AGRI Committee Report

Food Safety in Canada: Everybody’s Responsibility

A Dissenting Opinion by the Conservative Party of Canada on the Report of the Subcommittee on Food Safety

The Conservative Party of Canada presents this report regarding the recent study on food safety by the subcommittee, established by the Standing Committee on Agriculture and Agri-Food, as our witnesss believe that the main report does not sufficiently, accurately and/or fairly address certain issues.

The safety of our food is an issue that all Canadians care about. The Listeriosis outbreak of summer 2008 was traced back to ready-to-eat meat products produced at a Maple Leaf Foods plant in Toronto. Sadly, 22 people died from listeria-related diseases and many more became sick. This tragedy has raised some questions about the food safety system in Canada.

In this context, the Standing Committee on Agriculture and Agri-Food (SCAAF) struck the Food Safety Subcommittee with two general goals:

1)      Study the Listeria outbreak of 2008 and make recommendations for future outbreaks of this kind.

2)      Study Canada’s food safety system in general and make recommendations to improve food safety in this country.

 The Subcommittee on Food Safety has heard from witnesses from all over Canada, all levels of government, farm groups, food processors, food retailers, food safety academics and experts, and of course consumers. One common theme that has come from every witness is that we expect a safe supply of food and that everyone needs to work together – from the farm gate to the kitchen plate – to ensure that our food is indeed safe.

In Canada, food safety is a shared responsibility between industry, federal and provincial governments and consumers. Food processors have the responsibility to produce safe food, government has the responsibility to set the standards for food safety and enforcing those standards and consumers have the responsibility to handle food safely. Health Canada is the federal department responsible for developing the standards industry must follow and the Canadian Food Inspection Agency (CFIA) is the government’s regulatory authority to ensure industry adheres to the standards.

When a human-illness outbreak occurs, jurisdiction rests with municipal and provincial/territorial authorities to manage the outbreak and conduct the epidemiological investigation. Once the outbreak crosses provincial boundaries, the Public Health Agency of Canada (PHAC) takes the lead on managing the outbreak. It is up to the public health authorities to determine the source of the outbreak and in the case a food is identified; public health must inform the CFIA to conduct a food safety investigation to pinpoint the specific source and initiate a recall.

LISTERIA OUTBREAK

The 2008 listeriosis outbreak called into question CFIA’s approach to inspection in ready-to-eat meat plants as well as the approach taken by the responsible agencies and departments that manage foodborne illness outbreaks when they develop. 

CFIA’s inspection of ready-to-eat meat plants is based upon its inspection staff carrying out a series of tasks under the Compliance Verification System (CVS). CVS was developed by CFIA for federally registered plants, all of which operate under a Hazard Analysis Critical Control Points (HACCP) system. HACCP, was designed to improves food safety by identifying the areas in a plant (or a farm, grocery store, or any other portion of the supply chain) where potential food safety issues may arise and stipulates actions required to correct the problem and mitigate the risk to food safety. Maple Leaf Foods had a HACCP system in place however; it did not anticipate the buildup of organic material deep inside the meat slicers, where the most likely source of contamination was discovered. It wasn’t until the slicers were fully disassembled that the material was discovered. The Committee heard that CFIA inspectors disassembled slicing equipment as part of their regular inspections however testimony from Dr. Brian Evans refuted those arguments and stated that “to infer that in fact we, at CFIA, were somehow dismantling slicers on our own in past years I don't think is accurate.[1]”

Experts from CFIA and Maple Leaf concluded that this organic source was the most likely source of listeria contamination. Dr. Brian Evans again testified that “what was critical to this whole event was this determination at the end of the day that in spite of cleaning and disinfection and breaking down of equipment according to manufacturers' specifications, beyond the cutting and contact surfaces, a new threat, a new issue, was identified in this particular circumstance, which we had no knowledge about, that could colonize deep into the equipment.[2]”

Michael McCain even testified that, “No amount of inspection, be it higher or lower, would have changed that outcome. If you want to go to the exact cause of this outbreak, it was not about a lack of inspection. It wasn't about the lack of product testing or a lack of inspectors.[3]” Witnesses directly involved in the Maple Leaf plant repeated Mr. McCain’s opinion that the inspectors at the plant did their jobs and were adequate.

