Norovirus in Frozen Berries: The SFCR Hazard Your PCP Cannot Kill

On 15 September 2026 the Canadian Food Inspection Agency (CFIA) issued a food recall warning for Alasko brand frozen whole raspberries because of possible norovirus contamination. The recall covers a 1 kg retail pack and a 5 kg foodservice pack, both from the same lot, distributed across seven provinces. For anyone who handles frozen fruit, the recall is more than a supplier problem. It is a test of one specific line in your hazard analysis, and for most Preventive Control Plans in Canada, that line does not exist.

Most food safety plans identify bacterial, chemical, physical and allergen hazards, then stop. Viruses are rarely named. That omission is comfortable until an enteric virus recall lands, because freezing does not kill norovirus and there is no kill step in an individually quick frozen (IQF) process. A plan that never identified the hazard has no control to point to, no monitoring to show an inspector, and no defence when a CFIA investigation asks how the hazard was managed.

Executive summary

Norovirus is a biological hazard under the Safe Food for Canadians Regulations (SFCR), and biological hazards include viruses, not only bacteria. Freezing preserves norovirus rather than destroying it, so a frozen fruit line has no step that reduces the hazard to an acceptable level. The control strategy therefore shifts upstream, to supplier qualification, field and worker hygiene, water quality, sanitary facilities and cross-contamination prevention. This article walks through the September 2026 recall, why freezing is not a control, the six hazard classes a complete PCP must address, what CFIA surveillance actually found in Canadian berries, and the practical controls that work when there is no kill step. It closes with a compliance checklist, common mistakes, a FAQ, and how MFLRC helps food businesses close the viral hazard gap.

What happened: the September 2026 Alasko raspberry recall

What it is: on 15 September 2026 the CFIA published a food recall warning for Alasko brand frozen whole raspberries due to possible norovirus contamination. Why it matters: the recall reaches both retail and foodservice, so exposure runs from the grocery shelf into bakeries, smoothie bars and institutional kitchens. What to do: confirm you do not hold the recalled lot, and ask whether your plan could have caught the hazard at all.

Two products are named on the notice, both carrying lot SY25314 and best-before date 2027-NO-10: a 1 kg retail unit (UPC 6 95058 00205 4) and a 5 kg foodservice unit sold as five 1 kg bags (UPC 1 069505 800205 1). Distribution spans Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island and Quebec. The CFIA advises the public not to consume, use, sell, serve or distribute the recalled product, and to throw it out or return it.

The 5 kg foodservice pack is the detail most operators overlook. A retail recall ends when the consumer discards a bag. A foodservice recall does not, because the raspberries may already be baked into a dessert, blended into a drink or plated in a catering line. That is secondary recall exposure, and it is covered in its own section below.

Why freezing is not a control for norovirus

What it is: freezing is a preservation step, not a kill step. Why it matters: norovirus and hepatitis A virus survive freezing and remain infectious in frozen fruit for long periods, so a frozen or IQF process does not reduce the hazard. What to do: stop treating cold-chain steps as control measures for viral hazards and move the controls upstream. How it affects compliance: if freezing is your only named line of defence, your hazard analysis has a control that does not work.

Thermal processing that would inactivate norovirus, such as a validated cook step, is absent from a raw or frozen berry line by design, because the product is sold to be eaten without cooking or is added to finished goods that may never be heated to a lethal temperature. Enteric viruses are also hardy: they tolerate low temperatures, survive on surfaces and need only a very small dose to cause illness. That combination is why the hazard cannot be managed at the freezer and must be prevented before the fruit is ever harvested and packed.

Are viruses a hazard under the Safe Food for Canadians Regulations?

Yes. Under the Safe Food for Canadians Regulations, a licence holder must identify the biological, chemical and physical hazards that present a risk of contamination, and biological hazards include viruses. A Preventive Control Plan that identifies only bacterial pathogens has an incomplete hazard analysis. Why it matters: an incomplete analysis is an inspection finding on its own, before any product is even tested. What to do: add enteric viruses to your hazard identification for any raw or minimally processed produce.

The SFCR requires the control measures in a PCP to be based on evidence that they are effective. For a viral hazard with no kill step, that evidence is not a time and temperature log. It is documentation of supplier controls, worker health programmes, water and sanitation, and cross-contamination prevention. An inspector reading your plan will look for the hazard to be named, the controls to be justified, and the monitoring, verification and corrective actions to match. If the hazard is missing, everything downstream is missing too.

The six hazard classes every Preventive Control Plan must address

What it is: a complete hazard analysis covers six classes, not one. Why it matters: most Canadian food safety writing, and most plans, concentrate on bacterial pathogens and treat the other classes lightly. What to do: check your plan against every row of the table below, and confirm each hazard that is reasonably likely to occur has a named, justified control.

