Food Safety And Internat...veness. The Case Of Beef - Chapter 4 - Canada

Transcript

Food Safety 04 29/5/01 2:36 pm Page 55 Chapter 4 Canada Introduction Our second stop on the tour is Canada. Canada’s beef industry is about onetenth the size of that in the USA. Beef production in 2000 was pegged at about 1.1 million tonnes and nearly half of that was destined for export. Historically, Canada has had a close trading relationship with the USA, some would say, too close. Traditionally, Canada exports to the USA from the west (Alberta and Saskatchewan) and imports from the USA to the east (Ontario and Quebec). Trade between the two countries is in both beef and live cattle. The USA accounts for about 80% of Canadian beef exports and supplies about half of Canadian beef imports. Canada’s live cattle trade is virtually all with the USA. Canada exports over one million head of cattle to the USA with fed cattle for immediate slaughter representing about 80% of the total. It is clear that the Canadian beef industry is highly dependent on the USA as an export destination and moreover, is more dependent on the USA than the USA is dependent on it. This unique trading relationship colours the nature of the beef food safety system being developed in Canada. The layout of this chapter follows that of the previous one. There are three sections: the drivers for change; developments in the institutional arrangements in the Canadian food safety system; and the implications of these developments. Drivers for Change The Canadian food safety system has undergone significant restructuring since 1996, motivated by both external and internal drivers. However, the main drivers are external. It should come as no surprise the main driver for change in Canada is the restructuring going on in the food safety system south of its border. With the Canadian beef industry so dependent on the US 55 Food Safety 04 56 29/5/01 2:36 pm Page 56 Chapter 4 market, Canada is very sensitive to developments taking place in the US beef food safety system. This is not to say that there are no internal drivers for change. On the contrary, the government-wide focus on deregulation launched in the early 1990s also played a significant role. The external drivers will be discussed first, followed by the internal drivers. External drivers for change The main external drivers for change in the Canadian food-safety system are the food safety crises and issues arising in other countries. Thanks to widespread media coverage, such crises and issues, especially those in the USA and in Europe, do not go unnoticed by the Canadian public. Indeed, this contagion effect could lead to a broadening of domestic consumer concerns to include, say, British concerns about animal welfare issues (discussed in Chapter 5). With a significant reliance upon export markets, the Canadian beef industry and the food safety system are well aware of the structural changes occurring in important export markets. These include both the legislated and market regulations adopted as part of the foreign food supply chain. For instance, recent domestic crises in the USA have motivated structural change in the US food safety system, which, in turn, has altered the market access rules for Canadian beef products. In order to ensure market access and industry competitiveness, the Canadian food safety system has had to restructure in a manner at least equivalent to the restructured US system. Further, while Canada is not the only country exporting beef products to the USA, its high level of dependence on this market means it will be highly sensitive to any restructuring of the US food safety system. Indeed, as will be shown later in this chapter, the restructuring of the Canadian food safety system is very much predicated on the restructuring going on in the USA. Internal drivers for change An important internal driver for structural change in the Canadian food safety system was the federal government’s focus on deregulation in the early 1990s. This had two objectives; to reduce government costs and increase industry competitiveness. The first and perhaps more important objective was budget restraint among all levels of government. The desire of the government to reduce costs was captured in a Canadian Treasury Board requirement that government services be scrutinized according to whether they were legitimately essential ‘public goods’ or, instead, they were really ‘private goods’. Taxpayers would still pay for public goods, but private goods were required to be delivered on a cost-recovery basis. This produced a reallocation of resources, cuts in government services and/or shifts to a cost-recovery basis for some government services and activities. Of particular interest to us Food Safety 04 29/5/01 2:36 pm Page 57 Canada 57 was the establishment of the Canadian Food Inspection Agency (CFIA) in April 1997. We will discuss this important federal agency in detail later, but for now let us note that one of its stated objectives was to streamline the delivery of federal inspection services to make them efficient and cost effective. This had previously been a problem area for the government. Budget restraint impacts the overall restructuring of the food safety system by limiting or reducing the resources available for government agencies to perform food safety activities and services. The second objective of deregulation was to increase industry competitiveness. The aim here was to assess the efficiency and effectiveness of regulations, which for food safety regulations tended to encourage a shift towards the risk analysis-based regulatory framework. The most significant non-driver for change is sensationalized domestic food contamination crises. There have not been any. This is not to say there have not been any reported instances of food contamination, there have. But they have not been sensationalized by the local media in the way they might have been in other countries. It is not clear why. Perhaps the Canadian media believe their public is less hungry for such stories. This raises a potential problem for Canada – and that is complacency. Media sensationalization has been such a powerful driver for change in some other countries (e.g. the USA) that to not experience it could lead to vulnerability if and when Canada was to ever experience a major food contamination crisis. Complacency could also adversely affect Canada’s international competitiveness if its food safety system is not judged to be as advanced as its competitors’ food safety systems, which have been restructured in response to such domestic crises. Relationship between external and internal drivers The absence of a domestic food safety crisis in Canada means that domestic consumer concerns cannot drive (or shape) any restructuring of the domestic food safety system. Instead, the most influential drivers in Canada include an external one (the restructuring going on in the US food safety system) followed by an internal one (pressures to reduce government expenditures). It is these drivers that will provide most of any impetus for change in the domestic food safety system. Not only will they dictate the pace of change but also the shape of any change. Whereas the prime motivation for change in the USA was the restoration of consumer confidence, in Canada it is international competitiveness. In the next section, we will discuss the sort of institutional arrangements that characterize Canada’s food safety system. The most significant of the institutional arrangements to follow directly from these drivers for change are the development of a national, harmonized Canadian Food Inspection System (CFIS) and the establishment of the CFIA. Proposals to establish a single Food Safety 04 58 29/5/01 2:36 pm Page 58 Chapter 4 autonomous food agency stretch back as far as 1970. However, it was not until 1996 that the idea was acted upon along with the CFIS. The timing was no accident, and coincided with the major restructuring going on in the USA food safety system. In the USA, the 1993 E. coli outbreak at a fast-food franchise in the Pacific-Northwest led directly to enactment of the US MEGAREG legislation in 1996. The Canadian government could not ignore these changes to the US food safety system and the challenge that this posed for Canadian exports. But the federal government was not only concerned that the Canadian beef industry be responsive to restructuring taking place in the US food safety system, but also that the whole process of meat inspection in Canada be streamlined with the financial burden of meat inspection being shifted from government to industry. The CFIS and the CFIA were institutional arrangements sympathetic to both these needs. They are discussed further in the next section. Institutional Arrangements The Canadian food safety system is composed of both governmental and nongovernmental institutional arrangements. These are discussed in the next two subsections. The arrangements will be identified according to the type of risk analysis activities they perform; risk assessment, risk management or risk communication. Governmental arrangements What is interesting about the Canadian food safety system is that the application of standards and regulations on meat and meat products depends upon the destination of the product. Meat and meat products intended for interprovincial or international markets are subject to federal standards and must be processed in establishments that are federally licensed and registered. Federal standards for export to the US market require that plant facilities meet the USDA regulations, detailed in the MEGAREG, including: ante- and postmortem inspection of slaughter animals managed by veterinary surgeons; monitoring for microbial contaminants, veterinary residues, toxins and chemical contaminants; inspection and monitoring of processing techniques and storage and transportation facilities; and perhaps most importantly, the adoption of a HACCP food safety system. Meat products intended only for intraprovincial markets are subject to standards and regulations that are specific to the particular province or region where the products are marketed. Common to all