In the past, in order to use non-food chemicals such as degreasers, sanitizers, and conveyor lubricants in a federally inspected processing facility, the product’s manufacturer had to obtain a letter of no objection from the Canadian Food Inspection Agency (CFIA).
Most of these federally inspected plants were food producers involved in interprovincial trade or international exportation.
To obtain this document, the manufacturer had to submit a file to the CFIA. At a minimum, this file had to include the product’s complete list of ingredients, as well as information on their concentration and source. The manufacturer also had to provide commercial labels for the product which included its instructions for use.
If the submitted product met the CFIA’s requirements, the Agency would issue a letter of no objection (LONO). The CFIA also maintained a website listing all products holding a letter of no objection.
These letters of no objection could not be construed as an endorsement by the CFIA of the product’s quality or efficacy. Rather, these documents signified that the CFIA had deemed that when used according to the instructions on the label, these products would not jeopardize the health of consumers. In other words, the CFIA did not object to their use in federally inspected food & beverage plants .
Although these documents were not required for non-federally inspected facilities such as cafeterias, kitchens, and restaurants, many of these facilities nonetheless required these documents before agreeing to use these products in their food areas.
On July 2, 2014, the CFIA revoked this pre-registration requirement for products for the vast majority of applications. The CFIA no longer maintains its website nor does it recognize the validity of these documents. The only exceptions requiring a letter of no objection are processing aids used on red meat and poultry.
In lieu of a letter of no objection, the CFIA now requires federally inspected establishments to obtain a letter of guarantee from the manufacturer of non-food chemicals.2 This document is required for all products that come into contact with food or with surfaces that come into contact with food.
At a minimum, this document must include the following information:
The name of the company providing the letter of guarantee and its date of issue.
The non-food chemical in question, identified by name or code number.
A statement that the chemical is safe and appropriate for its intended use in food establishments.
A statement that the company will submit, at the request of the Canadian Food Inspection Agency, all necessary documentation to demonstrate that the chemical is safe and appropriate for its intended use in food establishments.
The product’s instructions for use in food establishments, including relevant limits, or a reference to the label if the instructions for use appear on the label.
The signature of an official of the company providing the letter of guarantee.
A number of products are exempt from this letter of guarantee. These include:
Chemicals that do not come into contact with food or with surfaces that come into contact with food, such as:
Chemicals used in offices or similar areas where food is not prepared
Chemicals used in bathrooms, cafeterias, and mess/dining halls
Chemicals used in heating systems
Chemicals used in laboratories
Chemicals used outdoors only for sewers or sewage disposal systems
Chemicals used in cooling columns or evaporative condensers
Chemicals used for cleaning and maintaining vehicle exteriors
Chemicals used for protection against fire and safety
For all non-federally inspected facilities, no document is required.