The viral row is the one most plans are missing, but it is not the only non-bacterial blind spot. The same structural gap appears with Cyclospora in imported produce and with chemical residues in imported food. If your hazard analysis is thorough on Listeria and Salmonella but thin everywhere else, the recall that tests it will come from a class you did not take seriously.

What CFIA surveillance actually found in Canadian berries

What it is: between 2016 and 2021 the CFIA collected 4,218 samples of fresh and frozen berries and pomegranate arils at retail across 11 major Canadian cities and tested them for norovirus GI, norovirus GII and hepatitis A virus. Why it matters: it is the best Canadian data on how often these viruses actually appear on the market. What to do: use it to justify a risk-based, not a zero-risk, control strategy.

Of 3,292 frozen fruit samples, 13 tested positive for norovirus RNA: norovirus GI in three samples and norovirus GII in ten, roughly 0.4 percent. Among the 926 fresh fruit samples, norovirus GI was found in one raspberry sample and norovirus GII in one strawberry sample. No fresh or frozen sample tested positive for hepatitis A virus. Across all 4,218 samples, the overall prevalence of norovirus GI and GII together was about 0.36 percent. The prevalence is low, but it is not zero, and detection tells you the hazard is present in the supply chain, not that a given lot is safe. A single contaminated lot with a low infectious dose is enough to trigger a recall.

Where the contamination comes from

What it is: enteric viruses reach berries overwhelmingly through human faecal contamination, not through the environment in the way bacteria do. Why it matters: that changes where the controls belong. What to do: focus prevention on the people and the water that touch the crop, and on the facilities and surfaces during processing.

The recognised contamination routes are field worker hygiene and health, inadequate or absent sanitary facilities and handwashing stations near the harvest, contaminated agricultural or process water, and cross-contamination during grading, sorting and packing. Berries are hand-harvested, fragile and not washed with a lethal process, so a single ill worker at harvest can contaminate a large volume of fruit that will then be frozen and shipped with the virus intact. This is why the FDA berry prevention strategy, discussed below, centres on worker health, sanitary facilities and cross-contamination rather than on a terminal treatment.

Controls that work when there is no kill step

What it is: a layered set of preventive controls that reduce the probability of contamination upstream, because you cannot remove the hazard at your own site. Why it matters: with no kill step, prevention is the whole strategy. What to do: build and document the following, and treat each as a control measure with monitoring, verification and corrective action.

• Supplier qualification that reaches the hazard. A risk-tiered supplier qualification programme for berries must verify field worker hygiene, sanitary facilities and water controls, not only a certificate of analysis for pesticides and heavy metals.
• Worker health and illness exclusion. A written procedure that requires ill workers to report symptoms and stay away from food handling, with return-to-work criteria and records that would survive an outbreak investigation.
• Sanitary facilities and hand hygiene. Accessible toilets and handwashing stations at the field and in the plant, maintained and monitored, because handwashing is a primary barrier to faecal-oral transmission.
• Water controls. Verification that agricultural and process water is from a controlled source and is not a contamination route.
• Cross-contamination prevention. Sanitation and personnel controls during grading, sorting, packing and repacking so an infected handler or a contaminated surface does not spread the virus across lots.
• Traceability and recall readiness. One-up, one-back traceability and a tested mock recall and traceability drill so you can identify and reach affected product quickly when a supplier lot is recalled.

Exporting to the US: FSVP and the FDA berry strategy

What it is: the FDA has published a prevention strategy for the control of enteric viruses in fresh and frozen berries, and US importers verify foreign suppliers under the Foreign Supplier Verification Programs (FSVP). Why it matters: a Canadian berry or frozen fruit exporter is reachable through FSVP, and a US importer will push the FDA strategy upstream. What to do: prepare documented worker health, sanitary facility and cross-contamination controls before an importer asks for them.

The FDA strategy addresses the same factors that drive contamination in Canada: inadequate field worker hygiene, cross-contamination during processing and gaps in food safety systems. A US importer asked to verify a Canadian supplier against that strategy will not accept a generic HACCP plan. They will want to see the specific viral controls documented. Building those controls now is both a compliance requirement at home and a market-access advantage for exporters.

Secondary recall exposure: when the recalled lot is already in your product

What it is: secondary recall exposure is the risk that a recalled ingredient is already inside a finished product you made or served. Why it matters: the 5 kg Alasko foodservice pack means bakeries, smoothie operators and institutional kitchens may hold the recalled raspberries as an ingredient, not a retail unit. What to do: trace the ingredient forward into every batch and menu item, and be ready to explain to whoever runs the food safety investigation what you did with it.

A downstream user of a recalled ingredient has to answer three questions fast: did we receive the recalled lot, where did it go, and is any of it still in finished product or on a menu. If your traceability stops at the receiving dock, you cannot answer the second and third questions, and the safe default becomes a broader withdrawal than the evidence requires. Traceability that follows the ingredient into finished goods is what keeps a supplier recall from becoming your recall.

Preventive Control Plan compliance checklist

Use these nine questions to test your plan this week. If you answer no to any of them, that is where the viral hazard gap is.