of the firms producing only for intraprovincial trade, is that they are not required to be federally registered. However, across Canada, these establishments may be inspected, monitored or audited by: Food Safety 04 29/5/01 2:36 pm Page 59 Canada ● ● ● 59 the federal government through a federal–provincial agreement; the provincial government through Agriculture and AgriFood Canada (AAFC) or Health Canada (HC); or the municipal government through public health offices. With respect to the federal government, inspection services may be provided by the CFIA as a result of ministerial agreements, on a cost-recovery basis. Provinces with such agreements include Saskatchewan, Manitoba and British Columbia. Therefore, firms in these provinces can voluntarily have federal inspection services. Not all firms choose to meet the federal standards voluntarily and instead are subject to provincial standards. Provincial inspection services are generally focused on slaughtering plants and processing facilities and may involve standards or regulations on the construction, processing techniques and methods as well as the type, frequency and cost of inspection. The provincial Departments of Agriculture or Health may have jurisdiction over provincial inspection services. There are differences in the provincial regulation and inspection of plants because the standards and regulations are not required to be nationally consistent and provincial inspection services are not mandatory in all jurisdictions. For instance, licensing of slaughtering plants is mandatory in all Canadian provinces, while licensing of processing plants is mandatory in all provinces except Saskatchewan and British Columbia. Inspection of slaughtering plants is mandatory in all provinces except Newfoundland, New Brunswick, Saskatchewan and British Columbia. Inspection of processing plants is also mandatory in all provinces except Newfoundland, New Brunswick, Saskatchewan and British Columbia. Finally, provincial inspection of meat products at the retail level is mandatory for all provinces except Newfoundland, New Brunswick, Saskatchewan and British Columbia. There are no mandatory provincial inspection service standards and regulations for Newfoundland, New Brunswick, Saskatchewan and British Columbia. Therefore, firms in Saskatchewan or British Columbia that opt out of federal inspection (which is voluntary for firms engaged only in intraprovincial trade) do not face any mandatory provincial standards and regulations. In both Saskatchewan and British Columbia some municipalities have by-laws requiring mandatory inspection services, either federal or provincial, in order to access some urban markets. In Saskatchewan, these centres include Saskatoon, Regina, Prince Albert and Moose Jaw. All firms which do not fall under any mandatory inspection services are subject to only one regulation; a sanitation inspection by a local health official. In Saskatchewan, the frequency of inspection by a local health official is once every 2 years. The result is that consumers in Saskatchewan, outside of Saskatoon, Regina, Prince Albert and Moose Jaw, may buy meat that is federally inspected, provincially inspected or not inspected at all. Therefore, as a result of the multi-jurisdictional nature of provincial, territorial and municipal governmental arrangements, the Canadian food Food Safety 04 60 29/5/01 2:36 pm Page 60 Chapter 4 safety system can be very inconsistent across the country. In fact, the only thing that is certain is that only exports from Canada have to meet the highest available standard (federal standard). The domestic meat supply does not have to meet the federal standard and may not be subject to the same level of food safety assurance as export products. Instead, domestic consumers choose from meat products produced under sometimes quite different meat safety systems, and these systems vary from province to province. Further, if the ‘National Treatment Provision’ is internationally interpreted to literally mean ‘the only standards that can be applied to imports within a province or territory would be those that govern trade within that particular province or territory’ then, with respect to Saskatchewan, consumers may purchase foreign meat products whose only mandatory standard was a sanitary inspection up to 2 years earlier. Over the last 30 years, there have been four separate government studies proposing that government involvement in food safety be through a single food safety agency. These include the Chapman–Osbaldeston Report (1970), the Cabinet Evaluation Study of Food Inspection (1975), the Single Food Inspection Agency Task Force (1979) and the Task Force on Program Review a.k.a. the Nielson Task Force (1985). The proposals were not adopted because it would have required too much regulatory reform and departmental re-alignment and coordination in order to work, and until there were strong external and internal drivers there was not the political motivation within Canada to make the necessary changes. After the Nielson Task Force Report in 1985 the Interdepartmental Committee on Food Regulation (ICFR) was established to: 1. Identify the roles of each department in the food safety system; 2. Examine the efficiency of the system; 3. Promote the coordination of food safety efforts; and 4. Promote the adoption of food safety enhancing innovations, including self-regulation, where appropriate. Thus, it is clear the inconsistency of food safety regulations across different jurisdictions was a major concern. The ICFR established a number of sub-committees to help carry out its mandate. According to a later review by the Office of the Auditor-General of Canada (1994) only one of these sub-committees was active. That was the Sub-Committee on Food Inspection, which attempted to coordinate inspection services across the federal departments and between the provinces and the municipalities. In 1987, concurrent with the work of the ICFR, HC established the Federal–Provincial–Territorial Committee on Food Safety. This was a coordinating committee with the objective of streamlining food safety initiatives and programmes among the federal health department and the provincial and territorial health departments. In 1990, AAFC also established a national coordinating committee, the Federal–Provincial–Territorial Committee on Food Safety 04 29/5/01 2:36 pm Page 61 Canada 61 Food Safety independent of HC’s Committee with the same name. The mandate was to promote uniform food standards and streamline the food safety initiatives among departments of agriculture. It has been suggested by an HC official that AAFC formed its own national coordination committee to prevent ‘empire-building’ by HC in the area of food safety. In 1992, under its broader national coordinating initiative, AAFC established the Federal/Provincial Meat Inspection Committee (FPMIC) to examine the government role in meat inspection in the Canadian food safety system with respect to the promotion of interprovincial meat trade. The focus of this committee was on the inspection of meat slaughtering and processing across the various provincial, territorial and municipal regions in Canada. The FPMIC developed the National Domestic Standard (NDS) for meat plant facilities, processing techniques and inspection methods. Yet, the NDS was not adopted due to a lack of provincial consensus on issues such as plant facilities and inspection frequency and uncertainty about the economic costs of adoption. One of the main issues for the provinces was how the NDS would play out with the many small volume operators that dotted the landscape. Their argument was that the proposed stringent nationally harmonized standards would pose significant economic costs for these operators without providing equally significant economic benefits. In 1993, the AAFC Federal–Provincial–Territorial Committee on Food Safety presented the FPMIC recommendations on coordinating and harmonizing meat hygiene and inspection standards to the Canadian Ministers of Agriculture. It was this committee that first proposed the development and implementation of the CFIS and in 1994, proposed the creation of a CFIS Implementing Group (CFIS-IG). The proposal would link together the activities of ICFR with the activities of the national coordinating committees for HC and AAFC to create a nationally coordinated food inspection system. This idea for the creation of a CFIS-IG shocked HC, which was already undertaking its own coordinating work. However, the CFIS-IG was finally born 2 years later in 1996. Following the 1993 proposal for a CFIS and a CFIS-IG, the independent initiatives of HC and AAFC were combined, along with the Department of Fisheries and Oceans (DFO), in a joint steering committee that sought ways to streamline standards and regulations not just across traditional departmental lines (i.e. Health and Agriculture) but also across local, provincial and federal jurisdictions. Closely following this amalgamation were two separate reviews of the government role in the Canadian food safety system. The first review, by the Office of the Auditor General of Canada, was published in the 1994 Report of the Auditor General of Canada, Volume 8, Chapter 13 on the ‘Federal management of the food safety system’. The report concluded that a single department or agency should provide food inspection. It also concluded that the single food safety agency should focus on consumer protection by emphasizing human health/food safety issues, not producer promotion. This would require a Food Safety 04 62 29/5/01 2:36 pm Page 62 Chapter 4 separation between the government department that promoted food safety and the government department that promoted the agrifood industry. Further, the report concluded that the proposed food safety system should be implemented in a cost-effective/cost-recovery way, since the Treasury Board required government departments and agencies to provide cost-recovery services to ease budgetary burdens. Therefore, the food safety services were encouraged to adopt the risk analysis framework (risk assessment, risk management and risk communication) provided as ‘private goods’ on a costrecovery