Health Canada Inspection Workflow

Food and Drugs Act  |  Food and Drug Regulations C.02  |  GUI-0001  |  GUI-0023
Food and Drugs Act  ·  FDR Division 2
GUI-0001 GMP Guidelines  ·  GUI-0023 Risk Classification
The risk rating assigned to each observation
drives the site's compliance rating outcome
Phase 1 - Pre-Inspection Preparation
Phase 2 - Inspection Opening and Conduct
Phase 3 - Observation Risk Classification and Close-Out
Phase 4 - Response and Compliance Rating Outcome
Decision point
GMPify Procedural Map Series
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Health Canada Inspection - Verifying Compliance Under the Food and Drugs Act

A Health Canada inspection verifies that a licensed establishment complies with the Food and Drug Regulations Division 2 requirements, using the GMP expectations set out in guidance document GUI-0001. Observations are classified for risk using the framework in GUI-0023, a three-tier Risk 1, Risk 2, Risk 3 model that determines the site's compliance rating and any impact on its Establishment Licence. This map details the pathway from preparation through conduct, risk classification, and the compliance rating outcome.

Food and Drugs Act  ·  FDR Division 2  ·  GUI-0001  ·  GUI-0023
Food and Drugs Act
FDR Division 2
GUI-0001
GUI-0023

Routine / Compliance Inspection

Periodic inspection conducted on Health Canada's risk-based inspection cycle for licensed establishments.

Trigger: Scheduled cycle

For-Cause Inspection

Triggered by a specific concern, such as a complaint, recall, or referral from another regulator.

Trigger: Specific concern

Pre-Licensing Inspection

Conducted before issuing a new or amended Establishment Licence, verifying the site can operate as described.

Trigger: Licence application

Foreign Site / MRA Reliance

Compliance for foreign sites verified directly or through reliance on a trusted regulator under a Mutual Recognition Agreement.

Trigger: Foreign supply to Canada
Phase 1
Pre-Inspection Preparation
1Maintain continuous GMP compliance
Site maintained in ongoing compliance with Food and Drug Regulations Division 2 and GUI-0001 expectations, not prepared reactively upon notice.
GUI-0001
↓
2Confirm inspection notification and scope
Notification, when provided, reviewed to confirm the expected scope, duration, and areas of the establishment the inspection will cover.
Health Canada Inspection Policy
↓
3Verify inspector identification and authority
Identification and authority of the Health Canada inspector confirmed before the inspection proceeds.
Food and Drugs Act
↓
4Assemble the inspection response team
Front-facing hosts and subject matter experts assembled, aligned to the Establishment Licence activities within scope.
Internal SOP
Phase 2
Inspection Opening and Conduct
5Conduct opening meeting
Establishment Licence activities, scope, and expected duration of the inspection confirmed with site leadership at the outset.
Health Canada Inspection Policy
↓
6Facilitate facility tour and record review
Inspector conducts a facility walkthrough and reviews quality system records, batch documentation, and validation files as requested.
GUI-0001
↓
7Log observations as they are raised
Every observation raised during the walkthrough or record review logged internally in real time, alongside the site's response.
Internal SOP
↓
Does the inspector identify a GMP observation?
YES → Classify by risk level NO → Continue facility review
Phase 3
Observation Risk Classification and Close-Out
8Classify each observation by risk level
Observation classified as Risk 1, Risk 2, or Risk 3 per the criteria defined in GUI-0023, based on actual or potential impact on product quality.
GUI-0023
↓
9Conduct the exit interview
Final discussion held to review all observations identified, with the site given an opportunity to respond before the inspector departs.
Health Canada Inspection Policy
↓
10Receive the Exit Notification and report
Formal Exit Notification and subsequent inspection report issued, listing observations with their risk classification and response timeline.
Health Canada Inspection Policy
Phase 4
Response and Compliance Rating Outcome
11Submit the corrective action plan
Written corrective action plan submitted within the timeline specified, addressing root cause for each classified observation.
Health Canada Inspection Policy
↓
12Implement and verify corrective actions
Committed actions implemented on schedule, with effectiveness verified before the response is considered acceptable to Health Canada.
GUI-0001
↓
13Receive compliance rating and licence outcome
Overall compliance rating assigned, with implications for the site's Establishment Licence status ranging from compliant to non-compliant.
Food and Drugs Act
Inspection Types (Overview)

Routine / Compliance

Periodic inspection under Health Canada's risk-based inspection cycle, covering the establishment's licensed activities broadly.

Health Canada Inspection Policy

For-Cause

Triggered by a specific concern such as a complaint, recall, or referral, with a scope focused on the triggering issue.

Health Canada Inspection Policy

Pre-Licensing

Verifies a site can operate as described before Health Canada issues a new or amended Establishment Licence.

Food and Drugs Act

Observation Risk Classification (Overview)

Risk 1 (Critical) A practice or process that has produced, or is likely to produce, a product that poses a serious health risk.
Risk 2 (Major) A practice or process that has produced, or may produce, a product that does not meet its required quality standards.
Risk 3 (Other) A practice or process that departs from GMP but does not meet the criteria for a Risk 1 or Risk 2 classification.
Classification drives the rating The number and severity of Risk 1, 2, and 3 observations determines the establishment's overall compliance rating.

Key Inspection Outputs (Overview)

Exit Notification Document provided at the end of the inspection summarizing observations discussed during the exit interview.
Inspection report Formal report listing every observation, its risk classification, and the required corrective action plan timeline.
Compliance rating Overall rating assigned to the establishment based on the number and severity of observations identified.
Establishment Licence status Licence maintained, amended, suspended, or cancelled depending on the compliance rating and response to observations.

Health Canada Inspection Readiness Quality Elements

Continuous GMP Compliance Quality system and facility maintained in ongoing compliance with GUI-0001 expectations, not assembled reactively before an inspection.
Inspection Support Team Readiness Front-facing hosts and subject matter experts identified and briefed on their roles before the inspection begins.
Real-Time Observation Logging Observations raised during the walkthrough and record review logged internally as they occur.
Risk Classification Understanding Site personnel understand the Risk 1, Risk 2, and Risk 3 criteria and their implications for the compliance rating.
Response Timeliness Corrective action plan submitted within the timeline specified in the inspection report.
Root Cause Depth Response addresses the underlying cause of each observation, not only the specific instance the inspector observed.
CAPA Verification Committed corrective actions implemented and their effectiveness verified before the response is considered closed.
Establishment Licence Status Tracking Licence status and any conditions tracked proactively across every activity and site covered by the licence.

Never do this

Treat a Risk 1 observation response with the same urgency as a Risk 3 item. Submit a corrective action plan without addressing root cause. Allow Establishment Licence conditions to go unaddressed. Assume a risk classification without checking the GUI-0023 criteria directly.

Risk 1/2/3 vs EU and FDA models

Health Canada classifies observations as Risk 1, Risk 2, or Risk 3 under GUI-0023. The EU model uses critical, major, and other deficiencies with similar intent. The FDA 483 model lists observations without an equivalent formal severity tier at issuance.

Routine vs for-cause

A routine inspection follows Health Canada's standard risk-based cycle and covers licensed activities broadly. A for-cause inspection responds to a specific concern and is typically narrower but more intensive around that issue.

Key regulations

Food and Drugs Act - statutory basis for Health Canada's inspection authority. Food and Drug Regulations Division 2 - GMP requirements for drugs. GUI-0001 - GMP guidance interpreting Division 2. GUI-0023 - risk classification framework for inspection observations.