:
Thank you, Mr. Chairman and members.
Thank you for inviting the Canadian Supply Chain Food Safety Coalition to appear during your hearings on this important subject.
The coalition was formed in December 2000 and incorporated in 2007 to act as a single, strong voice for industry along the food chain, together with the public and government, on industry-wide food safety issues. Our membership is composed of the national, provincial, and regional associations involved in the agrifood industry and the individual companies that provide services to that industry.
As you can see from the membership list attached to our submission, we represent organizations whose members encompass every link in the supply chain, from input suppliers through to primary producers, transporters, processors, manufacturers, importers, and final marketers at the export, retail, and food service stages.
Our mission is to facilitate, through dialogue within the food industry and with all levels of government, the development and implementation of a national coordinated approach to food safety to ensure credibility in the domestic and international marketplaces.
Over the past eight years we have been actively involved in consultations with ministers and officials at all levels, and in intra-industry discussions, about the future shape of Canada’s food safety system. We see the work of your subcommittee as a valuable opportunity to continue this work and to realize our vision: that Canada's agriculture, aquatic, and food industry will have a world-class reputation for producing and selling safe food.
In March of this year the coalition completed a year-long project to develop a national strategy for industry-led food safety programs. Copies in French and English have been circulated to you prior to this meeting.
The participating organizations, members, and non-members of the coalition who worked on this strategy determined that it should be grounded in a set of four guiding principles.
The first principle is that food safety is a shared responsibility of all participants in the supply chain, all levels of government, and consumers.
Our second principle is that governments at all levels, the agrifood industry, and other stakeholders should foster and facilitate the development of an integrated and coordinated and national approach to food safety policy and regulation, based on sound scientific risk assessment and risk management principles and international standards.
Our third principle is that industry and government food safety initiatives should encourage the implementation of HACCP and/or HACCP-based food safety systems by businesses all along the supply chain.
Finally, our fourth principle is that food businesses, governments, and other stakeholders have a responsibility to adequately resource and proactively manage, update, maintain, and continually improve their individual and collaborative food safety systems and food safety initiatives.
I'll touch on each of these principles in brief.
Businesses involved along the agrifood supply chain clearly recognize that they have a responsibility for food safety, which they share with governments and consumers. This is not a recent recognition or awareness; Canadian agrifood businesses and their associations have consistently and continually advocated this approach, especially over the past two decades of rapid change in the Canadian and global approaches to food safety. We ask you to endorse this principle of shared responsibility in your final recommendations.
We fully recognize that under our constitution, the jurisdiction for food safety is divided amongst the senior levels of government, and in some cases is delegated to the municipalities or other agencies within provinces and territories. However, our members and the agrifood businesses they represent firmly believe that Canada should have one national approach to food safety. Canadians, no matter where they reside or purchase their food, are entitled to the same level of assurances about its safety—assurances that should be based on common standards and expectations.
A corollary of this statement is that agrifood businesses within each link of the supply chain should be asked to operate according to common standards and expectations within and amongst the responsible jurisdictions. Our expectation of imported food products should, as a matter of course, be the same as our expectation of our national system.
Our national strategy sets out some very clear goals with respect to this principle. They include the need to revise the federal-provincial-territorial vision of a national approach to food safety, last looked at in 1994, based on an agreed set of principles. There is a need to establish a national decision-making mechanism for food safety policy and regulation in Canada. We need to clarify the role and the scope of national codes, industry-led food safety programs, food safety objectives, and other food safety requirements, and integrate food-safety-related discussions across departments within each government. We also need to open the lines of communication between government and industry groups in order to encourage collaboration on the future evolution of food safety policy, objectives, systems, etc.
We are aware that the federal, provincial, and territorial officials have been discussing the development of a national food safety strategy since at least 2003. In February of this year the agriculture ministers requested a food safety action plan. We are also aware that this national approach has been taken in Australia and within the European Union, and it is now under very active discussion in the United States. Models and best practices exist within federal systems with joint jurisdiction. These can be studied and perhaps adapted to our needs.
Therefore, we ask the subcommittee to strongly endorse this principle, the establishment of a national coordinated approach to food safety, in your report and make clear recommendations about the process by which it could be achieved.
Starting in the early 1990s, Canadian agrifood businesses and their national associations have cooperated with governments to develop and implement HACCP and HACCP-based food safety systems. You are aware that Canada was a pioneer in the field of HACCP and a major contributor to the development of the international approach through the Codex Alimentarius Commission. HACCP food safety systems have been implemented in federally registered establishments, in some provincial registered establishments, and in larger, more complex non-registered establishments. Canada has also been a pioneer in the development of HACCP-based food safety systems for micro, small, and medium-sized businesses that do not have the resources to develop and implement a site-specific HACCP food system.
Over the past 15 or so years we have seen the members of the coalition and other industry associations work closely with the federal, provincial, and territorial governments to develop and implement national HACCP-based food safety programs for almost every segment of the supply chain. For example, we now have 22 national HACCP-based, commodity-specific, on-farm food safety programs covering approximately 99% of primary production. For other segments of the supply chain, industry associations have developed or are in the process of developing and implementing at least 14 national programs.
The development of these initiatives has involved significant investments by individual agrifood businesses, by their industry associations, and by the federal government. So successful has this collaboration been that governments have renewed their funding initiatives under Growing Forward and the recently announced Canadian integrated food safety initiative for some of the key components of that collaboration.
Industry-led HACCP and HACCP-based food safety systems are now an integral part of Canada’s food safety approach. They are a necessary complement to the capacity of governments at all levels to engage in direct inspection and audit activities.
Our strategic document strongly endorses continued investment by agrifood businesses, their associations, and governments in both the implementation of these systems and in their continuous improvement. We ask you to endorse this concept--the implementation of HACCP and HACCP-based programs by businesses all along the supply chain--in your report.
Establishing principles is a first step. Developing the tools that are needed for a coordinated national approach is clearly a challenge, but a manageable one. But ensuring that these systems are adequately resourced, proactively managed, updated, maintained, and improved will be the real test of the Canadian approach to food safety.
Our national strategy sets out a number of goals and actions for industry, for other stakeholders, and for governments in this area. They include promoting awareness of the Canadian food safety programs; strengthening Canada’s food safety training and auditing infrastructure; increasing the pool of qualified food safety personnel; establishing quality consistency across food safety specialists, including consultants, trainers, etc.; and strengthening federal, provincial, and territorial support for industry-led food safety initiatives. We ask the subcommittee to endorse this principle as well and include recommendations concerning the resourcing of government food safety initiatives and concerning the development of the infrastructure needed to ensure that industry's activities can be updated, maintained, and improved.
In conclusion, the Canadian Supply Chain Food Safety Coalition would like to thank the subcommittee for asking it to make this submission. Your inquiry into food safety comes at an important time in the evolution of the Canadian system. As we have discussed, governments--federal, provincial, and territorial--are actively considering new food safety initiatives. As parliamentarians you are expecting amendments to the Food and Drugs Act to be introduced, I assume, in this session. Your recommendations will have a major impact.
We ask that you carefully consider our recommendations and the detailed contents of the national strategy for industry-led food safety programs, which we have tabled with you. They represent a strong consensus on the part of the agrifood supply chain and of our members about the future direction of Canada's food safety system.
As a final point, we would like to say on behalf of our members that the coalition is ready to engage further with this subcommittee or with other committees of the House as changes are made to the Canadian food safety system.
Thank you very much.
:
Thank you very much for the opportunity to be here and to address you on behalf of the Canadian Health Coalition.
I won't say very much about the coalition. It's national, largely voluntary, has a small staff, and is very active in several provinces, particularly Ontario and British Columbia, in addressing issues of public health in the broadest sense.
I've just been asked to fill in for Michael McBane, who is elsewhere today. I am an independent writer, author of half a dozen books on food, agriculture, genetic engineering, and corporate control. My wife and I have published for 30 years now The Ram's Horn, a monthly newsletter of food systems analysis.
Many issues concerning food safety have been in the news, of course, in recent years. I am sure you have considered and heard about many of them, from bovine spongiform encephalopathy--a still-unsettled controversy, I should say—to listeria, salmonella, bird flu, and the current so-called H1N1 swine flu pandemic.
It's very tempting to get drawn into a discussion of particular diseases and how they have been dealt with or not dealt with. I don't intend to do that, because I think they are all manifestations and consequences of the way we have allowed our food system to be organized and constructed. To look at particular diseases and public health issues one by one strikes me as kind of like that story about picking babies out of the water, out of the river, without ever asking who's throwing them in.
