On April 28, 2020, a message was circulated from Health Canada detailing provisions being put in place in response to the COVID 19 pandemic.
Part of the communication was outlining the plans for the commencement of Sales Inspections. The new approach would be to conduct sales inspections remotely on a risk-based approach and deliver the compliance promotion information presentation to key site individuals.
In the communication, Health Canada state that “The compliance promotion session will require mandatory participation of key individuals/positions as listed in the application (i.e., Responsible Person (RP), Quality Assurance Person (QAP), and alternates) “.
This blog post is intended to share experiences from the Compliance Promotion session to give LHs an idea of what to expect. A separate blog on remote inspections will be published.
The two-hour presentation was scheduled so all mandatory individuals could participate and delivered via a WebEx PowerPoint. Three different presenters delivered the content, opportunities were provided for the Licence Holder participants to ask question at the end of each section.
The presentation covered Compliance & Enforcement, Inspections, GPP, Recall, Pesticide testing, labeling, Promotions, and Reporting requirements.
The presenters added some useful examples of noted non-conformance from inspection based on their own experience without divulging company secrets. At times, the tone might have seemed a little harsh to the more sensitive individual, but the information imparted is valuable and could help with identifying and dealing with possible issues at site level before a problem arises.
In conclusion, the content was comprehensive and very useful. A copy of the slides was provided to attendees after the presentation. We really appreciated the time Health Canada had put in to creating this content. Moving forward, I would love to see this delivered annually or in conjunction with significant changes in the regulations/guidance. Smaller group sessions would facilitate better discussion. This would be an excellent topic for the C45 Quality Association to host in conjunction with Health Canada at the annual summit or as a networking session.
I plan to incorporate some of the examples into our annual refresher training for sure.