The management of the outbreak also revealed coordination issues revolving around the recall process, internal and external communications, and responsibility when it came to all agencies involved across all levels of government as well as industry, specifically Maple Leaf Foods. Lessons Learned reports were done by CFIA, Health Canada, PHAC, and the Ontario Ministry of Health and Long Term Care. Additionally, Maple Leaf Foods provided the subcommittee with its own analysis of what lessons it learned.

In addition to these Lessons Learned reports, the Prime Minister of Canada announced in September 2008, that he would launch an independent investigation into the outbreak. Shelia Weatherill was subsequently appointed to this position and her report is expected to be completed in late July, 2009.

A. Hazard Analysis and Critical Control Points (HACCP)

HACCP is an internationally accepted approach to manage food safety risks that ensures that industry and CFIA inspectors work cooperatively throughout the product line to ensure that potential risks are identified and managed. There was a general consensus among witnesses that the science-based HACCP system is the best way to identify and address potential problems early in the supply chain, before they occur. In regards to the importance of HAACP in facilities like Maple Leaf, Dr Brain Evans testified that “HACCP helped them arrive at a conclusion much earlier than would otherwise have been the case.[4]”

            RECOMMENDATION 1

CFIA should continue to work with Industry to develop HACCP, as it focuses on the prevention of food safety risks, rather than ‘after-the-fact’ detection on end products.

B. Compliance Verification System (CVS)

CVS is an inspection tool that was developed by CFIA in 2005 and piloted in 2006 to give inspectors a checklist to ensure the existing HACCP systems in place at a food processing facility are monitored and audited in a consistent manner across the country. CVS was fully implemented in April 2008 and adds new requirements to traditional inspection tasks where inspectors must review paperwork to ensure a plant is following its HACCP plan properly. For example, an inspector reviews records to ensure cleaning and disinfecting is taking place regularly and that a plant is conducting the microbiological testing required. Inspectors are also required to watch how the cleaning and disinfecting is done to ensure it is being done properly and they are required to conduct their own microbiological tests.

CVS has been criticized as “privatizing meat inspection” because companies are required to keep records to demonstrate they are adhering to their HACCP plans and do their own testing in addition to the government testing. According to Dr. Brian Evans, “CVS is not privatization[5],” and does not leave food safety in the hands of industry. Testimony to the Committee has shown that the Government has not and has no plans to privatize inspection. CFIA will always play its role as regulator and inspector. CVS tasks are continuously evaluated to ensure they remain current and relevant however, some concerns were raised by various groups that CFIA didn’t evaluate CVS properly before fully implementing the system.

On September 5, 2008, CFIA improved food safety controls ready-to-eat plants by adjusting CVS tasks for its inspectors to control bacteria and other food borne pathogens in federally registered ready-to-eat meat plants. CFIA also directed industry to aggressively and thoroughly clean slicing equipment; enhanced oversight of sanitation and equipment maintenance, started reviewing company records of end-product and environmental test results on a daily basis; started analysing trends in positive environmental test results to flag any potential problems early; and completed a review of cleaning and sanitation programs used in all federally registered ready-to-eat meat plants.

            RECOMMENDATION 2

CVS should remain the fundamental system that guides inspectors and assures consistency and uniformity in their inspection activities.

            RECOMMENDATION 3

CFIA needs to undertake a full evaluation of CVS to ensure that it is working to its full effectiveness.

C. Environmental Testing

As of April 1, 2009, it is mandatory for food processors to report the results of their environmental tests to CFIA. This will allow CFIA and industry to analyze trends of positive listeria results to preemptively flag potential problems. Testimony from Agriculture and Agri-Food Minister, Gerry Ritz; President and CEO of Maple Leaf Foods Inc., Michael McCain; Executive Vice-President and Chief Veterinary Officer of Canada, Dr. Brain Evans; and president of the Agriculture Union of the Public Service Alliance of Canada, Bob Kingston all supported the importance of environmental testing. Mr. McCain stated that, “the new listeria policy, we believe, is a very significant material step forward,” and that the “the most important question in enhancing food safety has to do with how you interpret the data.[6]” With this change, CFIA will be able to analyze the data and take immediate corrective action when required.