Public Safety Minister Peter Van Loan summed up very simply the issue that I wish to focus on when he tried to explain why the government decided to shut down six prison farms: “...it's simply a fact that the type of agriculture practised on the prison farms is totally unrelated to modern, high-technology, capital intensive agriculture.”
While Mr. Van Loan's statement may be true, it is not modern, high-technology, capital-intensive agriculture that actually feeds most of the global population, either today or at any time. In fact, it is a growing diversity of foods for the local population that is actually how people feed themselves. The prison farm style of agriculture, which supplied the prison population and the community, is closer to this global practice than it is to the high-tech industrial agricultural system that Mr. Van Loan pointed out.
The CFIA was created in 1997. I remember the discussions about its creation and all the issues therein. I would say that it has remained true to its not explicitly stated mandate to serve modern, high-technology, capital-intensive agriculture. Therein lies the source of the problems of food safety and public health that are being investigated by this committee. It is the structures and practices of industrial agriculture and food processing and distribution that are the source and multipliers of the public health problems the CFIA attempts to address but is handicapped from doing because of its mandate, which is to promote and protect this industrial food system. Instead, it has sought to polish its public image by trying to clean up, through HACCP and other means, and more and less regulate out of existence, small-scale, local, and regional food production, processing, and distribution in favour of large-scale, centralized, export-oriented corporate agribusiness.
This is unequivocally illustrated by the CFIA's treatment of small-scale local abattoirs, or its outlawing of the sale of fresh eggs at farmers markets unless they have been through the grading process, which has been mandated for eggs produced in 60,000-bird layer factories. The same thing could be said of pork, beef, and everything else.
The fact is that diseases like avian influenza are the products of intensive, large-scale, industrial poultry production, whether in Malaysia or in Canada, and not backyard flocks anywhere in the world. Just ask the farmers of the Fraser Valley of British Columbia.
Bacteria and viruses, such as listeria, salmonella, BSE, avian flu, and swine flu, are all virtually inevitable products of large-scale factory production of meat, eggs, and even vegetables. Monocultures of any sort invite attack by opportunistic bugs. In addition to monocultures are the conditions of intensive production, as in poultry, swine, and feedlot beef, and the conditions are ripe for the spread of all kinds of unwelcome guests.
No amount of downstream sanitation and regulation is going to alter this condition. If public health, efficiency, and sound ecology were to be the mandate of an agency charged with protecting and enhancing the health of Canadian people and the food we eat, this agency would have to call for a radical deconstruction of our current industrial production system and its control by a handful of giant corporations.
In each and every sector of the food system, from seeds to supermarkets, there are essentially three corporations that rule the roost, and these corporations are required to serve the interests of their shareholders, not the public. That's their legal, fiduciary responsibility, after all. It is the interests of these giant corporations that are served and protected by Agriculture and Agri-food Canada and the CFIA. This is what modernization of the seed regulations, streamlining of the regulatory process, removing the obstacles to innovation, and self-regulation are all about: corporate wealth, not public health.
Farmers and gardeners growing food for themselves, their neighbours, and their local markets are not going to poison themselves and their customers. They are highly unlikely to be breeding diseases. They would quickly be identified and soon be out of business if they were. Trust, after all, is the foundation of any functioning economy.
Factory farms and giant meat factories can write off the millions of dollars lost as a result of a disease outbreak caused by its products and carry on as before, with only some modifications to its operations as requested by the CFIA--another inspection process or two--and the CFIA no longer has the capacity to ensure that its rules are being followed. The only question is, when and where will the next disease outbreak occur?
I suggest very strongly that it's time--well past time, in fact--for a radical deconstruction of the global industrial food system for the sake of public health and the environment around the world. It is time to create a public agency dedicated to ecological farming, including animal and plant biodiversity, healthy food, food production for local and regional markets--not export--and the assurance of adequate nutrition for all. A genuine food system, in other words, dedicated to public health.
l realize this is a big challenge, but it is time for Agriculture Canada and the CFIA to get out of the corporate bed. It is time to make healthy soils, clean water, and ecological farming the basis of our food and agricultural policies. The problems currently identified as issues of food safety would largely disappear, and rural communities and local economies would thrive as they provide healthy food for all of us. It's a big but essential challenge that l am presenting, I realize, but I think the times call for it.
I would be pleased to discuss this further with anyone, and I thank you for the opportunity to present this to you.
:
Well, I've been growing this one for a very long time and losing this one for almost as long.
What we're looking for is a commitment on the part of governments to move towards that kind of an approach. There have been various initiatives in the past where governments have assigned officials to develop national codes, whether they were for horticulture, for dairy, or for retail and food service. What we saw happening then was provinces falling out of step with that objective, for various reasons. Some of them have to do with getting time on the agendas in provincial legislatures; some of them have to do with other things. But we don't see much progress down that road.
Starting with ministers of agriculture or agrifood and ministers of health, we would like to see them make that very strong comment to the principle of a coordinated approach, and secondly, then, launch a process that would involve themselves and their governments, and industry stakeholders and other stakeholders, consumers and others, in the discussion as to how to get there.
We see, as the brief pointed out, some very interesting examples as to how that could be done. Whether they would fit in the Canadian context, with all of our challenges and our history, that's another question, but I think great progress could be made down that road. In the end it probably would see some differences still remain, and whether those would be regional, that's possible, but it more likely would be provincial in that sense. What we'd like to see, though--I really don't like to use the phrase “minimum standards”--is a good, strong set of basic national food safety standards and approaches. That way, industry all across the country, whether farmers, input suppliers, manufacturers, or retailers and food service, would be able to say, “Okay, this is what we're trying to get to”, and everybody is trying to get there.
:
Thank you for your question. It's very much to the point.
I should say that my wife and I have farmed for 15 years. We raised our children on the farm. We raised sheep and lambs for the market. Very early on--we started with no experience--I got the local agriculture representative to come out and I asked him what we should do. He said we should grow corn. Well, we happened to be farming on glacial till of Nova Scotia, and the last thing you want to do is stir up those rocks. But that was a uniform program for the province. Corn was what was on the menu that year. So it really didn't matter where you were.
That was a pretty good lesson for us, a good introduction.
But we've seen, over the years, the movement back from agriculture of the federal government. Now if I were to ask an agriculture rep for some advice, I would get some consultant who might work for Cargill or one of the other agribusiness industries, who, obviously, would have a product to sell. I think that sums up where we've gone in 30 years.
So the government, in a sense, has privatized any public responsibility it had for agriculture. It's now engaged in plant breeding, or across the board trying to.... If you want to do research, you have to have a corporate partner. This means that it's the corporate agenda that is followed in every instance.
What we're calling for is actually a federal agricultural policy, an agriculture and food policy that has as its basis the health and welfare of the Canadian people and the economy, based on local production for local consumption, and reducing....
My first book, actually, talks about the characteristic of our industrial system as maximizing the distance between where your food came from and your mouth. And what we're seeing now is a move across the country with local food to reduce that distance, to shrink it back.
The federal government has a tremendous responsibility that it needs to take up on behalf of the Canadian people to redesign.... I shouldn't say redesign, because I think we do have to start all over again and rethink what agriculture is all about. Their current policy is about export and balance of trade, not public health. I think that's fundamental. That basic mandate needs to be reorganized.
It would mean shifting, for example, in plant breeding and animal science, and so on, to much stronger public support for public programs and public science, for the benefit of everybody. It would mean a different kind of education--and again, this should be directed in concert with the provinces right across the country--not to have a uniform program, rather to have programs that would meet certain criteria, standards in a sense, but that would have to be tuned, as with any farm, to the local ecology. What do you actually do on the prairies? What do you do in the Maritimes, or in the coastal fisheries in B.C., or the inland fisheries in Manitoba?
I would suggest that this would need to be done in conjunction with Health Canada. Our understanding of health has to begin with healthy food. It's interesting. Almost invariably, the people we talked to who have been through cancer treatments have switched to organic diets.
:
Mr. Bellavance, I think you're quite right, that we have a very uneven system in terms of food safety across the country and in terms of traceability at this point as well.
What the coalition is seeking is opportunities for governments and industry and other stakeholders to come to a consensus about where we should be trying to get to in the future. It may be that the best practices are currently enshrined in a provincial program in a particular province, or they may be best practices at the federal level already, or they may be best practices in what industry is already doing, which is ahead of federal, provincial, or territorial governments.
