The [US] Food Safety and Inspection Service and the Agricultural
Marketing Service have established an export verification program
designed to verify establishmentsâ€™ control of closed-faced sandwiches
destined for Canada. Once the program is implemented Feb. 1, 2016, only establishments participating in this program will be able to export closed-faced sandwiches to Canada.
Among other things, Canada is requiring that closed-faced sandwiches
be produced under a Hazard Analysis and Critical Control Point plan.
Under the program, the sandwiches will be produced in establishments
that are under FSISâ€™ voluntary reimbursable inspection service and are
operating under conditions that are as consistent as practical with
those under which other post-lethality exposed meat and poultry products
are produced under 9 CFR 430. Closed-faced sandwiches are under the
jurisdiction of the Food and Drug Administration but that agency does
not require that the sandwiches be produced under a HACCP plan.