In 2005, under the previous Government, mandatory testing and reporting by CFIA was cancelled. As a result, Maple Leaf Foods was not required to submit its environmental test results to CFIA in the months leading up to the outbreak. For three months before the outbreak, Maple Leaf Foods collected periodic positive environmental tests results for listeria but was not required to submit the results to CFIA. As a result, CFIA was not informed of the listeria problem in the Maple Leaf Foods’ Toronto plant. Since April 1, 2009, plant operators must conduct environmental testing and immediately report any positive listeria results to CFIA. The new policy also adds additional environmental and end-product testing done by CFIA. With the new listeria policy now enforced an event like last summer “could possibly[7]” be prevented, according to the CFIA inspection supervisor for the affected Maple Leaf facility, Don Irons.

Had environmental testing for listeria not been cut in 2005, CFIA may have detected problems sooner. CFIA now does a data trend analysis on environmental listeria test results taken by food processors and acts preemptively to determine its root cause.

RECOMMENDATION 4

The Government of Canada should continue to support the new mandatory requirements for listeria testing and reporting as well as trend analysis by industry to CFIA inspectors.

D. Recall of Maple Leaf Products

In his statements to the subcommittee, Dr. Brian Evans summarized the timeline from last summer, “The listeriosis outbreak began in early June and was detected by public health officials in Ontario over the ensuing seven weeks. Detailed investigative work at municipal and provincial levels led to their advising the CFIA on August 6^th, 2008, that a possible food link was suspected. It was on August 6 that the CFIA was first informed of a public health investigation into two listeriosis cases in a nursing home. Samples taken 16 days previously from meat used to make sandwiches in early July at the facility had tested positive. On August 8^th CFIA determined the source plant and began to investigate unopened samples across Ontario to determine how many products were affected. By August 16^th, CFIA had the test results required to initiate the recall with Maple Leaf.[8]”

In order to do a recall, CFIA requires a link to a specific product. If on July 21^st Toronto Public Heath had sent proper samples with the right product information CFIA would have been able to react sooner.

The CFIA Office of Food Safety and Recall (OFSR) is responsible for conducting food safety investigations and initiating recalls when a food-borne illness is suspected. OFSR is an independent body with protocols that require them to take action as soon as they are informed of a potential food safety risk.

In order for a recall to be triggered, the CFIA has make a scientific link to the right food source (including product and lot codes) before the public is notified. If a recall goes out too early, misinformation can have a worse effect than an accurate recall at a later date. In Dr. Brain Evan’s testimony, he cited the U.S. example of inaccurate information on a strawberry recall several years ago. He went on to explain that giving the public “information that we can't validate …perhaps puts them at greater risk and cause them to change their behaviours[9]” is more harmful than no information. As a result of the raspberry recall, US consumers switched from eating strawberries to raspberries, but months later, it was determined that raspberries were what should have been recalled.

            RECOMMENDATION 5

The CFIA should maintain its evidence-based methodology of initiating recalls.

E. Communications

The issue of how the federal government communicated with the public during the outbreak was raised by many witnesses. Statutory requirements put the Chief Public Health Officer out front as the primary spokesperson for the Government of Canada. However, as ministers and the government are ultimately held accountable to answering the concerns of Canadians, the Minister of Agriculture and Agri-Food along with representatives of the CFIA and the Chief Public Health Officer conducted 14 press conferences between August 24 and September 9, 2008 to brief the media and to keep Canadians informed. Despite this strong government presence, many felt that Maple Leaf Foods did a better job communicating directly to the public through television commercials and other forms of advertising.

CFIA did note in its testimony that it can only notify the public when an issue tied specifically to food has been identified. They can not act on hunches and risk getting it wrong. However, the provincial health authorities are not under the same legal restrictions that bind CFIA, and may have communicated a public health risk to the public much sooner. Instead, as Dr. Williams of Ontario testified, they abdicated that responsibility to the federal government.