So we'd like to see that consensus-building, decision-making process, but you also have to understand that many food businesses function across provincial boundaries, and what they find themselves faced with is different sets of requirements in different provinces. Some may be industry-leading, some may be lagging behind, and others may be quite different. They may achieve the same objective, but they may require the company to do quite different things in order to get there, which means that those companies have to retool and redesign their food safety management practices in order to meet these different jurisdictions.
And it's not just an issue between provinces and the federal system. It can also be a matter of concern within provinces, where at some levels, in some provinces, jurisdiction has been devolved down to local regional authorities and you can, so I'm told by some of my members, without actually leaving greater Toronto, cross between food safety requirements on one side of a street that are different from those on the next side of the street.
So our desire, from an industry perspective—and this goes from the farm level all the way through to the final marketers—is to have as close to a consensus as we can on what those standards should be and the opportunity to meet them on an equal playing field across the country.
:
It always intrigues me when folks come before us. Everyone talks about a science-based food safety system and everyone leans on HACCP in a lot of ways, in the sense of that being...I don't want to call it the crutch, but it seems to be the support mechanism by which they say this is a science-based system.
We had a witness here last week who talked about systems and systems analysis. In fact, that's what he did for a living for a long time. He was probably hired by many of your members over the years to actually come in to look at their systems. He talked about how systems fail.
This overreliance, in my words, on this science-based system gives one, in my estimation, a false promise in a lot of ways, in the sense that simply because it's science-based, that makes it work. Let me just point to this HACCP system, which has what they call a CVS piece to it, a compliance verification system, which was run out as a piece of the model that all accepted. In fact, I would suggest that members of your coalition were probably quite keen to do so, and yet they ran it out as a pilot and no one ever verified if it worked.
Now, I took science in university, but I'm not a scientist by any stretch of the imagination. It seems to me that if you're going to have a system that you try and it is supposed to give you a certain result, it's like the hypothesis you used to get when you started out to do an experiment. You started out with a hypothesis, you had a methodology, you did the experiment, and then you verified it and came to a conclusion. But if you leave out the verification, how do you know it worked?
If you're talking about science, and if part of your science-based program is to verify, but you don't ever find out whether the system that talks about verifying actually indeed works, do you really have science? Do you have a science-based system or do you have a system that really has the name “science-based”? So everyone out there who hears the terminology goes, “Oh, it must be safe because it's about science.” In reality, what you have as a system is a shell with nothing inside it.
How do we get to the point where we actually build the system, where everyone says this is how we do it, and then we verify it and we all agree upon the verification of it, so that we indeed have a science-based system that truly is based on science, not on someone's wishes?
:
You've asked a number of questions there.
I'll try briefly to deal with them, Mr. Chair.
First of all, I'd encourage the committee to think about HACCP or HACCP-based programs as having been constructed using a very powerful tool of analysis. HACCP is a toolkit that you use to apply the best knowledge available to the organization that's developing the program about what the hazards are and the measures that can be taken to control those.
HACCP is a component of a good food safety management system. There are other components to a food safety management system, and I think the witness last week was talking about some of those components. Unfortunately, I didn't stay past the ringing of the bells and the vote in order to hear all of his comments.
If you look at a standard, and let's say ISO 22000 is an example of a food safety management system standard, there are some definite best practices built into that standard that would require the validation that a system is actually delivering the results it was intended to produce. Those principles need to be applied, whether they are government mechanisms or industry mechanisms, in order to provide greater assurance.
HACCP is not a silver bullet. HACCP or HACCP-based systems are not perfect, but they are the best practice we have now as to how to develop a food safety management system, and the associations that are part of the coalition have definitely endorsed that approach. It is consistent with the international approach endorsed by the Codex Alimentarius Commission. All of our largest trading partners have gone, and are still going, down that route, and there are new advances that will add to it, which we should be looking at as to how we move forward. You'll see some of that in the government's safe food strategy, the FPT safe food strategy, when it comes out.
:
Thank you, Mr. Chairman, and thank you, witnesses, for being here today.
Mr. Chambers, I take a lot of what you're saying to be very good information, and I appreciate your comments and your presentation to us today.
As you know, along with what we're doing as a subcommittee, Sheila Weatherill is doing an investigation that will be completed in July. One of the things the subcommittee actually agreed to and wanted was to look not only at listeria but at food safety in a general context. I think we see the value of that, given the amount of discussion witnesses have had and have talked to us about. It has not only been in terms of listeria, which was one issue we dealt with--unfortunately had to deal with--last summer, with the loss of life. I think what we're seeing right now and what we're hearing, and all my colleagues, I think, agree, is that this is a bigger, broader issue. We want to make sure that the food system and the integrated line of food is protected and safe, basically from the farm to the fork, I guess, which is one of the analogies we use.
I think during this I've continually heard also that in terms of food safety, whether it's listeria or general food safety, we share that responsibility, and not only as a government. It is shared by everyone from the farm to the fork, basically. Do you share that concept that it is actually a shared responsibility?
I think what we also heard is that there may be some glitches, under lessons learned, that we need to improve upon. I'm wondering if you could just help me. What are your thoughts on shared responsibilities but also on where we have gone since that incident last summer in terms of food safety?
:
Thank you both very much.
As we are coming to the end of the hearing part of this, we're very interested in what specifically you think should be done. Obviously, some of the issues around traceability and the idea that you would end up being able to better respond are going to be essential. But I was quite concerned, in reading the report for the Public Health Agency of Canada, that FIORP--the way the government has organized to respond to an outbreak--it seems hasn't been updated since 1999. Most people didn't even know about the agreements or how different departments and jurisdictions have dealt with one. But in looking at FIORP, Mr. Chambers, I don't see the industry even there, in terms of being part of the communication plan, or of how you would do this.
We thought we had learned the lessons from SARS about what cooperation, collaboration, and communication were, and had gained a clarity concerning who does what, when, as David Naylor's report told us. It seems to have worked pretty well in H1N1, given the fact that for pandemic preparedness there have actually been meetings and an approach to communication across departments, across jurisdictions, and with the private sector.
I would like to know what your recommendations would be as to how industry would fit in to some sort of planning for the future, particularly given that the confidence of Canadians relies heavily on the communication plan and everybody being on the same page. As we saw in the outbreak last summer, it seemed that Maple Leaf Foods' Mr. McCain was the communication person and everybody else just fell in behind.
I would love to have your recommendation, as the Supply Chain Food Safety Coalition, and I want to know why your coalition didn't tell these guys to get this plan fixed over the last ten years.
:
I guess I would answer that question in a couple of ways. We haven't gone down to that level of detail because we've suggested very strongly that we need to have a very good discussion as to what that model would look like and what the commitments would be. We're trying to get governments to agree that there needs to be that discussion in the first instance, and then to elaborate that.
Clearly, jurisdictions have responsibilities and budgets, and all these things, which they have to sort through, but if they put food safety as the priority we believe they would if we did have a national strategy and we did have national decision-making mechanisms, then I would hope they would put the resources into it as well.
I'll answer another part of your question by pointing out that during a forum the coalition held with federal, provincial, and territorial officials and industry representatives in 2003, it identified that we needed to have, in a national agreement or consensus, or whatever it's called, a common standard for the qualifications and competencies of food safety auditors, whether they are working in companies in audit and certification programs by third parties, or for governments—federal, provincial, territorial, or municipal.
You'll note that in our national strategy, completed at the end of March, we are still promoting that idea, because six years later we have yet to convince a government—federal, provincial, or territorial—this is something that needs to be done.
So there are infrastructure issues like that on which we need to move ahead before we can have the comfort we should have in the quality and competence of the persons working in the industry and government with the responsibility for verification, etc., in these things. I'm not saying these people are incompetent; what I'm saying is that we need to have an agreed upon standard by which that competence can be judged. That in itself will bring greater confidence to our system, from the perspective of Canadians, food businesses, governments, and from our customers outside of Canada.
And that's just one example of the long list of things we have in our national strategy document. Going back to Ms. Bennett's question on what suggestions we have, we have a long list of suggestions in the basic document.
I'm here today representing the Canadian Federation of Agriculture. I sit as co-chair of their Food Safety Committee.
Let me start out by saying that the Canadian agriculture and agrifood industry does produce safe, high-quality food to sustainable environmental standards. Since the early 1990s, Canadian farmers, in partnership with governments, have taken leadership in developing national systems to strengthen our food safety commitment and in working in partnership with Agriculture and Agri-Food Canada and the Canadian Food Inspection Agency to develop the Canadian approach to on-farm food safety.