basis. The second review of the role of government in the Canadian food inspection system was the Program Review II of AAFC. This review was driven by the objective of identifying areas of substantial cost reduction within AAFC’s operations through institutional clarification and organization. There were two major conclusions of the review pertaining to food inspection services. First, inspection services should be performed in a cost-recovery fashion, consistent with the requirements of the Treasury Board to reduce government expenditures. Second, federal–provincial–territorial coordination and partnerships were considered necessary to improve inspection efficiency and effectiveness and to remove differential regulatory requirements across Canada. Some of the recommendations of the Auditor General’s Report and AAFC’s Program Review II were included in the 1995 Federal Budget. In this budget, the federal government called for the creation of the Office of Food Inspection Systems (OFIS) to examine the federal food inspection bureaucracy and identify areas of overlap and duplication. Out of OFIS came two initiatives: the CFIS and the CFIA. The CFIS was to be an integrated, national food inspection system responsive to the safety concerns of consumers and the competitiveness concerns of industry. This system was intended to improve inspection efficiency and effectiveness and harmonize regulatory requirements across Canada. To assist the development of CFIS, the CFIS-IG was established in 1996 with a mandate to harmonize federal–provincial inspection systems in order to achieve a national inspection system. It consists of federal, provincial, territorial and municipal government representatives from agencies such as Health, Agriculture, Fisheries and Oceans. In 1998, the CFIS-IG noted the goals of the CFIS to be: high quality, safe food supply, harmonized standards, cost-effective inspection system, enhanced access to markets for Canadian food producers, scientific risk assessment-based inspection and protection from economic fraud (CFIS-IG, 1998) Functionally, CFIS-IG facilitates the development of sector-specific nationally harmonized food safety codes. National codes were developed for such sectors as dairy, meat, and poultry. With respect to meat, the CFIS-IG picked up on the work began by AAFC’s FPMIC to develop an NDS. This code, Food Safety 04 29/5/01 2:36 pm Page 63 Canada 63 now known as the National Meat Code, is being designed to apply consistently across all provinces, territories and municipalities. The stated goal of the National Meat Code is to develop ‘one set of requirements for meat inspection which are reasonable and scientifically-based and will protect the public health, eliminate provincial trade barriers and protect Canada’s economic standing in the international marketplace’ (CFIS-IG, 1998). Although progress has been made on the development of the National Meat Code, at the time of writing the code had not been finished. The second initiative of OFIS was to propose an arrangement by which the CFIS could be administered. In the same year that the CFIS-IG was established (1996), the OFIS presented four options to the federal government and to national stakeholder meetings across Canada for an administrative arrangement. They were: 1. Maintain the status quo; 2. Strengthen the role of ICFR and retain its past responsibilities; 3. Create a new autonomous food inspection agency to focus on risk management while HC focused on risk assessment; and 4. Create a new autonomous food safety agency combining all current risk analysis food safety activities of HC, AAFC and DFO; risk assessment, risk management and risk communication. In the 1996 Federal Budget, the federal government announced it had decided on the third option; the creation of an autonomous food inspection agency to focus on risk management. On 16 September 1996 Bill C-60 announced the creation of the CFIA to be established on 1 April 1997. Essentially, the CFIA is a federal governmental Special Operating Agency administering and enforcing all federal food inspection legislation and providing all risk management activities and services. It consolidates all those federally mandated food inspection and animal and plant quarantine services previously performed by HC, AAFC and DFO. As a Special Operating Agency, the CFIA is administratively distinct from the traditional government departments such as HC and AAFC (although it reports to Parliament through the minister of AAFC). The agency is required to be open and transparent. And, with a projected initial budget of C$300 million for 1998/99, the CFIA is required to move towards cost recovery and to be managed in an increasingly commercial manner. In fact, the projected revenues for 1998/99 fiscal year were C$60 million for the inspection services alone. The current government involvement in the Canadian food safety system will be discussed in four sections below according to the governmental arrangement involved: (i) HC; (ii) CFIA; (iii) AAFC; and (iv) provincial, territorial and municipal governments. HC and the CFIA assume the major roles. HC establishes the food policies associated with human health, safety and nutrition where these policies are required to be based on scientific procedures for risk assessment and may result in food industry standards, guidelines, codes of Food Safety 04 64 4/7/01 4:16 PM Page 64 Chapter 4 practice or regulations. The CFIA provides the subsequent risk management activities of inspection, monitoring and auditing of the food industry for compliance with the food policies developed by HC. In the case of industry non-compliance, the CFIA is also responsible for the enforcement of the food policy. AAFC plays an indirect role promoting the domestic food industry through various programmes and initiatives while at the provincial, territorial and municipal level, there is a diverse range of government involvement. HC HC’s role in the Canadian food safety system is to ensure both short- and long-term consumer protection through the provision of both safe and nutritious foods. The specifics of its role are set out in its Food Program and deal with areas of food safety covered in the Food and Drugs Act. Principally, the role is to develop food policies based on scientific risk assessment procedures. However, HC’s mandate extends beyond risk assessment to include some aspects of risk management (e.g. the development and promotion of GMPs) and risk communication (e.g. consumer education and nutrition labelling). Let us take a closer look at the various components of its role, grouped under food policies and risk assessment, risk management and risk communication. FOOD POLICIES AND RISK ASSESSMENT. HC’s development of food policies is based on a six-step process involving: issue identification; issue prioritization; sciencebased risk assessment; policy option development; policy decision making; and, finally, policy implementation. One priority objective of HC in carrying out this process is transparency. The process is open to broad consultation at all stages where the consultation network includes all levels of government, food industry participants, consumers and health-care industry participants. To date, the consultations have yielded a number of important policy positions, namely: 1. All food policies must be determined using a risk analysis framework, which is based on scientific evidence where human health and safety impacts (not broader socio-economic considerations) are the element of concern. 2. The scientific evidence must be credibly obtained from peer-reviewed and internationally accepted research sources. 3. Other impacts must also be considered after establishing the health and safety impacts; where other impacts include economic, trade, social and environmental impacts. (In this sense, Canadian food safety policies must have a firm scientific foundation, but based on such a foundation they can then deal with broader non-safety issues.) 4. Ongoing, transparent stakeholder consultation must be an integral part of food policy development. Thus, the foundation of HC’s food policies is science-based risk assessment procedures where risk is associated with human health and safety risks Food Safety 04 29/5/01 2:36 pm Page 65 Canada 65 only. Socio-economic risks are not a factor. The risk assessment procedures begin with the identification and characterization of hazards associated with a given food product. Hazards include pesticide residues, veterinary biologics, microbial pathogens, food additives as well as the nutritive fortification of food products. This leads to the development of a risk profile for that food product. A risk profile ranks the risk of the product to human health. It includes the probability of the occurrence of the risk and the establishment of maximum tolerance targets for the presence of microbial contaminants. An important objective of the Food Program is the establishment of consistent risk profiles across all products so the allocation of HC’s resources may be optimized. It devotes more resources to the more risky products. The risk assessment procedures and the risk profiles form the scientific foundation of HC’s services and activities. These include pre-market product reviews that focus on the human health and safety impact of the food product. Pre-market reviews are mandatory for both domestic and foreign products destined for Canadian markets. Product attributes, which are unrelated to food safety, are not considered during the pre-market review. These reviews involve a multi-disciplinary approach to determining the product’s safety according to its risk profile. HC’s interest in food policies and risk assessment extend beyond the borders of Canada. HC provides assistance in the development of international food policies. In particular, HC participates in the development of Codex standards, guidelines, codes of practice and recommendations to ensure that Canadian safety standards are reflected in international standards. Such participation also influences domestic standard setting. Finally, in the risk assessment area, HC is exploring the possibility that third parties may