PACC Committee Report

GOVERNMENT RESPONSE TO THE FOURTEENTH REPORT OF
 THE STANDING COMMITTEE ON  PUBLIC ACCOUNTS

Report of the House of Commons Standing Committee on Public Accounts

The Fourteenth Report of the Public Accounts Committee was tabled in the House of Commons on February 19, 2002.  A comprehensive Government Response has been requested under Standing Order 109 of the House of Commons.  The Fourteenth Report addresses the recommendations of Chapter 25 of the December 2000 Report of the Auditor General.   The audit work itself was undertaken during 1999-2000.   Since that time, significant progress has been made towards addressing the recommendations of the Fourteenth Report of the Public Accounts Committee, as detailed below.

RECOMMENDATION No. 1

    That the Canadian Food Inspection Agency strengthen its program audit function to improve the effectiveness and efficiency of compliance actions. That the Agency prepare an action plan on this initiative together with an implementation timetable and present the results achieved against performance targets in its performance report to Parliament for the period ending 31 March 2003.

The audit report noted that Aprogram audit is the chief mechanism that the Agency uses to determine whether inspectors are delivering food inspection programs according to the Agency=s standards@ and that Athe Agency has had some difficulty integrating the program audit functions; it harmonized them in early 1990.@  Program audit represents only one of many activities that are in place to ensure the efficiency and effectiveness of compliance actions.

To put Aprogram audit@ into perspective, it is important to understand where this activity fits in the overall control framework in place to promote accountability, effectiveness and continuous management and program improvement in the Agency=s operations.  Key activities in this overall control framework include both internal and external review activities. Internal review activities include those of management oversight of inspectors (Operations Branch), program audit, corporate audit, compliance and enforcement, legal services, etc.  External review activities are carried out by such organizations as Health Canada, the Office of the Auditor General, Treasury Board,  foreign trading partners, etc.

Ultimately this framework contributes to: safe food and labelling practices; protection of the health of animals and control of animal diseases that are transmissible to humans and protection of the plant resource base from regulated pests and diseases.

The Agency has recently taken measures to hire new veterinary supervisors in the animal health and meat hygiene areas.  These supervisors will undertake program audit functions on a regional basis, providing greater assurance of consistent delivery of inspection programs.

The Agency will present the results of compliance actions in its performance report to Parliament for the period ending 31 March 2003.

RECOMMENDATION No. 2

    That the Canadian Food Inspection Agency, in consultation with the Office of the Auditor General of Canada, engage in discussions with its provincial and territorial counterparts to identify and develop a satisfactory method to carry out a proper overall risk assessment of the non‑federally registered sector.  That the Agency present the result of these consultations in its performance report to Parliament for the period ending 31 March 2003.

The federal government registers approximately 2000 meat, fish, dairy, eggs, and processed food and vegetable establishments engaged in interprovincial and international commerce.  All other establishments fall into the Anon-federally registered sector@.   This latter sector falls under the provisions of the federal FDA and/or provincial or territorial legislation.  Both levels of government have established compliance and enforcement systems.  Companies in this sector include large multi-nationals and small local marketers.

In 2000, the Agency modified its enforcement and compliance approach for this sector.  CFIA=s Bureau of Food Safety and Consumer Protection (the Bureau), established in 2000, has successfully developed an effective and modern approach to enforcing the safety, compositional, nutritional and labelling and advertising requirements of the FDA and the Consumer Packaging and Labelling Act (CPLA).  The risk-based approach to inspection developed and implemented by the Bureau differentiates the federal role in inspection of federally registered establishments from those establishments which fall outside the federal registration process.  The revised program uses a science and risk based approach to guide inspection activities of food processors, sellers and importers that fall under the provisions of the FDA.

The new approach to inspection is based on the overall health and safety provisions regulated under the FDA.  The approach is managed by Science Committees of CFIA on which HC officials participate, which annually examine overall risk in the sector and set out multi-year investigation plans to address these risks.

