection.

4.4 Participating Facility Obligations: Participating Facilities will be expected to:

• Provide a letter with the application demonstrating the owner's and/or senior management's commitment to the development and implementation of a Facility Level Traceability System. The letter should also explain the reasons for applying to be a pilot project, describe the expected benefits for the Facility and what resources and capital investments the company is willing to incur to successfully implement the Facility Level Traceability System;
• Enter into a legally binding agreement with OMAFRA;
• Provide dedicated staff as traceability coordinator/team;
• Develop and implement a Facility Level Traceability System throughout the Facility, for all products/processes, by February 1, 2008;
• Maintain a Facility Level Traceability System throughout the Facility for a minimum period of three years;
• Train staff at all levels in their areas of responsibility related to the Facility Level Traceability System;
• Host pre-arranged on-site visits for industry groups and other operators to observe/tour Facility demonstrations of the Facility Level Traceability System;
• Allow a generic model to be developed from the traceability pilot project and be made available to other Facilities;
• Allow access for review of traceability pilot project records;
• Provide sample record-keeping forms and other materials developed during the implementation;
• Allow access to business records for operational and economic analysis (prior, during and post implementation);
• Procure adequate liability insurance with OMAFRA added as an additional insured for the duration of the term as specified under the agreement with OMAFRA; and,
• Provide proof of traceability implementation as per Schedule B, using Can-Trace Data Standards (Schedule A).

4.5 Role of OMAFRA:

• OMAFRA will hire consultants and assign them to the selected Facilities to assist the Facility in the development and implementation of the Facility Level Traceability System;
• OMAFRA will pay consultants directly;
• OMAFRA will administer the traceability grant program; and,
• OMAFRA will have oversight of the project during all stages of development, implementation and proof of traceability.

4.6 Role of the Consultants:

• the consultant will provide their services to the Facility with the purpose of developing and implementing a Facility Level Traceability System. Their role may include staff training.
• the consultant will conduct a cost/benefit analysis of the implementation of a Facility Level Traceability System and provide it to OMAFRA.
• The consultant will report on implementation of Facility Level Traceability System.

4.7 Eligible Costs: A successful pilot project Applicant will automatically be enrolled in the traceability grant program to cover eligible costs. Please refer to Section 3.3 for associated Eligible Costs.

4.8 Payments: Refer to Section 3.5 of the guidelines.

4.9 Application Deadline: Applications for the traceability pilot project to be received no later than Friday March 16, 2007. OMAFRA reserves the right to extend the deadline.

5.0 Signatures:

5.1 For a sole proprietorship, Part E must be signed by the owner.

5.2 For partnerships and other forms of joint ownership, Part E must be signed by all partners or owners.

5.3 For corporations, Part E must be signed by the authorized officer(s) required to legally bind the corporation.

5.4 Designates are not permitted to sign application forms unless they have duly authorized powers of attorney, the proof of which must be submitted with the application.

6.0 Substantiation, Verification, Audit and Enforcement:

6.1 Applicants will be required to sign a declaration authorizing the Program Administrator to obtain information from or disclose information to any municipal corporation, federal or provincial government, or any agency, board, or commission thereof, or other governmental or non governmental body for the purposes of evaluating, verifying, auditing and enforcing the application and payments made under the Program. This information may be contained in the application or may be other information necessary and relevant to the application.

6.2 Applicants will be required to agree to give the Program Administrator access to examine their business operations and physical facilities and make available to the Program Administrator all business records, books of account, receipts, invoices, and income tax returns necessary to audit the operation of the Program and Facility and/or to verify any information provided in their application under this Program. This may include but is not limited to copies of all business records, books of account, and income tax returns of persons who are partners, shareholders, others who act on behalf of the Applicant, or persons who are involved in non-arm's length relationships as defined by the Income Tax Act.

6.3 The Program Administrator may require the Applicant to provide additional information as appropriate and necessary to complete the evaluation of the application.