The Canadian approach entails the development of auditable, national commodity-specific programs and the creation of strategies and the necessary tools to educate producers and to implement national on-farm food safety initiatives consistent with the Codex Alimentarius' hazard analysis and critical control point--HACCP--definitions and with CFIA's on-farm food safety recognition program.
Agriculture and Agri-Food Canada has co-funded and assisted in the development and implementation of the national on-farm food safety programs since 1997. While no food safety system can assure zero risk, it's a primary goal of the Canadian Federation of Agriculture to ensure the continued development of strong, sustainable, industry-led food safety, traceability, and animal health systems for the greater public benefit of Canadians. We thank you for the opportunity to address the members on some of the key requirements that we feel are needed to ensure this continues.
Canadian farmers have taken leadership in developing national systems for food safety, but the implementation and ongoing management is costly. These initiatives contribute to the public good and greater welfare of Canadians, but have returned little or no value from the marketplace. There are no premiums for safe food. With already low incomes, the sustainability of these food safety systems is strained. In order to support the continuation and strengthening of these systems, ongoing financial commitment and partnership from the public and from governments is required. The Canadian Federation of Agriculture also advocates for government support for enhancing Canada’s reputation as a provider of high-quality, safe food through a government-funded communications plan that raises awareness at domestic and international levels on the strong food safety and quality systems that Canadian production has implemented. This plan would help in achieving marketplace value for the initiatives the industry is putting in place, and it would support the competitiveness of Canadian agriculture.
On industry leadership and industry-government partnerships, first, through a program called the Canadian on-farm food safety program, which ran between 1997 and 2004, and later through the Canadian food safety and quality program, Canadian producers, in partnership with AAFC and CFIA, have proactively led and designed the science-based Canadian approach to on-farm food safety. It's through this industry leadership that 19 commodity groups, with 22 commodity-specific programs covering 99% of all Canadian production, have now completed or are completing the development phases of their HACCP-based on-farm food safety systems.
Producers are wary of increased costs in a very competitive marketplace. They are also extremely concerned about government downloading of costs, administration, and regulation. Producers, however, are also keenly aware of the need to ensure the safety of their products. It’s for these reasons that industry must continue its leadership in on-farm food safety and that its development be a strong industry-led partnership with governments.
Through CFA, the national commodity organizations, and the Canadian On Farm Food Safety Working Group, development of on-farm food safety systems has been a success, efficiently allocating funds, conducting industry research, building buy-in from producers through their own organizations, and maintaining accountability to Canadians through yearly third-party financial and compliance audits.
Without that partnership, the CFA believes the strong progress, producer buy-in, and ultimately success in developing strong on-farm food safety systems would not have occurred. To date, this has been an excellent example of how industry-government partnerships can be a very effective tool in delivering services while saving costs to taxpayers.
On-farm food safety programs are only effective if they are implemented. CFA believes it is imperative to have a well-funded, strong on-farm implementation program available to national producer organizations and their provincial counterparts to use, to implement the national food safety systems. CFA welcomes the establishment of incentive-based programs for food safety initiatives and strongly believes flexibility and incentive-based programs are much more effective at achieving progress compared with inflexible regulatory approaches. However, the recent shift to provincial delivery versus federal under Growing Forward has raised concerns that access to funding may vary across provinces, creating a patchwork approach to the food safety program.
As we move from the APF to the Growing Forward program, CFA recommends the following: significantly streamlining the approval, processing or agreements to improve the ability to obtain contracts or extensions in a timely fashion; and much greater flexibility for use of funding in the areas of training, human resources, purchase of equipment, and full audit cost recovery. CFA also recommends that Canada pursue clearer language on equivalency that will make it more incumbent on countries to allow imports where the food safety protection afforded by exporting countries’ inspection programs is at least equivalent to that of the importers, even if the modus operandi is different in certain aspects.
Traceability is the ability to track movements of animals and goods through the supply chain. It is an important tool for agriculture. There is a significant public good in the development and implementation of traceability systems in the areas of the protection of plant and animal health and in the area of food safety. Many initiatives are currently under way to implement traceability systems at the farm level and throughout the chain. However, traceability standards alone do not make food any safer; they simply make it easier to track.
CFA welcomed the decision of federal, provincial, and territorial ministers of agriculture to develop and implement a national agriculture and food traceability system in Canada and has called for a system comprising all food production, including primary producers and along the value chain, and building on national standards.
In addition to the obvious benefit to government in protecting the public, a national identification and traceability system would constitute a risk management tool that can greatly improve the competitiveness of the industry as it would allow for identification of contamination sources, reduction of response time in the event of a crisis, and minimizing the economic impacts of a foreign animal/plant disease outbreak or a food safety crisis disease outbreak in Canada. Reduced economic impact results in less industry reliance on government risk management programs. A successful agricultural industry reflects on the economy of the country.
A national traceability system would allow the industry to seize opportunities for reinforcing our domestic and export market access while responding to the growing need of consumers across the globe to know the origin of their food. It would also support Canada’s on-farm food safety systems and aid efforts in eradicating domestic animal/plant diseases and elimination of foreign animal disease incursions.
It is therefore important that governments provide leadership and support to ensure that the various traceability initiatives work and are able to communicate with each other. Governments must also assist industry in the event of an incident with trade loss or when receiving compensation. With respect to implementation, CFA again encourages the use of incentive-based systems as opposed to an inflexible regulatory system.
CFA supports a national traceability system that is compatible across the country, across commodities, along the value chain, and technologically compatible with international standards. In conclusion, we'd like to thank the committee for the opportunity to present to you on this very important issue.
The recommendations you make in June will have a significant impact on the food industry, and it's our hope that you'll bear our comments in mind and build on the strong, science-based Canadian on-farm food safety programs. The CFA and its members remain committed to working with government and all stakeholders to further strengthen the food safety system in Canada.
Thank you.
:
Good evening, Mr. Chairman and subcommittee members.
My name is Ron Lennox. I'm a vice-president with the Canadian Trucking Alliance, a federation of Canada's provincial trucking associations representing some 4,500 carriers and trucking industry suppliers nationwide. CTA is a member of the Canadian Supply Chain Food Safety Coalition, who appeared before you earlier this evening. With me is John Gyoroky, corporate dock manager and HACCP coordinator with Erb Transport. Erb is a family owned carrier based in New Hamburg, Ontario, specializing in refrigerated transportation, operating a fleet of 1,000 refrigerated trailers, 500 tractors, 150 straight trucks, and employing some 1,200 people and 140 owner-operators.
Erb was the 2008 recipient of Canadian Transportation & Logistics magazine's Shippers Choice Award, as well as the Premier Carrier Award from food giant Sysco Corporation. Erb Transport was also one of the first carriers in Canada to implement CTA's HACCP-based trucking food safety program, which I will speak to in a moment.
I had the pleasure last week of speaking before the full agriculture committee as part of its study on the competitiveness of the Canadian agrifood industry. During my remarks, I made the point that you can't have a competitive agrifood industry unless you have a competitive transportation industry as well. The same holds true here. Virtually every food product we consume is moved on a truck at some point, probably several times for that matter. If you want a full picture of the state of food safety, you have to look at every link in the supply chain, and trucking is a key component.
I'll keep my remarks fairly general. I want to give the subcommittee a sense of the regulatory landscape that the trucking industry operates in, as well as some background on CTA's HACCP-based program.
Most of you here this evening heard my description last week of the highly competitive nature of the trucking industry in Canada: 10,000 carriers employing a quarter of a million drivers, 375,000 people overall, and generating about $30 billion in annual revenue from the for-hire sector. The industry provides service to virtually every town and city in Canada and the U.S. and is responsible for about two-thirds by value of Canada's trade with the United States.
Erb Transport alone provides temperature-controlled service for 1,800 shippers delivering their food products to 24,000 consignees throughout Canada and the lower 48 U.S. states. It is often said that trucking is the most regulated deregulated industry in Canada. The days of economic regulation of trucking rates and routes are long behind us. The carriers nevertheless face the daunting task of compliance with federal, provincial, and state regulation in areas such as road safety, environment, and labour. While most of Canada's trucking industry falls under federal jurisdiction, we are nevertheless impacted by provincial and state regulation in areas such as vehicle weights and dimensions, where no fewer than 63 sets of requirements exist in Canada and the U.S.