perform some of the scientific risk assessment activities in the future. HC would continue to be responsible for food policy setting and risk assessment decision making for the food safety system. However, non-governmental parties may be involved with the technical risk assessment activities. RISK MANAGEMENT. Once a food safety policy has been developed and adopted, HC sets food safety standards, guidelines, codes of practice and, when necessary, regulations for the food industry. Thus, regulations are viewed as only one of several tools available to HC to implement the policy. They tend to involve specific rules with little flexibility in interpretation. And, they can be the most effective tool for ensuring minimum essential standards are met. Codes of practice, on the other hand, tend to be much broader and more open to interpretation. As a result they may be more effective at providing latitude and flexibility of response in the food safety system. In 1989, HC developed a programme for food manufacturers on GMPs. These are risk management strategies designed to identify those food-processing methods and techniques that minimize the risks to human health. GMPs are based on HC’s Voluntary Code of Practice (VCP) – General Principles of Food Food Safety 04 66 29/5/01 2:36 pm Page 66 Chapter 4 Hygiene for the Food Industry in Canada released in 1983. The VCP was based on the Codex codes of hygienic practice and, consequently, was designed to be internationally consistent. For a particular manufacturing operation, the degree of stringency of the GMPs is based on the risk profile of the food product being produced. According to the GMP guidelines, food manufacturers must keep detailed records commensurate with the product’s risk profile so they possess documented evidence that the products are safe and nutritious and that appropriate risk management efforts are being undertaken. The information generated in this way is assembled to create a public health intelligence network to monitor the incidence of human health risks associated with food products. Eventually, the goal is to link domestic and international government health agencies with domestic and international industry participants. This is intended to provide a comprehensive, accurate and timely set of information on the incidence of food-borne illness and thereby, to improve the accuracy of the risk profiles. The adoption and implementation of GMPs by food manufacturers is voluntary, although HC does encourage their adoption at all stages in the food supply chain. Currently, firms that process food products with a higher risk profile are targeted by HC. Further, HC has recognized that small firms face higher costs during the development, adoption and implementation of GMPs and so have instituted a staggered phase-in period for the establishment of GMPs depending on the risk profile of the firm’s product and the firm’s size. This initiative has not been without problems for HC. In particular, it has been the subject of a turf dispute with the CFIA. GMPs are a risk management tool, but CFIA views risk management as its area of responsibility. The jurisdictional dispute between the two federal agencies concerned has been a hindrance to the implementation of GMPs. HC has one other responsibility in the risk management area and that is to audit the risk management activities of the CFIA. The objective of the audit is to assess the effectiveness of the CFIA’s programmes and activities related to the inspection, monitoring, surveillance and enforcement of food safety and nutrition policies. RISK COMMUNICATION. HC is involved in several risk communication activities. One such activity is the National Partnership for Consumer Food Safety Education Program involving the CFIA and 20 other organizations including industry and consumer groups. This programme recognizes that consumers have an opportunity to limit food-borne illness. The objective is to provide accurate and timely information on those food handling and preparation techniques that minimize the risk of contamination. For instance, most microbial contaminants may be eradicated simply through cooking the food product at adequate temperatures. Consumers who are educated about health and safety risks play an important role in ensuring their own health and safety. Food Safety 04 29/5/01 2:36 pm Page 67 Canada 67 Nutrition labelling is another risk communication activity of HC. HC believes that current label requirements do not provide enough information about inputs, production and processing methods and product attributes for consumers to make good nutrition decisions. Thus, HC is pursuing a strategy to encourage consistent labelling of food products that adequately signals standards of nutrition. There are four benefits of a consistent and widely used labelling system. First, it enables consumers to make informed consumption choices, aiding in consumer sovereignty. Second, it encourages producers to supply foods incorporating sound production and nutrition principles. Third, it prevents mislabelling that improperly identifies possible human health and safety hazards. Fourth, it prevents economic fraud where processors claim production techniques or nutritive contents that are not accurate. One additional dimension to the nutrition labelling issue is the development of US labelling regulations. US labelling requirements require the provision of more and different information from what is accepted in Canada. This has implications for Canadian food exports to the USA, which would need to abide by the US regulations. CFIA The CFIA is an autonomous Special Operating Agency of the federal government created in September 1996 and established on 1 April 1997. Its primary responsibility is to undertake risk management activities including the inspection and monitoring of domestic food establishments and enforcement of the food safety policies developed by HC. It has extensive jurisdiction over all the food industries in Canada as well as jurisdiction over imports into the Canadian food supply. Like HC, the CFIA may, if it chooses, permit other, non-governmental parties to provide these risk management activities. The CFIA pursues four general objectives. They are: 1. To ensure consumer protection from risks to human health. Apart from the inspection, monitoring, and enforcement activities, this includes promoting the adoption of safety assurance risk management schemes by food industry firms such as a HACCP system. 2. To ensure consumer protection from economic fraud arising from the mislabelling or misrepresentation of food products. 3. To promote market access for Canadian food products. Unlike the first two objectives, this role is a producer promotion role that involves the CFIA promoting the safety and quality of Canadian food products and the effectiveness of the Canadian food safety system both domestically and internationally. 4. To ensure the CFIA is operated in a cost-effective manner. This includes streamlining food safety rules through a coordinated national food inspection system built on a user-pay principle. It is interesting that the CFIA objectives include both consumer protection and producer promotion activities despite the Auditor General’s report specifying that these two objectives should be institutionally separated. Food Safety 04 68 4/7/01 4:18 PM Page 68 Chapter 4 The legislation governing its operation is the 1997 Canada Food Inspection Agency Act. This Act confers on the CFIA extensive jurisdiction over 13 acts of parliament as they pertain to food safety and inspection activities. These Acts include the Canada Agricultural Products Act; the Consumer Packaging and Labelling Act; the Feeds Act; the Fertilizers Act; the Fish Inspection Act; the Health of Animals Act; the Canadian Meat Inspection Act; the Seeds Act; the Food and Drugs Act; the Plant Breeders’ Rights Act; the Plant Protection Act; the Canadian Health Act; and the Agriculture and Agri-Food Monetary Penalties Act. This last act was created to establish monetary penalties for non-compliance of firms with the various food safety rules subject to enforcement by the CFIA. Administratively, the operational divisions of CFIA, which carry out the inspections and so on, are organized according to four regional areas; the Atlantic, Quebec, Ontario and the West. Of most concern to us is the Food Inspection Division (FID). In April 1998, the FID was re-organized into four new food directorates: (i) Animal Products (meat, poultry, dairy, fruit and vegetable divisions); (ii) Plant Products; (iii) Program Laboratories; and (iv) Policy Planning and Coordination. The first of these directorates is responsible for ensuring the safety of meat products. The FID focuses on two types of risks: 1. Contamination risks from pesticide residues, heavy metals, veterinary residues, microbiological pathogens or natural toxins; and 2. Misinformation risks from the mislabelling of allergens, additives, reworks, processing aids or preservatives which may have adverse health effects on sensitive consumers. To manage these risks in the Canadian beef supply chain, the FID, and in particular the Animal Products Directorate, undertake a number of activities in accordance with the 1985 Meat Inspection Act. They are: 1. Registration and approval of meat plants (slaughterhouses, meat processing plants, meat import and meat storage facilities) involved in interprovincial and international trade; 2. Inspection of the registered meat plants; 3. Administration of scientific tests at the meat plant; 4. Assistance with the voluntary adoption by registered meat plants of a CFIA-approved HACCP system – this initiative is known as Food Safety Enhancement Program (FSEP); 5. Enforcement of food safety regulations at the meat plants; 6. Inspection and monitoring of imported meat and meat products; and 7. Administration of scientific testing programmes and enforcement of labelling regulations at the retail level. Let us consider these activities in a little more detail. Food Safety 04 29/5/01 2:36 pm Page 69 Canada 69 REGISTRATION AND APPROVAL OF MEAT PLANTS. The FID is responsible for the registration and approval of plants