• Does your hazard analysis name enteric viruses (norovirus, hepatitis A) for raw and minimally processed produce?
• Have you removed freezing and cold storage from your list of control measures for viral hazards?
• Does your supplier qualification verify worker hygiene, sanitary facilities and water, not just chemistry on a certificate of analysis?
• Do you have a written worker illness reporting and exclusion procedure with return-to-work criteria?
• Are handwashing and sanitary facilities specified, maintained and monitored as control measures?
• Can you trace an incoming ingredient lot forward into every finished product and batch that used it?
• Have you run a mock recall in the last twelve months, including a secondary-recall scenario for a recalled ingredient?
• If you export to the US, can you show viral controls that satisfy an importer verifying you under FSVP?
• Do your monitoring, verification and corrective-action records line up with each viral control you claim?

Common mistakes

• Treating freezing as a control. Freezing preserves norovirus; it does not inactivate it. Listing it as a control measure creates a plan that fails on contact with a real recall.
• Qualifying suppliers on chemistry only. A certificate of analysis for pesticides and heavy metals says nothing about field worker hygiene or water. The viral hazard passes straight through.
• A personnel hygiene clause with no exclusion criteria. Almost every plan says workers must be clean. Almost none has an illness reporting and exclusion procedure that would survive an outbreak investigation.
• Traceability that stops at the supplier. If you cannot follow a lot forward into finished product, a supplier recall forces a broader withdrawal than the evidence requires.
• Closing the recall CAPA on corrective action alone. A recall-triggered CAPA that skips the effectiveness check is the most common second-round finding after the initial event.

Frequently asked questions

Does freezing kill norovirus?

No. Norovirus survives freezing and can remain infectious in frozen fruit for months. Freezing is a preservation step, not a kill step, so a frozen or IQF process does not reduce a viral hazard to an acceptable level.

Are viruses a hazard under the Safe Food for Canadians Regulations?

Yes. Biological hazards under the SFCR include viruses. A Preventive Control Plan that identifies only bacterial pathogens has an incomplete hazard analysis, which is an inspection finding regardless of whether any product tests positive.

Does my Preventive Control Plan need to cover viruses?

If you handle raw or minimally processed produce such as berries, then yes. Enteric viruses are reasonably likely to occur in that supply chain, so they must be identified and controlled through supplier, worker health, water and sanitation measures.

What do I do if a recalled ingredient is already in my product?

Trace the ingredient lot forward into every batch and menu item, quarantine affected finished product, contact your regulatory authority, and document the decision. Strong one-up, one-back traceability keeps a supplier recall from expanding into a full withdrawal of your own goods.

How do you control norovirus in frozen fruit if there is no kill step?

You prevent contamination upstream: qualify suppliers on worker hygiene and water, enforce worker illness exclusion, maintain sanitary facilities and handwashing, control agricultural and process water, and prevent cross-contamination during grading and packing.

Was hepatitis A found in Canadian berries?

In the CFIA surveillance of 4,218 fresh and frozen samples collected from 2016 to 2021, no sample tested positive for hepatitis A virus. Norovirus was detected at low prevalence, so hepatitis A remains a recognised hazard for berries even though it was not found in that survey.

How MFLRC can help

MFLRC helps food businesses close the viral hazard gap before a recall tests it. We run Preventive Control Plan gap assessments and rewrite hazard identification to cover every class, build risk-tiered supplier qualification programmes, develop SOPs for worker health, illness exclusion and sanitary facility management, design environmental monitoring for ready-to-eat produce, run mock recall and traceability simulations, prepare FSVP readiness packages for US-bound exporters, and design CAPA programmes that close with effectiveness evidence. If you are unsure whether you even need a PCP, we can confirm whether the small business exception applies to you.

If you handle frozen fruit, imported produce or ready-to-eat ingredients, your hazard analysis is either complete or it is one recall away from being tested. Contact MFLRC at info@mflrc.com or +1-647-492-5301 for a Preventive Control Plan gap assessment.

Conclusion

The September 2026 Alasko recall is a reminder that the hazard classes a plan ignores are the ones that end up on a recall notice. Norovirus cannot be frozen out, so the control strategy has to move upstream to suppliers, workers, water and sanitation. A Preventive Control Plan that names the viral hazard, justifies its controls and can trace a lot both ways is not just compliant. It is the difference between managing a supplier recall and becoming one.

Sources and references

• CFIA, Alasko brand frozen whole raspberries recalled due to norovirus (15 September 2026)
• CFIA / Open Science, Norovirus GI and GII and hepatitis A virus in berries and pomegranate arils in Canada
• FDA, Prevention Strategy for the Control of Enteric Viruses in Berries
• FDA, Microbiological Surveillance Sampling FY19 to FY23, Frozen Berries
• Safe Food for Canadians Regulations (SOR/2018-108), Justice Laws Website