Food is no different, where both provinces and the federal government set standards and regulate. The challenge for a trucking company is to ensure that they are familiar with and comply with the standards in all of the jurisdictions in which they operate. Government regulation is of course just one fact that will influence carrier practices in the safe transportation of food products. The second important consideration is the market. Carriers sell their services to food shippers, and if they want to win new freight contracts and retain existing business, they must meet the service standards they negotiate with their clients.
When it comes to the food business, there is probably nothing more important than meeting shipper requirements dealing with food safety. We have seen the irreparable damage that can be done to a food manufacturer or retailer, and the health risk to the public, if a food product is subject to chemical, biological, or physical contamination.
Food shippers have a very clear interest in ensuring that the carriers they use have standards and procedures in place to ensure vehicles are adequately cleaned and sanitized, that there is no cross-contamination of food products with other commodities, and that the cold chain is maintained throughout the transportation process, from the loading dock to the receiving dock. On the receiving end, consignees also need to satisfy themselves that food that arrives on their dock has not been contaminated during transport, and that they have procedures in place to monitor, for example, the temperature of loads during transport.
I'm certainly not here to suggest that the market is somehow a substitute for food safety regulation. But going back to what I said to the full committee last week, there is probably not a more competitive industry in Canada than trucking. A carrier is not going to last very long in this business if they fail to live up to their obligations to shippers in vitally important areas like safe food handling practices. It's not just about price.
In a similar vein, there are various things carriers can do to go beyond regulatory and shipper requirements for food safety, the most notable one being HACCP. I'd like to take a few minute to describe CTA's involvement in this area.
Back in 2001, CTA was approached by the Canadian Food Inspection Agency regarding the Canadian food safety adaptation program. It provided funding for HACCP-based programs to national associations representing the off-farm sector all along the supply chain. Our first question, naturally, was what HACCP stood for, because nobody on staff at CTA had heard of it. We were also reeling at the time from a spate of new security programs being introduced in the wake of 9/11, and the last thing we really needed was another project.
However, the more we talked to CFIA, the more we realized two important things. First, if CTA didn't get engaged in the development of a HACCP-based program for trucking, somebody else would do it for us, so better to steer the ship than just be along for the ride. Second, HACCP programs were beginning to spread among the customers we served, so we felt it important to give carriers a program they could adopt that would dovetail with shipper programs. We wanted to create a situation where a carrier would not have to comply with multiple shipper programs, but instead would have one that was uniquely tailored to our industry.
I won't go into all of the details, but CTA applied for and received funding from CFIA, and later from Agriculture and Agri-Food Canada under its food safety and quality program, to develop a HACCP-based food safety program geared specifically to trucking operations. We assembled an advisory team consisting of carriers, CFIA technical experts, and national food associations such as the Canadian Meat Council, the Canadian Council of Grocery Distributors, the Canadian Produce Marketing Association, and the Canada Grains Council. While CTA had overall responsibility for the project, the actual work of developing the program was contracted to Kasar Canada, a Nova Scotia-based company with significant expertise and experience in the development and implementation of FSEP and HACCP.
Work began in 2001 on the development of a strategic plan. A draft food safety program was put together with the input of the advisory committee. It was piloted by 10 carriers from across the country operating in different parts of the food industry such as meat, dairy, grain, and dry goods. It was revised according to the lessons learned during the pilot phase, and ultimately submitted to CFIA for technical review.
I'm pleased to note that in February 2005, CFIA advised CTA that our trucking food safety program, consisting of a set of core elements and supported by 10 product-specific modules, met the agency's technical requirements. CTA subsequently contracted with Kasar to deliver the program on its behalf and assist carriers on a consulting basis to integrate the trucking food safety program into carrier operations and to oversee implementation through annual audits.
I'll be perfectly blunt with you in saying that we've fallen short of expectations in moving our HACCP program into the marketplace. As of today, we have 14 certified carrier participants. Some, like Erb Transport, and Midland of Moncton, New Brunswick, are major players in the food trucking business. Other, smaller carriers in different parts of the country have also come on board. What accounts for this? There are several reasons I can suggest.
We believed from the outset that the major push for HACCP would come from the food shipping community, but it seems this took longer than expected to materialize. A lot of carriers got in touch with Kasar to learn about the trucking food safety program when it came out, but many backed off, saying, “We already comply with regulations. We're already meeting any additional requirements that our clients place on us, so we'll do HACCP if and when shippers demand it.”
One other thing carriers noticed when exploring HACCP was that they already did most of what was required, but they didn't have the detailed record-keeping systems in place to demonstrate compliance with HACCP principles.
Though my information is only anecdotal, I would say that the tide seems to be turning in this regard. As Mr. Gyoroky will attest, food clients are increasingly demanding signed food safety agreements from their carriers, including HACCP programs, perhaps in reaction to high-profile food safety incidents, perhaps in response to the huge attention given to food and product safety generally in the United States, and perhaps in response to inquiries such as these. Whatever the reason, we're beginning to see positive signs.
We had also thought that if the federal government were to confer official recognition on off-farm HACCP programs such as CTA's, they would have more cachet with shippers. While there has been a number of discussions between industry--under the auspices of the food safety coalition--and government representatives from CFIA, the discussions have not yielded anything concrete thus far.
Thank you, Mr. Chairman and subcommittee members, for allowing us to appear today. Both Mr. Gyoroky and I would be pleased to respond to any questions you may have.
Thank you.
:
Ms. Crews, I share your concerns about the costs producers will have to pay to ensure food safety. Your organization represents several thousand farm producers who want to provide consumers with safe food. Ultimately, even if they are not the cause of the problem, their reputation will suffer.
Producers want to ensure that their products meet safety standards, and this costs money. Sometimes there is doubt as to whether or not governments realize how hard producers are trying in their work methods and financially to ensure that food is as safe as possible. In recent years, we have taken some steps to ensure that farm products are very safe.
The government does not seem too sensitive to this, and it is actually imposing measures that will be very expensive for producers. I am thinking particularly of specified risk materials, the SRMs. Our beef producers are now required to eliminate SRMs, even though our American trading partners are not required to do so. This results in unfair competition for our producers.
I am not saying they are opposed to the introduction of these measures. However, I am wondering why the government put them in place. Does it not realize that they are creating unfair competition? The government must help our producers pay these extra costs.
I have other examples of food safety crises. When I was first elected, the Standing Committee on Agriculture and Agrifood visited Manitoba producers whose cattle had had bovine tuberculosis. We saw one producer in tears when he thought about what happened years before, when he had lost everything. The compensation payments arrived late and were inadequate. The same was true of producers in British Columbia, who had had to cull millions of chickens because of avian flu.
In response, the government recently published in the Canada Gazette some changes in the compensation payments—they were decreased from $33 per chicken to $8, or something like that. I share this concern. There is an imbalance here.
I would like to hear your comments on this. You may have some other examples to give us as well.
:
I would concur, from the perspective of consumers, and I think all the witnesses have concurred, that they actually believe there is no one in the business of producing food who is out to poison anyone. That's what the consumer believes also. There are actually all those things behind them in that chain you've talked about, including the chain Mr. Lennox is involved in that is trucking things and moving things from place to place. Indeed, everyone in that chain is doing the utmost to ensure that when it finally gets to the shelf or gets to the plate, the food is actually safe. They truly don't understand what happens behind the scenes in the chain in the sense of where things come from.
We don't grow papaya, so people know when they buy papaya that it's not Canadian. But they may not necessarily know about tomatoes or leaf lettuce, depending on the season, especially at this time of year, when we get into May. Asparagus is probably a prime example. They may not know whether it's a product of Chile or a product of Canada, unless they're checking really closely, and it's not every place that actually points that out to us.
There is a sort of taken-for-granted attitude, if you will, on the part of consumers, and it's a fair one to take, which is that no one is out to poison anyone.
The cost has to be borne somewhere. If the cost ultimately is going to be borne at the primary producer level, it seems incumbent upon us, because we cherish the safe food supply as a society.... In fact, it's the only thing that will sustain us. If we poison ourselves, we just won't be here. We ultimately need to bear the cost as a society, which means that all of us contribute.
I agree with you, by the way. When my kids were younger and I was paying a mortgage--because I'm kind of like you, and they're kind of gone, almost--it was a tough go for a while to try to make ends meet.
It seems to me that we need a policy that says this is how we pay for safe foods and how we intend to make sure that the processes we're asking for are put in place. We're asking that as a Canadian government. Here is what we need to see happen. The industry is saying that this is what it wants to do. Ultimately, someone actually has to pony up the dollars to pay for that. It seems to me that it's never going to be consumers.