that produce for either interprovincial or international markets. According to the Meat Inspection Act, no firms may operate a registered establishment without a federal licence. And meat plants, which possess a licence, must apply for registration with the CFIA if they are involved in interprovincial or international trade. The application for registration must include a detailed account of the establishment’s processes, procedures and specifications, including a description of the plant’s structure, the grounds and the equipment used. Upon approval, the plant is issued with a verification number. INSPECTION OF REGISTERED MEAT PLANTS. Approximately 1500 FID inspectors perform mandatory inspections in registered meat and poultry plants across Canada. Federal inspection is not required in plants involved only in intraprovincial shipments of meat. But, in fact about 98% of the domestic industry’s output is federally inspected. Of the carcasses, which are federally inspected, about 0.5% are rejected from the human food supply. The inspection of domestic meat plants focus on slaughtering and processing facilities and involve both ante- and post-mortem inspection. There are two different approaches taken to the inspection of such meat plants in Canada. The choice of approach depends on whether or not the meat plant in question has adopted a CFIA-approved HACCP system. The inspection procedure used for firms, which have not adopted HACCP, is discussed immediately below, while the procedure for firms, which have adopted HACCP, is discussed in the section ‘Assistance with the voluntary adoption of HACCP’ on page 70. For those domestic meat plants without HACCP, inspection is visualbased, where veterinary surgeons or animal health officers use organoleptic techniques to identify potential health hazards and the possible presence of contaminants. At the slaughterhouse, ante-mortem inspection is carried out to ensure: (i) there is no evidence of abnormal behaviour or appearance among the live animals; (ii) that diseased or injured animals are segregated; (iii) that animals are not handled in a manner causing avoidable pain or avoidable distress; and (iv) that animals have not died before the controlled killing. All animals destined for slaughter must be inspected a maximum of 24 h before slaughter using a two-step process. The first step is to segregate the animals based on appearance of health, disease or abnormality. The second step is to provide a mandatory veterinary examination and diagnosis of all the segregated animals deemed unhealthy or abnormal. Following the veterinary examination, affected cattle may be either released for slaughter or further segregated. In the latter case, the veterinary inspector assesses whether the animal must be destroyed or may be returned to the feedlot and medicated to improve its health for slaughter at a later date. Post-mortem inspection of the carcass focuses on the muscle tissue, the lymph nodes and the internal organs, to ensure that all carcasses appear Food Safety 04 70 29/5/01 2:36 pm Page 70 Chapter 4 normal and free from disease (i.e. such as lesions that generally appear on the organs of a tuberculosis-infected bovine) and that all materials used from carcasses (e.g. blood, organs, etc.) are clearly identified. The federal inspectors also perform invasive chemical residue testing activities on products pulled from the supply chain in the processing plant or at the retail level. At the discretion of the inspector, samples taken randomly along the processing stages or samples that appear to be diseased or abnormal may be sent to the Program Laboratories Directorate of the FID for chemical residue testing. This can include samples from those animals that have been segregated and destroyed in order to determine the reason for the animal’s unacceptable health. It should be noted that all of the CFIA activities and services are provided on a cost-recovery basis and their frequency is a function of the firm’s history of compliance. Since each inspection and audit described above will cost the firm money, the CFIA has created an incentive for compliance among industry. For instance, if non-compliance is found, the frequency of inspection and audit will go up and the costs to the firm for ensuring food safety will also go up. ADMINISTRATION OF SCIENTIFIC TESTS AT THE MEAT PLANT. The FID’s Program Laboratories Directorate administers four scientific testing programmes for microbiological, chemical residue or natural toxin contamination. They are: 1. The Core Monitoring Program where samples are tested to determine the level of known residues such as sulphonamides, antibiotics, pesticides, hormonal substances and microbial pathogens, that is, substances on the critical list of contaminants; 2. The Exploratory Monitoring Program where samples are tested for the presence of any new residues currently not on the FID’s critical list of contaminants; 3. The Surveillance Program which is a traceback programme designed to match any samples that have been identified as contaminated with the herd of origin and the slaughterhouse; and 4. The Bacterial Monitoring Program, where programme inspectors monitor the meat processing at critical stages of production to verify that the plant’s processing methods and its safety control measures are adequate in preventing contamination of the food supply. The Program Laboratories Directorate of FID also provides an accreditation service to independent auditing firms and food testing companies. Accredited firms may then conduct laboratory tests for the federal inspectors. ASSISTANCE WITH THE VOLUNTARY ADOPTION OF HACCP. Apart from the mandatory inspection activities, the FID also encourages and assists in the voluntary adoption of HACCP systems. If the slaughterhouse or processing plant has voluntarily adopted a CFIA-approved HACCP system, federal inspectors Food Safety 04 29/5/01 2:36 pm Page 71 Canada 71 do not perform the front-line type of inspection services outlined above. Instead, the firm’s personnel are responsible for such activities while the federal inspectors monitor and audit activities at ‘critical control points’ in the food production chain to ensure the company-based inspection techniques are adequate to control the risk of contamination. The CFIA promotes the voluntary adoption of HACCP through the FSEP. This was designed by AAFC in 1996 and taken over by CFIA when it was formed in 1997. The FSEP programme is based on five steps. They are: 1. The firm develops a proposed HACCP system including details of critical control points, product flows and prerequisite programmes (e.g. Standard Operating Procedures) specifically tailored to the firm’s products and processes. The prerequisite programmes are required to be consistent with the international principles and standards of the Codex. Through the FSEP, the firm can receive a HACCP Curriculum Guideline as well as the four-part HACCP system manuals. 2. The CFIA assesses the proposed HACCP plan. If the proposed plan requires some refinement then the firm is assisted in achieving the FSEP requirements for a HACCP scheme. 3. Once the HACCP system is approved, the firm’s personnel are responsible for controlling, monitoring and keeping accurate records for each critical control point. Firm managers must review the documentation to identify deviations, discrepancies or problems requiring corrective actions. 4. The CFIA then reviews all plant records, assesses corrective actions where necessary, observes on-line processing at critical control points, takes samples as appropriate and verifies that the overall HACCP plan is being followed. 5. The CFIA inspectors monitor the company inspections and audit the HACCP documentation to ensure the firm is complying with the HACCP principles. One of the implications of the introduction of HACCP has been the need for training and upgrading of inspectors’ skills. All CFIA personnel involved with monitoring firm-based HACCP systems must complete a HACCP Certification Protocol Program. This programme provides information and training on how properly to verify prerequisite and HACCP plans. The CFIA personnel are also trained on how to monitor and audit the firm’s HACCP system effectively. However, this has provided a significant internal administrative challenge to the CFIA as it attempts to deal with the resistance of CFIA inspection personnel to change. It should be noted that, unlike the USA, the adoption of an HACCP system in Canadian meat plants is not mandatory. Rather, the firm chooses whether or not to adopt a HACCP system. Both small- and medium-sized firms may be eligible for funding to assist in the adoption of a HACCP system. The maximum amount for 1 year is C$5000 with funding renewal possible for a maximum of 3 years. Food Safety 04 72 4/7/01 4:19 PM Page 72 Chapter 4 ENFORCEMENT OF FOOD SAFETY REGULATIONS AT MEAT PLANTS. With respect to the issue of enforcement in the event of a company’s non-compliance, the CFIA has broad enforcement powers as outlined in the 1997 Canada Food Inspection Agency Act. This includes jurisdiction over the 1995 Agriculture and Agri-Food Administrative Monetary Penalties Act. This Act was created in order to establish monetary penalties for non-compliance of firms with several federal Acts related to the agricultural food industries. This enforcement legislation applies to: the Canada Agricultural Products Act; the Feeds Act; the Fertilizers Act; the Health of Animals Act; the Meat Inspection Act; the Plant Protection Act; and the Seeds Act. If a violation of any of the Acts under the Agriculture and Agri-Food Monetary Penalties Act is identified or suspected, the violation must be ranked as a minor violation, a serious violation or a very serious violation. The CFIA may take one of four actions. It may require the recall of an unsafe food product, diseased animal or plant that poses a risk to the public, animal or plant health. It may apply to a court for an interim injunction to prevent further production or distribution of the unsafe food product; it may levy and collect enforcement fees for non-compliance; and it can withdraw or withhold services should a client