7.0 Other Program Requirements:

Eligible Applicants who receive payments under this Program must ensure that all work is done in accordance with the laws of Ontario, otherwise the eligible Applicant is liable to repay any or all payments received. Until such payment is made, it will create a debt owing to the Crown in Right of Ontario that can be set off against any money the Crown owes to the Applicant.

8.0 Request for Reconsideration:

An eligible Applicant may request reconsideration of the
Program Administrator's decision regarding their application within 30 calendar days of notification of the status of their application. The request for reconsideration should be made in writing to the Program Administrator and include the reasons for the request. Requests should be submitted to: Program Administrator, Food Safety Initiative - Traceability, OMAFRA, 1 Stone Road West, Guelph, ON,
N1G 4Y2.

9.0 Termination of Program:

The Minister may terminate this Program at any time without notice to Applicants.

10.0 False or Misleading Information:

Applicants who provide false or misleading information under
this Program forgo all rights to any benefit for which the Applicants would otherwise be eligible from this Program, are liable to repay any or all payments received, and may be subject to prosecution.

11.0 Default:

If an Applicant fails to provide any requested records within a reasonable time, that
Applicant shall be deemed in default of the program guidelines and the Program Administrator may require the Applicant to repay all or part of the funds received by the Applicant in relation to this application. Failure of an Applicant to make a repayment as required by the Program Administrator creates a debt owing to the Crown in Right of Ontario, that can be set off against any money the Crown owes to the Applicant now and in the future.

12.0 Refunds:

Applicants will be required to refund any or all payments received under this Program that are not in accordance with the Program Guidelines, and the laws of Ontario, within 30 calendar days of notice being provided to them by the Program Administrator.

13.0 Confidentiality:

The Program will be administered by the Food Safety Programs Branch of the
Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA). Any information supplied further to this Program may be disclosed by OMAFRA where it is obligated to do so under the Freedom of Information and Protection of Privacy Act (FIPPA), by an order of a court, tribunal or pursuant to a legal proceeding.

Applicants will also be required to provide consent to OMAFRA to allow the Program Administrator to obtain information from municipal corporations, federal and provincial governments, or any agency, board, or commission thereof, and any non-government organizations, as appropriate, which is necessary to the assessment, evaluation, verification, audit and enforcement of applications and payments.

The Program Administrator may disclose information contained in the application or relevant to it and obtained by the Program Administrator in the course of verifying, evaluating or auditing the application, to any other municipal corporation, federal or provincial government, or any agency, board, or commission thereof, or other governmental or non-governmental body as appropriate, which is necessary to the assessment, evaluation, verification, audit and enforcement of applications and payments.

Questions about the application process may be directed to Food Safety Initiative - Traceability, OMAFRA, 1 Stone Road West, Guelph, ON N1G 4Y2 or by calling toll-free 1-866-641-3663.

14.0 Ministerial Discretion:

The Minister has the absolute discretion to determine any Payments
under this Program notwithstanding the Program Guidelines. The Minister has absolute discretion to administer this Program; to make, amend, or revoke rules concerning administration of this Program; to amend, revoke, replace, or add any other Program Guidelines; and to interpret any word, sentence or phrase contained in the Program Guidelines and Application Form, including the ability to make, extend, or waive timelines.

15.0 Debts to Government:

The Minister has the right to deduct from the eligible Applicant's
payment any amount due and owing to the Province of Ontario.

16.0 No Liability:

The Applicant will be required to acknowledge that Her Majesty the Queen in right
of Ontario is not liable to the Applicant, the Applicant's heirs, administrators and assigns for any injury, including personal injury, property damage, or any other damage, injury, claim or loss whatsoever arising out of this Program and the Applicant's participation in it.