Mr. Lennox, you said earlier that your industry was trying to absorb the cost through efficiencies in your HACCP-based systems. You said that you have been successful or that you've been fairly successful. Do you see that success continuing, or is there a point at which your efficiency gains will simply be tapped out and you'll have to pass costs along?
Mr. Chair, honourable members, ladies and gentlemen, we appreciate the opportunity to appear before the committee again. As I indicated to the committee at our last appearance, all of us at the CFIA were saddened and disheartened by the food-related illnesses last year, and we do express our sympathy to all those affected.
I would like to make three main points. First, I share the view that has been expressed by many of the witnesses who have appeared before this committee that food safety is a shared responsibility that starts with the stewardship of producers and concludes with an informed consumer. It is not the sole responsibility of any one group or organization.
These various responsibilities are set out in statute. Government is responsible for setting standards for food safety. Specifically, Health Canada is responsible for deciding what constitutes a health risk. The CFIA is responsible for setting strong standards for food production, verifying industry compliance with those standards, and undertaking enforcement actions and recalls when necessary. Food producers are responsible for producing safe food.
[Translation]
Second, I want to emphasize that CFIA employees are professionals and dedicated public servants. CFIA employees worked hard to identify, understand and respond to the factors that contributed to last summer's outbreak.
We took action to reduce the risk of this happening again. We took a hard look at what we could have done better. These efforts are described in the Agency's "Lessons Learned" documents, which have been shared with this committee and the general public.
[English]
Finally, I want to emphasize that the agency looks forward to the advice of this committee and that of the independent investigator, Sheila Weatherill, on how improvements can be made to reduce risk and enhance food safety for Canadians.
Thank you. I now turn it over to Dr. Evans.
Mr. Chairman, honourable members, ladies and gentlemen, I appreciate as well the opportunity to appear again before this committee.
Despite the best efforts of the CFIA last summer, Canada bore witness to the tragic loss of life for 22 Canadians and serious illness for many others due to listeria contamination in ready-to-eat meats. It was a situation the likes of which we never want to see repeated. So the CFIA wholeheartedly supports the work of this committee and the independent investigator to provide recommendations that will further contribute to food safety in Canada and mitigate against any similar circumstance happening in the future.
Well before the appointment of the independent investigator and our first appearance before this committee, the CFIA undertook a thorough and frank review and analysis of our protocols, procedures, and activities as they related to the listeriosis outbreak. This important work was necessary to determine where vulnerabilities may have developed in an ever-changing and dynamic risk environment for our food safety system and to make immediate adjustments.
[Translation]
Armed with that knowledge and a resolve to maintain the highest standards of safety possible for the over 100 million meals consumed each and every day in Canada, we have turned our attention to the future. We have gained valuable insight as a result of the findings and lessons gained from the outbreak. Those insights have resulted in many key initiatives being brought forward which will demonstrably enhance protection for Canadians against this potentially lethal pathogen. Time does not permit me to outline all of the actions taken but allow me to cite a few examples for you.
[English]
Inspector training has been stepped up. This is especially necessary since we have mandated greater stringency in listeria environmental testing. Furthermore, we are strengthening our coordination with the other key players in the food safety network, such as Health Canada, the Public Health Agency of Canada, and the provinces and territories and their public health units. Key among those partners, as Carole alluded to earlier, are the food producers themselves, whose commitment to the provision of safe food is also paramount.
Investments have also been made at the laboratory level. There is ongoing work to validate new and more rapid test methods and to increase our capacity collectively to conduct genetic fingerprinting. We are continuing to fine-tune a robust inspection regime called CVS, with the full engagement of our inspection staff, that aligns with HACCP principles, which is a strong and proven approach embraced by international leaders in food safety.
While the CFIA has taken these measures to enhance protection against the risk of listeria, taken alone they will not be enough. We need to look at the food safety network holistically to ensure that all contributors take strong action to prevent a similar tragedy from occurring in the future. Just as a chain is as strong as its weakest link, vulnerabilities in any of the elements of the production continuum can have dire food safety results. That is why I have been heartened to see representatives from other government authorities, industry, academia, and unions come before this committee to share their perspectives and commit to improvements to the system. We all have a role to play.
[Translation]
In hindsight, it is clear that opportunities were missed to both reduce the consequences of the contamination and to reduce the potential for contamination to occur.
It is our collective earnest desire and obligation to do better.
While improvement is always possible and necessary, I reject the notion put forward by some that CFIA resources and staffing were inadequate to meet the situation. The CFIA has more resources now than at any time in its history.
[English]
Food safety inspection numbers have steadily increased since the inception of the agency, as has the educational quality and competencies to perform these tasks. The same can be said of lab technicians and food safety investigators who were key players in determining the source of the contamination. Professionalism, passion for public service, and recognition of the importance of the work they do is the hallmark of CFIA employees. Those who say otherwise serve a different agenda and constituency.
The tragic loss of life may have been reduced or avoided if this type of food, with its known associated risk to vulnerable populations, had either been heated prior to serving or had not been served to the elderly or people with compromised immune systems, in line with the long-standing guidance from Health Canada. The contamination of product may have been averted or detected earlier if positive environmental results had been reported or assessed in more detail.
Another significant contributing factor to the timelines of the situation was the speed and quality of information flow between public health and food safety authorities. The proper collection, identification, handling, and testing of food samples was also a contributing factor to the time necessary to confirm contamination at production and not during preparation.
While information flow may not have been ideal, it is evident that all jurisdictions brought a high level of intent to protecting the public and getting to the answers as quickly as possible. While lives were unfortunately and regrettably lost or forever changed, your search through the evidence will inform you that no effort was spared and undoubtedly it prevented further illness and loss of life.
[Translation]
By all international standards, the food safety investigation was thorough and rapid, resulting in actions to recall even before the confirmation of the typing of the listeria as the same as the illnesses and a week before the first death was confirmed as due to the deli meat contamination.
[English]
There is one overarching theme that I would like to leave you with today, and that is complexity. The interaction and interventions of many players are required to provide safe food. That necessarily introduces complexity to our food safety regime. This complexity is further compounded by the globalization of food production, changing consumer demands, demographic shifts, new production and processing technologies, and so on. The nature and the sources of risks to food safety are evolving rapidly, and our inspection systems must keep pace.
To use a military metaphor--and I do so with some reluctance, in light of what was celebrated over the past weekend in terms of D-Day remembrance--the war against food safety risk is currently being prosecuted by an alliance of units, each with its own specialty and command structure. The enemy they face is dynamic and evolving. The terrain on which they fight is constantly shifting. That is a very challenging and complex environment. To expand on the metaphor further, what is required is a broad view of the campaign and an understanding of all the assets that can be brought to bear on the challenge before us. Vision and strategy are required at the highest levels, while strong, coordinated execution is required from all the supporting units.
The CFIA is one of these many key assets in the defence against food-borne illness. We look forward to playing our part in executing the broader strategy that will be put forth by this committee and from the office of the independent investigator.
In closing, let me assure all members of the subcommittee that any and all who bring in earnest an ability to contribute to high standards of food safety and their effective implementation in Canada will find a committed, willing, and collaborative partner in the CFIA.
Thank you.
:
Thank you, Mr. Chair, and thank you, Mr. Easter for the question.
With respect to the amount of time that inspectors spend on the plant floor versus record review, the 50% is a number we stand by as a number that globally describes the amount of time inspectors across the country, in a wide variety of plants, spend on the plant floor. There is a wide variety of sizes of plants, risks associated with plants, the number of CVS tasks that have to be done and the nature of those tasks, so it may be that in one plant an inspector may find that it's 30% or 35%, or it could be the other way. We have data that would substantiate the 50%, so I simply want to emphasize that there's no magic number here. The 50% time spent on the floor versus record review is not necessarily directly related to food safety outcomes. It's about the whole system. It's about doing the right thing, doing the tasks that get at the greatest level of risk.
In answer to the second part, the training, I want to emphasize that all inspectors who delivered the CVS program, when it was initiated last year--every single inspector--had the appropriate level of training with the required amount of training necessary before they could enter into their full-time duties in implementing CVS. These inspectors received what we called FSE, food safety enhancement, HACCP training. There are three modules there; they received those. They learned about audit there. They learned about HACCP. And then that was added to with the CVS training, which was three and a half days, followed by mentoring by more senior inspectors. As a result, we feel very confident in saying that as far as CVS implementation and HACCP, our inspectors who have been involved have been fully trained.