fail to pay a prescribed fee. The severity of the enforcement is associated with the risk profile of the particular food product and the degree of contravention. Before a monetary fee is fixed, consideration is given to several factors such as the degree of negligence, the actual or potential harm inflicted, whether or not the violation was committed for commercial gain or benefit, as well as the individual firm’s history of compliance with the food legislation. The maximum monetary penalty for a minor violation is C$2000, for a serious violation is C$10,000 and for a very serious violation is C$15,000. In the event that the violation is found not to be for commercial gain then the assessed penalty is C$2000. At the time of writing, the CFIA had prosecuted or was currently prosecuting for non-compliance in 94 separate cases of violation. As a result, 65 firms have been assessed monetary penalties ranging from C$2500 to C$15,000. A firm found guilty of a violation may enter into a voluntary Compliance Agreement with the CFIA committing itself to ensuring future compliance. A commitment such as this by the firm may reduce the original monetary penalty levied. CFIA personnel would then monitor and audit the firm to ensure that the firm is complying with the usual standards and regulations as well as the Compliance Agreement. Another option open to the CFIA to assist enforcement is cancellation of a firm’s registration licence. Such an action would effectively prevent the firm from producing for interprovincial or international trade. This process involves first a written notice of cancellation summarizing the reason for cancellation, including a copy of the original inspection report that identifies all areas of non-compliance. The firm is offered a time frame to prove compliance and prevent the cancellation of the registration. But, failure to do so would Food Safety 04 29/5/01 2:36 pm Page 73 Canada 73 result in a hearing involving the CFIA and the violating firm. If the firm is unable to show adequate commitment to compliance, then a Notice of Cancellation of Registration is delivered to the firm. INSPECTION OF IMPORTED MEAT AND MEAT PRODUCTS. The aim of import inspection programmes is to protect domestic consumers from foreign meat where the source country has an inferior domestic food safety system or has recently experienced a food safety crisis. The CFIA must coordinate with the Canada Customs and Revenue and clarify roles and responsibilities to ensure: that all import products comply with domestic health, safety and quality standards; that there is consistency across all products and all regions in Canada; and to ensure the expeditious processing of imports. The CFIA and Canada Customs Agency have undertaken a Joint Service Initiative providing opportunity for CFIA personnel to inform, educate and train Customs officials on what are the CFIA import requirements. For some imported food products, the pre-retail stage (i.e. when products are finished or market ready) may be the only opportunity FID inspectors have to carry out inspections. This is not the most effective way to ensure that imported products are safe. In fact, the current rationale is imports need to be controlled in a manner consistent with the way domestic production is controlled and monitored. For imports, this must occur before they are shipped rather than when they enter Canada. The CFIA applies three basic rules to imported food products: 1. They must originate from countries having product standards and regulations, and a system for inspecting processing facilities, at least equivalent to the Canadian system. Equivalency is determined by CFIA auditors who examine the food safety legislation and the industrial practices of the foreign producers. 2. They must meet the domestic grade requirement for similar products produced in Canada. 3. They must bear a product origin label and label information must be congruent with the Canadian Consumer Packaging and Labeling Regulations. The CFIA work with the administration of foreign governments to ensure these rules are met. One example is the Canada/United States Border Management Accord. The goal of this accord is to establish the framework allowing for the harmonization of import inspection activities, the sharing of facilities and resources and the exchange of information. The CFIA has introduced four initiatives to make the import inspection process efficient and effective. They are as follows. 1. The Product Inspection Program (PIP), which is the traditional, visualbased inspection service provided at the border on imported products that have not been pre-approved for import. 2. The Enhanced Import Operation (EIO), which is designed to facilitate thorough yet expeditious import inspection as it is too time- and resource- Food Safety 04 29/5/01 2:36 pm Page 74 74 Chapter 4 consuming to handle all imports under the PIP. Two initiatives have been implemented under the EIO to speed up the import inspection process. They are Import Primary Contacts (IPCs) and the Agricultural Pre-Arrival Review System (Agri-PARS). The IPCs handle approximately 94% of all food products imported into Canada. Agri-PARS is a special expedited import procedure for importers who have proven to be compliant, reliable and trustworthy. Through the Agri-PARS the importer is encouraged to secure pre-arrival clearance by sending the Import Declaration forms ahead of the shipment. Such importers are eligible for a Frequent Importers Release status implying that the history of compliance is exceptional and the import products are considered to meet or exceed Canadian standards and regulations. 3. The Enhanced Importers Responsibility Program (EIRP), through which products are ranked according to their risk profile as established by HC. Thus, PIP would be carried out with a high level of inspection frequency for products of identified high risk and from importers who do not have a history of compliance with Canadian standards and regulations. Products with lower levels of risk would be subject to lower levels of inspection frequency. 4. The National Audit Program (NAP), which is designed to ensure that inspectors across the country are inspecting and monitoring imports in a manner consistent with other imports and domestic products. Import declarations and the judgment of inspectors may be reviewed to determine consistency in the inspection results. Ultimately, the NAP attempts to harmonize the programme delivery of the CFIA inspectors. This programme is a way for the FID inspectors themselves to be monitored for both effectiveness and compliance with their duties; a case of checking the checkers. In addition, the CFIA has a number of other initiatives under development to streamline the import inspection process. These include: 1. The Electronic Data Interchange (EDI) System for electronic import inspection and import clearance programmes to ensure rapid decision making. 2. The Automated Import Reference System (AIRS) for timely and accurate information on Canadian import requirements for potential importers. 3. The Import Tracking System (ITS) for improved tracking of an imported shipment after import inspection. This is intended to enhance the CFIA’s ability to respond to any problems with an import product (e.g. through a product recall) before it reaches the Canadian consumer. 4. The Import Decision System (IDS) for consistent decision advice to the CFIA or Customs Canada personnel on the proper inspection action to be taken. This System would contain information on such variables as country of origin, particular foreign brand, seasonal factors and packaging types. ACTIVITIES AT THE RETAIL LEVEL. At the retail level, the FID verifies that food advertising complies with requirements and it performs retail inspection to enforce labelling standards in order to prevent economic fraud. Retail Food Safety 04 4/7/01 4:20 PM Page 75 Canada 75 inspection is designed as a reactive ‘spot-check’ test for safety and to ensure that the label accurately reflects the contents of the package. CFIA inspectors may collect samples to perform residual testing or to be weighed to ensure price accuracy (although this is also performed by Industry Canada product inspectors). As part of the Food Emergency Response Program (FERP), it is also responsible for instituting and monitoring the recall of unsafe beef when necessary. FERP is an interdepartmental initiative involving both the CFIA and HC and is responsible for conducting science-based Health Hazard Evaluations (HHE) following identified outbreaks of food contamination. It deals with any extraordinary food product emergencies such as product recall, sabotage, product-related illness, serious allergies as well as man-made or natural disasters threatening the safety of the food supply. The HHE of a food-related emergency are based on a three stage categorization (I, II, III) with I posing risk that the product will cause serious health consequences or death. In this case, the course of action may be to implement a widespread product recall. The CFIA also provides Emergency Response Manuals to industry designed to inform a firm of the procedures for when a mandatory food recall may be necessary and how the food recall will be administered. For example, between April 1997 and August 1998 there were 164 food recalls under the FERP where 46 recalls were stage I, 104 stage II and 14 food recall cases were stage III. As a new Special Operating Agency, the activities of the CFIA in the Canadian food safety system have been subject to an internal review of the CFIA legislation. This was undertaken by the Task Force on Legislation. Specifically with respect to the beef industry, the Task Force has identified several important areas where further consultation on the appropriate role of the CFIA is warranted. One issue was whether legislative renewal should consider more the role of voluntary codes of practice (i.e. market regulation) as opposed to the mandatory legal regulation. Codes of practice were seen to allow the industry more flexibility of interpretation. Another issue is the possibility of allowing third parties to perform accreditation, certification