Schedule A

Generic CAN-TRACE Data Requirements::

www.can-trace.org

Schedule B - Proof of Traceability Implementation:

Traceability grant program requirements:

1. Submit a copy of the Traceability Program Protocol. The program protocol:

   1. Describes the roles, responsibilities, and instructions that apply to the appropriate gathering, storing, and sharing of traceability information.
   2. Ensures that the mandatory data requirements as established by Can-Trace (See Schedule A) are met.
      
      
2. Submit documentation showing that you have conducted a successful mock recall on one of your products, including:
   
   
   1. Date of the test.
   2. Identifier for the product used (that reached your intended customer i.e. one-level up).
   3. A description of the test scenario. (e.g. forward from the raw ingredient level, for example:
      "Our firm received a phone call from Supplier "X" who informed us that ingredient "AA" was contaminated and that all products which have this ingredient should be removed from the market immediately", or backwards from the finished product on the marketplace, for example: "Our firm investigated a consumer complaint and found that product "BB" manufactured by our firm was unsafe and should be removed from the market immediately.")
   4. The number of accounts/clients/customers that were notified of the recall.
   5. The number of accounts/clients/customers that were contacted to verify that they received the recall notification.
   6. Method of confirming that the accounts/clients/customers were notified.
   7. A statement describing how you determined that your recall notification was effective. (100% retrieval of target product in 48 hours or less).
   8. A statement of the corrective action taken if it was determined that the recall was not satisfactory.
   9. Indicate problems you identified during the test. (if any)
   10. If problems were identified during the test, indicate how you changed the recall plan to correct each problem.

Traceability pilot project requirements:

1. Submit a copy of the Traceability Program Protocol. The program protocol:

1. Describes the roles, responsibilities, and instructions that apply to the appropriate gathering, storing, and sharing of traceability information.
2. Ensures that the mandatory data requirements as established by Can-Trace (See Schedule A) are met.

2. Submit a copy of the Traceability Training Program:

   Traceability training is delivered and updated as required to ensure that personnel understand and are competent in the policies and procedures necessary to ensure that food products are traceable from supplier inputs/raw material, through to the finished product destination. Training is delivered at an adequate frequency to ensure personnel's understanding remains current.

3. Submit a copy of the Recall Program:

   The program outlines effective policies and procedures that enable the identification and complete, rapid recall of any implicated food product. The program includes roles and responsibilities, details and methods of recall activities, and records to be completed and maintained.

4. Submit a copy of the Recall Training Program:

   Recall training is delivered and updated as required to ensure that personnel involved in recall activities understand and are competent in procedures necessary in the event that the safety and suitability of food is compromised. Training is delivered at an adequate frequency to ensure that personnel's understanding remains current.

5. Submit documentation showing that you have conducted a successful mock recall on one of your products, including:
   

1. Date of the test.
2. Identifier for the product used (that reached your intended customer i.e. one-level up).
3. A description of the test scenario. (e.g. forward from the raw ingredient level, for example:
   "Our firm received a phone call from Supplier "X" who informed us that ingredient "AA" was contaminated and that all products which have this ingredient should be removed from the market immediately", or backwards from the finished product on the marketplace, for example: "Our firm investigated a consumer complaint and found that product "BB" manufactured by our firm was unsafe and should be removed from the market immediately.")
4. The number of accounts/clients/customers that were notified of the recall.
5. The number of accounts/clients/customers that were contacted to verify that they received the recall notification.
6. Method of confirming that the accounts/clients/customers were notified.
7. A statement describing how you determined that your recall notification was effective. (100% retrieval of target product in 48 hours or less).
8. A statement of the corrective action taken if it was determined that the recall was not satisfactory.
9. Indicate problems you identified during the test. (if any)
10. If problems were identified during the test, indicate how you changed the recall plan to correct each problem.

 

References:

HACCP Advantage Program Manual - Version 2.0

Canadian Food Inspection Agency (CFIA):
http://www.inspection.gc.ca/english/fssa/recarapp/rap/mgguide.shtml

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