As to your point about freeing people up in order to get the training, I would acknowledge that is an issue, not with respect to CVS food safety essential training, but training that.... In slaughter plants, our inspectors must be there, and we always have to have a full complement of inspectors there. That makes it difficult at times to schedule training. That is the reality of our business, but that is not to say that essential training in relation to HACCP and CVS was not implemented.
:
On the listeriosis issue, I am sure that no one deliberately did anything to cause that situation and that no one wanted it to happen, but it did happen.
There are two aspects concerning how the crisis and the period after the crisis were managed where I feel the various parties involved should not be contradicting one another so much. That is why it is important to be hearing your testimony once again, since a number of other witnesses have come before the committee since your first appearance, and we have heard contradictory evidence about the crisis.
The time has come to make sure that taxpayers... People often say that it is the public who pays the salaries of members of Parliament, ministers, etc. And we are accountable to the public. The same is true for the public service. All of your salaries are paid for by the public, which has a right to all the transparency, and of course, the whole truth, since this crisis resulted in deaths and people certainly had cause for concern. This failure in the food safety system definitely caused a crisis of confidence as well with respect to our food safety system.
I would like to point out some of these contradictions to you. Of course, I have no need to ask you to be transparent, since I did so in my introduction. On April 20, 2009, when you appeared before the committee, the Canadian Food Inspection Agency told us that the information about the listeriosis outbreak had been received on August 6, 2008.
We then received testimony and a report from Dr. David Williams, the Chief Medical Officer of Health for Ontario. He told us that he had notified the agency about the situation on July 29, 2008. In an e-mail dated May 27, 2009, the Ontario Minister of Health and Long-Term Care also told us that notification had taken place on July 29.
That is a discrepancy of just a few days, but we know that in a crisis of this kind days and hours are extremely important when it comes to taking action and dealing with the problem head on. Where does this contradiction come from? Explain that to me.
:
Thank you, honourable member.
Mr. Chairman, my comments, I think, echo those that have been made previously by myself and others in testimony before this committee. The fact is that food safety is not delivered by any one point of inspection. Food safety is a continuum of activities. It is a culture of commitment that starts, as has been indicated by many before, with the stewardship that we benefit from in Canada from an industry that at a producer level takes the food safety commitment very seriously.
I believe you've had testimony from others who have talked about on-farm HACCP programs and the commitment that various industry sectors have brought to incorporating HACCP principles as prerequisites to the HACCP that we apply at slaughter and at processing.
Again from that perspective, what we have done at CFIA is ensure that the resources allocated to us as an agency cover the spectrum of risk, so that we can mitigate risk at multiple points along that continuum, from our activities of ensuring that the animals entering the food system are health, through good disease control and zoonotic control programs to ensure that animals at the point of slaughter receive appropriate ante-mortem and post-mortem inspection to ensure that only healthy and fit animals are used to produce food in this country. That oversight extends through multiple layers of processing, including deboning and further processing, with inspection activities that support the type of work that is absolutely essential to dealing with the types of risks, such as listeriosis, that you cannot detect through physical inspection processes. We have ensured that we have appropriate lab capacity to adequately sample and perform tests that are delivered to gold standards to validate what the environment is telling us now and what end product can tell us as a subset of verification of the activities.
I think you have heard testimony from academic and other experts who reiterated that you cannot inspect or test your way to food safety. The reality is that technologies can be applied to achieve food safety outcomes, but what is critical to the agency is ensuring that we have the capacity at all points along that production continuum with the appropriate competence to ensure that there is no weak link in the chain that we can identify.
I am very confident that as an agency we continue to make good investments in terms of our recruitment and in terms of our training, both within CFIA and in working with those who train inspectors before they even join the organization, through outreach to agricultural and veterinary schools and through the teaching curriculums, to make sure people come to the agency with a wealth of experience and knowledge that will be critical to food safety.
:
Thank you for the question.
Honourable Chair, I think the fundamental principle, again, is one of finding that correct balance where you can give information to the public that is actionable for them, so they can take that information and turn that into an action they can take to protect themselves. I think it's very clear, in reviewing the circumstances of last summer, that while there was a tragic loss of life of 22 people, when one looks at the totality of the health information, the vast majority of those illnesses and more dire consequences were the result of exposures of those individuals to the food source before CFIA was even aware there was a potential food contamination issue. The incubation period was one where the exposure had taken place before we were brought to the table.
In exercising the efforts from the 6th of August to the 16th, with regard to the sharing of information, when one looks at the evidence, in terms of what information we had available, what information Toronto Public Health had available, the reality is that we were all collectively working to find that solution as quickly as possible. The CFIA, on the 13th of August, took the initiative to bring the community together when we became aware of secondary investigations beyond the primary investigation by Toronto Public Health. We started to make sure that everybody was sharing the information they had in as timely a way as possible and that this information could be used by everybody around the table within the scope of their regulatory and jurisdictional authorities.
It concerns me that there is a suggestion that we were in any way obstructive to the work of other jurisdictions. I think that suggestion is most unfortunate and disrespectful, given the body of evidence that has been assembled around that. The reality is that from our perspective, the decision to go to recall late on the 16th, early on the 17th, was arrived at when all we knew was that we had L. mono and we could confirm there was a contamination at a production source. We didn't have the PFGE pattern. Because of that, we couldn't even confirm that this product linked to illnesses with a common PFGE pattern. That was seven days later, after the recall was issued.
So again, I believe that when one looks at the actions that were taken, with the evidence that was known at the time--two illnesses up until August 6, a second pair of illnesses on August 12--we were investigating four illnesses, and from that point forward, within four days we had done a recall. Against any international event I can find over the past number of years, international standards such as they are, people would look at that and say that was an amazing level of investigation, an amazing early determination, and the appropriate call in terms of a recall, to do that as early as they did it.
:
I only have five minutes, which is very short. So I will ask you a series of questions that you may be able to answer later, once you have taken note of them. I think that will be the easiest way.
Ms. Swan, my first question is for you and it concerns a letter that you sent and that was co-signed by Dr. Butler-Jones, from the Public Health Agency of Canada, and Mr. Rosenberg from Health Canada. On April 20, 2009, you wrote to the Ontario Health authorities to tell them that they had sent the samples to the wrong place. You indicated that they should have been sent to the Canadian Food Inspection Agency laboratory in Scarborough rather than to Health Canada.
In his testimony on April 23, 2009, that is, three days after he signed the letter, Mr. Butler-Jones told us here in the committee that the Ontario Ministry of Health officials actually did the right thing by sending the samples to Health Canada. So I would like to know whether you too have changed your mind about this.
I would also like to know what you think the ideal ratio would be in terms of the number of plants that each inspector should be responsible for. Do you have enough inspectors to implement that ratio? In the case of the Maple Leaf plant where this unfortunate incident took place, we know that a single inspector was responsible for seven plants. I think that he is now responsible for just one plant. From the start of the subcommittee's study, it has been clear to everyone here that one inspector being responsible for five, six or seven plants was much too high a ratio. In your opinion, what is the ideal ratio? Do you have enough inspectors for that ratio?
Furthermore, is it normal practice for inspection reports to be changed well after the fact, as we have heard about here in testimony? Is it customary in the agency for inspectors to have to make changes to their reports weeks after writing them? Former agency employees have told us that that is not the usual practice.
Dr. Williams, who is also Ontario's Chief Medical Officer, told us that there was a lack of compliance with the CFIA's emergency protocol in the sense that you were supposed to set up an emergency operation centre and that was not done. I would like to hear your comments on that.
Finally, on the product recall, we heard testimony here in the subcommittee that you allowed Maple Leaf to issue voluntary recalls and that the alert was sent out three days after Ontario provided notification of the problem.
That is my list of questions for the moment.
There are a number of questions there. Let me take them in order. First, in regard to the letter that we prepared for Dr. Williams and the issue of the use of the Scarborough lab, our intention was not to indicate that it was the wrong place to send the samples to, but rather a missed opportunity. But if it had been clearer that we were dealing potentially with a very serious food-borne illness, sending the samples to the CFIA Scarborough lab would have expedited the process and we would have had the results quicker.