and verification activities, which include monitoring and auditing. The Task Force also argued that any legislative changes should ensure safe and nutritious food while not contravening industry competitiveness. However, with increased industry responsibility for food safety, the legislative framework must also be capable of dealing with industry non-compliance. The Task Force’s consultations on these issues resulted in some general objectives of new food legislation. The first and most inclusive is a consensus on the need to develop a Single Food Act harmonizing the legislation of the 13 Acts under the current jurisdiction of the CFIA. It was argued such an Act should: 1. Consider both food safety and industry competitiveness issues; 2. Be focused at every stage of the processing supply chain, rather than the current emphasis only on the processing stages; and Food Safety 04 76 4/7/01 4:20 PM Page 76 Chapter 4 3. Base all food policy under this Act on a scientific risk analysis framework applied in a uniform and consistent manner to all domestic and foreign products sold in the Canadian market. The CFIA Management Council meeting from 15 to 17 April, 1998 identified three key future issues facing the CFIA: 1. To improve risk management services and activities; 2. To implement an Integrated Inspection System (IIS); and 3. To update and streamline the CFIA’s organizational structures. The IIS is a proposal to extend CFIA’s risk management activities (inspection, monitoring and auditing) beyond meat plants to include the entire meat supply chain in an integrated risk management system. Its development would be based on a number of principles including: 1. An emphasis on a whole-of-chain, science-based risk analysis framework where HC performs the risk assessment and the CFIA performs the risk management; 2. Reliance upon government and industry partnering to ensure the IIS is congruent with both food safety and industry competitiveness concerns; 3. An extension of the focus of intervention beyond the processing stage of the food supply chain to encompass primary producers, processors, distributors, retailers and food preparers; 4. The identification of hazards along the supply chain through consultations with the various stakeholders including; food industries, government, consumers, the health-care industry and environmental groups; and 5. The harmonization of food safety systems across Canada so the IIS may be applied by governments at the federal, provincial and municipal levels as well as by private sector parties such as independent auditors and food production firms. The benefits of a harmonized IIS include an enhanced level of risk management efficiency and effectiveness in the Canadian food safety system and a consistent and equitable science-based method for determining a product’s risk level. These benefits result in a reduction of overlap and duplication, a more efficient allocation of resources and a uniform national approach ensuring market access for Canadian products. There are three challenges to the development of the Canadian IIS. First, the IIS should be flexible enough to deal with future risks to human health. To achieve this flexibility, it may be more beneficial to develop IIS codes or guidelines rather than legislation. Second, a nationally harmonized IIS may have to be mandatory, which requires some form of legislation to ensure adoption by the entire food supply chain across all product lines. Third, the harmonization of risk management activities across all levels of governments and across all provinces is viewed as especially difficult to achieve because of the differential levels of regulatory oversight that exist among these jurisdictions and the need to achieve consensus across these different jurisdictions. The CFIS-IG experienced similar difficulties in its work on the National Meat Code. Food Safety 04 29/5/01 2:36 pm Page 77 Canada 77 AAFC When the CFIA was created in 1997 it took over many of the risk management activities previously performed by AAFC. But, despite the creation of the CFIA, AAFC will continue to impact the overall beef safety system in Canada in two main ways: first through the Health of Animals Division (HAD) and then through the Red Meat Section of the Market and Industry Services Branch (MISB). HAD veterinary surgeons and animal health officials continue to monitor the health and welfare of livestock animals on the ranch or in the feedlot. Their focus is on the eradication of bovine diseases such as tuberculosis, foot and mouth disease, anthrax and brucellosis as well as the prevention of the introduction of any foreign animal diseases such as BSE to Canadian herds. With its goal of prevention and eradication of livestock diseases, HAD performs several key functions including; laboratory research in identifying and diagnosing diseases; domestic herd monitoring and treatment for disease and abnormality; monitoring for the humane treatment of livestock; and import controls such as animal health tests before the import clearance of live animals. MISB performs an exclusive producer promotion role of assisting the industry to compete in domestic and international markets. Assistance to industry from the Red Meat Section includes; meat industry analysis, domestic and international market information and analysis on livestock and beef, updated information on the import standards from over 100 foreign destinations, red meat commodity strategies and meat technology development and adoption. The Red Meat Section also works as a liaison between foreign regulators and the Canadian food safety system to ensure that the domestic system continually meets import requirements. Provincial, territorial and municipal governmental arrangements As previously mentioned, the CFIS-IG is currently working on harmonizing the standards and regulations for the meat industry across all levels of government – federal, provincial, territorial and municipal. This initiative has emerged because of the differences between jurisdictions in the regulatory requirements for meat processing; especially the requirements for inspection frequency, inspection cost and physical plant facilities such as equipment, buildings and grounds. The differences result in two broad industry concerns. First, meat plants are concerned that these differential requirements provide competitive advantages to particular producers (i.e. those that face few food safety costs) or that these differences fragment the Canadian market and hinder equitable market access because of interprovincial limitations to trade. Second, there are industry concerns that differing federal, provincial and municipal standards and regulations might force the Canadian food safety system down to the lowest Food Safety 04 78 29/5/01 2:36 pm Page 78 Chapter 4 regulatory levels prevailing within Canada because of the ‘National Treatment Provision’ included in various international trade agreements. Some observers believe that Canadian markets may be exposed to imports that meet only the lowest standards prevailing in Canada. These would be the standards maintained by some small meat plants, serving only local (intraprovincial) markets, which are only subject to site inspections by a local public health officer, perhaps once every couple of years. The current Canadian government position would dispute this interpretation of national treatment. In the government’s view national treatment requires import standards to be the same as the federal standards (i.e. as required for the interprovincial and international movement of meat and meat products). Non-governmental arrangements Along with the changes in the role of government in the Canadian food safety system, the beef industry has been undergoing developments of its own. Through a process of cooperation and coordination many industry associations are developing programmes designed to enhance, and in some cases replace current government activities in the area of producer promotion. In some cases, consumer protection issues are also addressed. Foremost among the industry developments is the new Canadian Beef Grading Agency, but other national industry associations include the Canada Beef Export Federation (CBEF) and the Canadian Cattlemen’s Association (CCA) where most provinces have at least one regional industry association for the cattle/beef industry. Some of the initiatives of these industry associations will be examined below. Canadian Beef Grading Agency The Canadian Beef Grading Agency was created when the government privatized its beef grading activities on 1 April 1996. This agency performs a producer promotion role in its attempt to develop and deliver a grading system based on objective/scientific standards of meat quality and retail yield to facilitate the marketing of domestically produced meat products. The early response from the industry is one of acceptance of the cost recovery nature of the service. Although the Canadian Beef Grading Agency is primarily focused on quality aspects of the meat supply, it does have an impact on food safety. Firms who wish to have their products graded must be federally registered and must achieve some base level of standards and regulations for food safety. Meat graders have the authority to refuse to grade carcasses or meat cuts which appear to be abnormal, diseased or contaminated even though they may have made it through the mandatory government inspection system. Food Safety 04 29/5/01 2:36 pm Page 79 Canada 79 A current initiative of the Agency is the development and implementation of a new grade of beef. This new grade, ‘Canada Prime’ is to be conferred on those carcasses which achieve at least an AAA grade and show marbling equivalent to the ‘USDA Prime’ grade. This development represents an attempt to develop equivalency with the USA on quality standards as well as safety standards. CCA The CCA is an industry association with a mandate to enhance the competitiveness of the Canadian beef industry. It aims to carry out this mandate by: (i) providing a safe supply of beef products; (ii) providing consistent, highquality products; (iii) providing customer service; and (iv) promoting