The Science Committees follow a structured process that involves the completion of an environmental scan to identify potential food hazards in the food supply which includes consideration of the following information: results of investigations; review of analytical results; review of food recalls; information obtained from international sources; information provided from provincial sources; and other background information provided by Agency and HC specialists.  The Agency then reviews the current level of control by the industry and identifies the risk management approaches likely to have the greatest impact on improving industry controls.  In determining the most effective risk management approaches, the Agency considers the role and possible contribution of provincial, territorial and municipal governments and the industry in managing the risk.  Provinces will be asked to contribute to these Science Committees.   Program specialists with the Bureau then develop specific projects to manage the identified priorities in the non-federally registered sector. The extent of the Agency risk management activities are dependent on the resources available.

The Agency believes it is making sound progress in improving its capacity to assess and manage overall risk in the Anon-federally registered A sector.  It  will continue to work with OGDs, provinces and territories to enhance the methodology to carry out overall risk assessment of the Anon-federally registered@ sector.  Progress will be reported in the performance report to Parliament for the period ended 31 March 2003.  The Office of the Auditor General will be kept apprised of progress. 

RECOMMENDATION No. 3

    That the Canadian Food Inspection Agency engage in discussions with its provincial and territorial counterparts about their respective roles and responsibilities in managing the non‑federally registered sector. That the Agency report the results of these discussions in its performance report to Parliament for  the period ending

 31 March 2003.

Recognizing the shared responsibilities of the federal government and provincial, territorial and municipal governments for food safety and inspection,  the Agency works in close cooperation with several federal-provincial-territorial committees and has established a large number of bilateral work sharing agreements with the provincial and territorial governments. Bilateral agreements are in place or are being negotiated with all provinces and the Northwest Territories; five have been recently updated.  These arrangements include  a number of bilateral umbrella agreements aimed at coordinating federal, provincial and territorial inspection services and a number of subsidiary agreements covering such areas as food safety, management of shellfish harvesting, dairy inspection, egg and egg product inspection, non-registered food establishment, food recalls, investigation of foodborne illness etc.

Three Committees exist to coordinate federal-provincial-territorial activity: a policy committee, an inspection committee, and an overall umbrella committee. The Agency co-chairs the umbrella committee - Canadian Food Inspection System Implementation Group (CFISIG).  The Agency also participates in the Federal Provincial Territorial Committee on Food Safety Policy (FPTCFSPP and co-chairs the Federal Provincial Territorial Agri-Food Inspection Committee (FPTAFIC).  These national committees coordinate national food safety policy initiatives (standards and inspection approaches) and serve as the national fora for the exchange of scientific and technical information.  The goal is to foster cooperation and coordination of food safety initiatives at all levels of government.

The CFIA continues to cooperate and consult with the provinces and territories, industry and other stakeholders on issues related to the non-federally registered sector and will continue to participate in national coordinating bodies and in bilateral agreements to ensure that roles and responsibilities continue to be clear and well understood.  Progress will be reported in the performance report for the year ended 31 March 2003.

RECOMMENDATION No. 4

    That the Minister of Health table, in Parliament, the Agency=s status report from various initiatives related to the implementation of an overall strategic approach pertaining to the management of imported commodities, including the requirements of Bill C‑80 should it become law. That this progress report be tabled no later than 31 March 2003.

This recommendation should be addressed to the Minister of Agriculture and Agri-Food, rather than the Minister of Health.  Furthermore, it should be noted that the Canada Food Safety and Inspection Act (formerly Bill C-80) died on the Order Paper when the election was called in the Fall of 2000.  It has not yet been re-introduced.

The Agency prepared a discussion paper and draft import policy (October 2000) to provide a strategic direction to enhance and guide the integration of the various import control systems within the CFIA.  As progress is being made in all areas of import controls, an Agency-wide import policy and strategy guide programs, such as  developing comprehensive import control programming.  Areas of particular attention include managing the border; managing the tools CFIA uses to mitigate the risks presented by import trade flows; managing information and technology; managing the introduction of importer quality management systems; taking full advantage of Canada=s international rights while respecting its obligations; and managing the continuum of CFIA inspection control activities.   The CFIA works closely with the Canada Customs and Revenue Agency on import issues.

In the post-September 11 environment, attention has focused on border and inspection issues.  The 2001 Budget provided the CFIA with additional resources to respond to public security issues, such as enhanced border controls, increased surveillance and detection activities and upgraded science and laboratory capacity.

