Well, you rightly point out, Mr. Allen, that the HACCP protocols in any plant are a living document. They ebb and flow and change as the plant redirects its staffing and what they're doing on a given day, and you try to make them as complete as possible.
I would not agree with you that CFIA is completely removed from the adjudication of those HACCP programs; it is there. It is there to make sure they are efficient and equivalent to what the plant is actually doing. Then through the CVS, the compliance verification system, CFIA constantly audits the efficacy of the HACCP program as to what's actually happening on the floor.
That's what tripped up XL at the end of the day, when its certificate was pulled. What it had written down and what it said it was doing did not correspond to what was actually happening on the plant floor. That was the decertification point.
You rightly point out that these HACCP programs are changeable and they are adjudicated, as you say, by third parties, but the day-to-day verification that HACCP is still efficient and effective in the plant is done by CFIA.