innovation in the industry. To assist in carrying out this mandate it has adopted the principle of attempting to improve the relationship between industry and consumers with minimum governmental intervention. It sees food safety as basic to achieving its objective of enhancing competitiveness. It has identified food contamination as a major challenge to the competitiveness of the Canadian beef industry because a real, or perceived, contamination crisis can adversely affect the entire industry. As a result, one objective of the CCA is to manage and reduce the risk of a contamination crisis upon the industry. To achieve this it has developed a strategy called the Integrated Food Safety Program. According to this strategy, the focus of the CCA should be on: ● ● ● ● ● ● ● ● establishing minimum food safety requirements for market access; assessing the environmental impacts of the beef industry; establishing standards for animal welfare; developing consistent and science-based labelling and nutrition information rules; assessing the application of modern agricultural biotechnologies in the beef industry; developing a traceback system; encouraging the development and implementation of ‘pasture to plate’ food safety and quality assurance programmes and initiatives; and establishing product handling procedures for maximum safety and quality at all points in the food chain. Under the auspices of the Integrated Food Safety Program, the CCA is involved with several producer promotion initiatives that have implications for the goal of consumer protection. For instance, the CCA released a manual outlining ‘good production practices’ for ranch operators. This manual follows the release of a similar manual for feedlot operators. Together, these manuals, promoted under the CCA’s ‘Quality Starts Here’ programme, are designed to disseminate information to producers on how to maximize the value of their livestock proactively through control of those particular hazards that reduce Food Safety 04 80 29/5/01 2:36 pm Page 80 Chapter 4 the value of their livestock. These hazards may include the existence of tags on the animal’s hide (dirt and faeces), improperly administered veterinary biologics as well as undue stress to the animals brought on by the inhumane treatment. The principles on which these manuals are based are consistent with HACCP principles. In short, through the ‘Quality Starts Here’ programme, the CCA is introducing HACCP to a part of the supply chain where there is no mandatory federal governmental involvement. The CCA has also released a proposal for a mandatory National Beef Identification System; an industry-led traceback system designed to ensure consumer confidence in beef products. By tying good upstream practices with downstream products through traceability, the safety of the food supply is improved. The initial system calls for traceback from the processing plant/ carcass stage to the herd of origin. The long-term goal is to develop traceback abilities from the finished meat products to the herd of origin. The benefits from such a system include the ability to react rapidly to any identified contamination by identifying the herd, isolating the spread and finally eradicating the problem. Consumers may be confident that the meat they consume is produced in a supply chain concerned with ensuring the safety and quality of its product. As an industry association, the CCA suggests that strategies such as the National Beef Identification System are vital because they limit the need for government intervention and regulation of on-farm and processing firm practices. One initiative intended to improve international competitiveness while at the same time lowering food safety costs is the so-called North West Project. The CCA began this project in October 1997 in partnership with its US counterpart, the National Cattlemen’s Beef Association. The Project created an open trade corridor, which allows shipments of feeder cattle to be sent from Montana and Washington State to Alberta feedlots without having to go through the costly herd health tests normally required of such international shipments. These cattle are fed out and slaughtered in Alberta and the meat exported back to the USA. Only specifically registered feedlots can take the US cattle, which must continue to be segregated both before and after the controlled killing to ensure there is no introduction of any bovine disease to the Canadian herds. This Project has had a number of advantages. It provided the Alberta cattle feeding industry with access to more feeder cattle, it lowered transportation costs and it caused less stress and hardships to the livestock thus adding to the humane treatment of the animals. Finally, the CCA runs an informational network for beef industry participants called CANFAX. This system provides access to market information, intelligence and analysis and is a link to current issues facing the beef industry. The safety of beef products has been a common current issue. This has resulted in the availability of information on research dealing with the prevention of microbial contamination and with improvements in the systems for ensuring food safety. As well, information is available on the safety requirements of importing nations. Food Safety 04 29/5/01 2:36 pm Page 81 Canada 81 Canada Beef Export Federation (CanadaBEEF) The Canada Beef Export Federation supports the export activities of the Canadian industry by providing it with information, intelligence and analysis on foreign market conditions including trade restrictions based on health or sanitary standards. It also provides information for foreign importers on the Canadian food safety system including the level of inspection and the various safety and quality assurance programmes to which the export products are subject. Indeed, while the primary objective is to increase the competitiveness of the Canadian beef industry, a consequence is the provision of information to increase foreign consumer confidence in the safety of Canadian beef products. Cargill Beef Alliance: BEEFWorks This was an industry attempt to integrate quality assurance programmes through the development of a brand-specific supply chain. Cargill operates feedlots, slaughterhouses, processing plants and distribution channels in both Canada and the USA. The objective of this programme is to achieve higher returns for all supply-chain participants by adopting production performance standards exceeding the required levels as well as those of other industry competitors. To do this, ranches that can prove their ability to adopt a highlevel of quality assurance earn the designation of Preferred Calf Suppliers (PCS) and can sell their livestock to Preferred Feedlots (PF). This programme attempts to utilize innovative, scientific methods to ensure a high-quality supply of cattle to PF. Although the BEEFWorks programme is focused on quality, safety is implicitly considered since quality products are necessarily safe products. Implications of these Developments From this review, it is clear the restructuring of the Canadian food safety system is on a very different trajectory from that of the USA. The Canadian trajectory has been: To ensure international market access – especially to the US – by encouraging industry competitiveness in all areas including food safety. However, its ability to be internationally competitive may be constrained by the direction and pace of restructuring in the US food safety system. The differences between the US and Canadian trajectories show up in subtle ways. For example, whereas the US MEGAREG made HACCP mandatory in all meat plants, in Canada it is voluntary. A mandatory programme is consistent with the need to restore consumer confidence, while this is not so important if the driving force is greater international competitiveness. Food Safety 04 82 29/5/01 2:36 pm Page 82 Chapter 4 Given the importance of the external driver to Canada, the restructuring of the Canadian meat safety system is bounded by the restructuring in the dominant export market, namely the USA. It is not surprising the main focus of governmental intervention in Canada is the slaughter stage, rather than the pre-slaughter or the post-slaughter stages. This mirrors the situation in the USA. The challenge for those attempting to restructure the Canadian beef food safety system is to move beyond the limits posed by US restructuring. In particular, other issues for Canada such as a harmonized, integrated food safety system and the development of a co-regulatory system of meat inspection (see Australia) are moving slowly. On the question of harmonization, this is not an issue for the USA. What is an issue for the USA is that Canadian meat export standards are equivalent to US standards. Hence, the Canadian system persists in having differential standards where the highest safety standards are required of firms producing for the export market and the lowest standards are faced by firms producing solely for the local market. Co-regulation is the partnering of industry and government to regulate the beef industry. Under co-regulation, responsibility for ensuring food safety is moved away from just the shoulders of government, and participants in the beef supply chain assume some of this responsibility. While the Canadian system is shifting in this direction, the speed of this shift is bounded to a large extent by how fast this is going on in the USA. Australia is moving much faster down this road. Looking to the future, there appears to be a loss of political momentum in the USA for restructuring the food safety system. For Canada, this translates into the loss of an important external driver for change. Given also, the lack of strong internal drivers for change, there is a danger of rising complacency about institutional change in Canada. This could pose problems for Canada to the extent that the quality of a food safety system is an important contributor to international competitiveness. This completes the North American leg of our tour. We now ‘cross the pond’ to take a look at the food safety system in the UK. This promises to be quite different from either Canada or the USA.