The development of an integrated CFIA response on these issues will contribute to positioning the Agency for the future and enhance our ability to anticipate and respond to the changes underway in Canada and internationally.

Progress on this front will be reported in the performance report for the year ended

31 March 2003.

RECOMMENDATION No. 5

    That the Canadian Food Inspection Agency provide in its annual report, its report on plans and priorities as well as its performance reports to Parliament, information on human resource management matters and challenges facing the Agency, particularly on current and future human resource requirements by occupational groups, the progress of various recruitment and training initiatives together with information on results expected and achieved. That the Agency commence reporting this information in its performance report for the period ending 31 March 2003.

The Agency will continue to report on Human Resource Management initiatives, outputs and results in the CFIA using  a balanced approach that reflects both our human resource achievements as well as those areas requiring development.  The Agency has developed the  capacity to forecast and assess its recruitment and retention needs.  In January 2001, CFIA completed a statistical study of all occupational groups which resulted in the identification of occupational groups facing the greatest recruitment and retention challenges.  Targeted recruitment and retention strategies are being developed to address the specific issues of these critical groups. 

The CFIA is in the second year of its Officer Training Program, (OTP), an innovative, 12‑month training program targeted at new and recent graduates who are interested in exploring challenging and rewarding positions with the CFIA.  The program consists of up to three work placements within the various business lines and geographic locations of the Agency.  Recruits also participate in formal learning assignments and are assigned a mentor.  This program has been very successful in contributing to recruitment objectives.

The Agency continues to make improvements towards the establishment of an Agency-wide approach to the collection of recruitment and training information so that complete training information required for business analysis and reporting purposes is captured.  

As well, our Human Resource Performance Measurement Framework is helping the Agency in identifying what needs to be measured as well as a consistent approach to collect/ analyze data and to produce reports.

Progress will be reported in performance reports for the year ended 31 March 2003.

RECOMMENDATION No. 6

    That the Canadian Food Inspection Agency develop a more formal strategy for managing the implementation of the Hazard Analysis Critical Control Point approach. That the Agency present a  progress report on its implementation in its performance report to Parliament for the period ending 31 March 2003.

The Agency considers that it has an effective strategy for managing the implementation of the Hazard Analysis Critical Control Approach.  The Agency=s HACCP strategy involves a mix of mandatory and voluntary initiatives to the application of HACCP based control systems by the industry.

The CFIA presently has two programs that incorporate HACCP systems into their program requirements. These are the Quality Management Program (QMP) for the fish and seafood sector and the Food Safety Enhancement Program (FSEP) which applies registered meat, poultry, processed products, dairy, honey, maple and egg establishments.  In addition, the CFIA has also been actively involved with industry-led HACCP-based initiatives including the Canadian Food Safety Adaptation Program and the On-Farm Food Safety Program.

The QMP program was one of the first mandatory HACCP programs in the world, and has evolved to include prerequisite safety components, recall procedures and other regulatory action points (quality, packaging and labelling).  The FSEP program is presently voluntary.  The government is in the process of introducing mandatory HACCP requirements for the federally registered meat sector.   Establishments which have developed and implemented HACCP plans on a voluntary or mandatory basis are moved from a traditional inspection approach to a more audit-based government verification of the establishment=s controls.

In support of the Agriculture Policy Framework (APF), the Agency is working with Agriculture and Agri-Food Canada, provincial governments, and industry associations to develop and implement a recognition process for industry-developed On-Farm Food Safety Programs (OFFSPs).

In June 2001, the Agriculture Ministers= Whitehorse Accord identified the a step-wise approach to HACCP recognition.  The approach involves seven steps in which the CFIA in cooperation with provincial governments lead the first and last steps.  These consist of official recognition of the technical soundness, including regulatory requirements, and the effectiveness of the OFFSP national administration by industry.  The intermediary steps combine to create a documented program that will be implemented and audited by registered third-party auditors.  Although industry is responsible for these steps, the CFIA is an active participant, providing advice in program development. 

Approximately ten national associations have expressed their intention to forward their applications for OFFSPs for technical review by CFIA by the end of 2002.

Progress will be reported in the performance report for the year ended 31March 2003.