Secondly, in terms of inspectors, it is true...and I have mentioned that we have looked at the appropriate ratio of plants to inspectors. I would point out that in the case of the inspector at Maple Leaf—and there were in fact two inspectors, and other inspectors—there was a combination of ready-to-eat meat plants and also cold storage. So there were different obligations for inspection, and different timeframes. We have taken a look, especially in our southern Ontario complexes, at what the workload should ideally be. When I'm finished, I will ask Cam to perhaps come back on that one in detail.
On the inspection reports, they were quite clearly added to. They were not changed in the sense of anything being deleted. During the very detailed investigation of what happened at Maple Leaf, when we sent in our very specialized food safety auditors, the food safety auditors recommended to the inspectors that in fact they should add additional information to the record. It was not that they should change the record, or edit the record, or remove anything from the record, but rather that additional information should be added to it for the purpose of understanding what had happened—which was our goal, to really understand what happened. I imagine that's not usual, in the sense that it's not usual that we have such extreme investigations of situations in plants where there have been such issues.
In regard to the emergency centre, one of the lessons learned was that we did not set up our national emergency operation centre for this. In retrospect, it would have been helpful, particularly on the documentation side, because it does contain some very stringent protocols for reporting daily information. At the time, however, we knew what we knew at the time, which was that we had a small number of listeria illnesses. We were tracing them out as a food safety investigation. We did put all of our resources, in terms of our recall and investigation, to this. So even though the emergency centre wasn't set up, we had a very thorough response, a very immediate response, with our food safety investigation.
On the question of recall and allowing Maple Leaf to do a recall, the minister does have the power to require mandatory recalls. In the vast majority of cases, industry does voluntary recalls. In this case, the recall was initiated very, very quickly after CFIA determined that in fact there was a sample from Maple Leaf that had tested positive for listeria. As Dr. Evans testified earlier this evening, at that point we only had an indication that it was a listeria species—that it was mono, not the PFGE pattern. So we couldn't, at that point, even necessarily directly connect it to a specific illness and a specific product, but in the interests of precaution, the recall was issued.
Cam, would you just speak for a minute about the issue of inspectors?
Perhaps I'll start with a comment. My colleagues always want to mention the precautionary principle as if it's not science. But it seems to me, if I remember my biology class from many years ago, that the precautionary principle really is about science. It's just simply an alarm bell, if you will. It's like the canary in the old coal mine. When the canary dies, you know that carbon monoxide is going up, so get out. That's called the precautionary principle.
So it's not as if this is not based on science. It's not voodoo economics, as we thought about what happened in the United States, when the previous President was there and someone talked about his economic theories. It is based on science.
I think, Mr. Evans, you would accept the fact that it is a science-based term, the precautionary principle. It is based on a certain amount of science. It's not an absolute. In other words, we don't wait for folks to die in the coal mine. They get out, because the canary died; that's why it's the precautionary principle.
Let me go back to this sense of.... You've clearly said, and what I've just heard now again, and clearly it's in your documentation, that you've increased the amount of inspection at the Maple Leaf Foods plant, the Bartor Road place, where all of this stemmed from.
In your comments, Brian, again on page 2 near the bottom, you said, “The contamination of product may have been averted or detected earlier if positive environmental results had been reported or assessed in more detail.” That basically aligns with the summary of findings between Ms. Swan and the minister in part of the overview and the lessons learned. It said, “In depth assessment of plant revealed that MLF experienced challenges in environmental control and sanitation in May and June 2008.” Those two match. I would call those two circles, and they certainly overlap.
What it says to me, and I'd like you to either confirm or not, is clearly we didn't have enough inspection there in May and June, based on what we've done now. Albeit, maybe we have one person in there, or two; depending on the shifts that are being run, you may not have that. Mr. Prince may decide it won't be necessary, that number going forward, because of the experience we had.
Clearly we weren't looking for a microbe when we talked about sanitation and environmental control. We were talking about things like condensation. We were talking about things not being cleaned properly. We were not talking about looking for the listeria microbe, which, everyone always keeps saying, you can't see.
You haven't found anybody on this committee, especially on this side, ever refuting that. Of course you can't see it. You know, I didn't buy these glasses that I wear today on the back of a comic book, where you can buy glasses that can see everything in the world. So we know that we can't see it. But we can see the environment when it's not good, and the report fully indicates that it wasn't.
Your additional comments here, Brian, are that if we had gotten a good assessment, it could have come from two places: (a) CFIA's inspector, if he'd had more time to be there, or (b) the inspector that the HACCP program allows to be inside the plant, based on the plant's HACCP program, if it had been reporting properly. If the program had been working correctly, it could have told us something, and we perhaps could have done something different.
Can you comment on that?
:
Thank you. It took a while to get here.
In any event, coming back to the key to going forward on the public's information, it is getting proper information on how many inspectors are actually on the floor in certain plants doing certain jobs. Regardless of all the evidence that we've had here tonight, we do have contradictions around that from the Agriculture Union.
I forget who answered that question, whether it was you, Mr. Prince, or Mr. Mayers, but the information presented to the committee was on meat inspectors available to work in meat processing and cold storage facilities. They said that in Toronto the average was 4.6, and in Montreal, 4.7--that's facilities per inspector, sorry. In northern Alberta it was 5, and in Greater Vancouver, 5.9. Regardless of where the numbers are at the moment, in going forward—and I don't think it's in the lessons learned documents—how do we get credible, accurate information? What can CFIA do to get credible accurate information on how much time is actually spent on the floor?
We know for a fact that if the key inspector's computer is in the Maple Leaf plant, then he certainly is going to spend 50% of his time there because that's where he has to take his reports to put them in the computer. So it goes as time spent in that plant.
But is there not a better system than what we currently have? Are you working on getting to a system that can take out the duplications and give people who ask about time the proper information? There must be time in, time out, etc.
Could Ryan or Cameron, or whoever, answer?
Ms. Swan, you had said earlier, when I had asked about phone calls, that you didn't keep notes but you thought you might have made some notes. We did request them and they didn't come forward. The only request I have is, could you go back and take a second look? There were seven phone calls with Maple Leaf during that timeframe and you've indicated you might have made some notes. If you could take another look for that, I'd appreciate it.
And the same for you, Brian. You made quite good notes in your phone logs, except for the one meeting in November where you made none at all--November 5, 2008, Maple Leaf Foods, Brian Evans. There is no phone log, and no notes, but prior to that there always were. Perhaps it was just misplaced. I would just ask you to go and look. I don't need you to answer. Just go back and take a second look, and if they're there, send them to us. If they're not there, then the same response is here, so I don't need a second response to say you didn't have any.
My question really is around what was sent to me in response to the questions about the inspection numbers and CVS tasks. The one task that wasn't completed out of five is number 4, which is the HACCP system design and reassessment. Now we have changed some things, and Brian, you talked earlier about recognizing some things at the Bartor Road facility and that you made some changes. Environmental testing is back, which is really part of the HACCP design plan.
The note in the documents provided to me indicates that we're not going to have that verification of that entire system for two years, because it's a two-year look, according to the note. In other words, they started it last year and it won't be complete for two years. So my sense is that because of the situation we faced, and we have changed the HACCP system in Maple Leaf Foods, why didn't we simply go in and do a complete verification of that particular system and do it right away? And if we are, why didn't you indicate it to us?
I'll just pick up on that, because I think that's the critical part, quite honestly. It leads me to my comment. Maybe I'll have a question at the end of it.
We've listened to witnesses, and a little earlier we had comments come from the Beef Information Centre about the irradiation of meat. Then we had witnesses before us from Bioniche, who were here to promote their E. coli vaccine. As a company, they basically have come forward and asked the government to bankroll their test programs for the vaccine.
We're talking about irradiation of food and giving another vaccine to animals so that it will help in terms of food safety. I just wonder, when we actually just go back to having what we have produced in Canada, which is safe food, and just take that through the monitoring systems we've got, like HACCP and CVS, which is part of HACCP, I'm concerned, quite honestly, with the public perception of what might be happening when we start doing stuff to food that normally isn't done. It's all in the context of food safety. We're going to irradiate it now, or we're going to give vaccines to something else, so that we have less influence upon what we think is a natural product.
We had witnesses in here earlier tonight who were even concerned about some farm practices, even though we know farm practices have become better. Animals are better protected, better served now, have better diets now. Farmers are concerned more about the environment now than I think they ever have been, and contribute more to the environment than they ever have. Yet, if we continue to want to add stuff to our food system, I get concerned about the perception of what our consumers are going to think about our food.
Can you talk to me a little bit about what you think the effectiveness is of the conclusions of your test, and what the effectiveness of this vaccine would be on food safety?