These faults in communication were noted by all government agencies in their testimony and the Lessons Learned reports provided to the subcommittee.

Recommendation 6

The federal government should review its protocols on providing timely, accurate information to the public and put in place the necessary protocols and resources to ensure that there is better communication to the public during a food-borne illness outbreak.

Internal communications between the responsible federal and provincial authorities was another area that all parties agreed need to be improved. The Foodborne Illness Outbreak Response Protocol (FIORP) was not activated by neither the federal government nor the provincial governments despite being a Federal/Provincial/Territorial agreement designed to facilitate communications during this very type of outbreak. The purpose of the FIORP is to establish clear lines of communication and protocols for all partners to follow. In addition, CFIA did not activate its emergency command centre, despite its sole purpose of managing emergency situations such as this one. As a result of this inaction, there was confusion among the partners as to who had the lead for which part of the investigation and which agency had the authority to do what.

The general consensus from witnesses is that Canadians do not want a food borne outbreak to become an opportunity for government agencies and departments to flex their bureaucratic muscles against each other – rather they would prefer that these agencies cooperate to put an end to whatever is happening.

Internal communications by the federal agencies, provinces and regional health authorities have improved since the outbreak. The Executive Director of the Canadian Meat Council, James M. Laws commented on the improvements in the Government agencies coordination, “Well, I can say that I think we've been very happy with the Government's actions lately on the header1N1 flu virus. That's the type of response we'd like to see in the future for other food safety events like this one.[10]”

RECOMMENDATION 7

The Government of Canada should support Health Canada, PHAC and CFIA’s effort to improve communications between themselves and other jurisdictions.

RECOMMENDATION 8

The FIORP should be activated when a food borne outbreak becomes apparent in order to better facilitate cooperation and communication between all levels of government and their respective agencies and departments.

F. Responsibility

Food safety is a shared responsibility from farms to the processing industry and all levels of government and even in our kitchens. Testimony from the president of CFIA, Carole Swan, states that “Responsibility for food safety does not reside in one person or one institution. There is a network of people and organizations responsible. Government has an important responsibility. We are responsible for setting strong standards and holding industry to account. But, ultimately, industry has responsibilities, as well; they have responsibilities for producing safe food. There is a great deal of shared responsibility. CFIA is one player in a continuum of players who are responsible for making sure that the food Canadians eat is safe.[11]”

The Codex Alimentarius (published by the World Health Organization and the Food and Agricultural Organization of the United Nations) states that everyone, including farmers and growers, manufacturers and processors, food handlers and consumers, has a responsibility to assure that food is safe and suitable for consumption. The Canadian Food and Drug Act also clearly describes the shared responsibility between Government and industry. 

Industry

Maple Leaf Foods has taken responsibility for the listeriosis outbreak. Industry is ultimately responsible to ensure the products they produce, import, store and distribute are safe for consumers. They must identify potential issues and assist with food safety investigations. Industry also initiates or responds to direction to implement a recall.

CFIA

CFIA contributes to the control of food borne outbreaks through its food safety investigations and recalls, as well as its compliance and enforcement activities. It also notifies the public when specific food safety issues have been identified.  Food inspection programs administered by the CFIA confirm that establishments have taken the appropriate steps to produce safe food products.

Health Canada

Health Canada establishes food safety standards and policies along with decision-making with respect to a Risk Assessment Process. It also releases communication of issues related to food safety.

PHAC

The Public Health Agency of Canada (PHAC) is usually the first point of contact at the federal level for food borne illness outbreaks. It is in charge of public health surveillance and leads during an epidemiological investigation when cases occur in multiple provinces or if requested by a province. PHAC also releases communication of issues with a human health impact, including notification of the public.

Provinces/Territories

The province/territory leads investigations of human illness outbreaks within their boundaries including the epidemiological investigation. They also release communications of issues with respect to human health issues, including notification to the public.

Minister of Agriculture and Agri-Food

The Minister acted as the Government’s lead spokesperson to Canadians to keep them updated of the Maple Leaf outbreak. The independent government agencies conducted themselves appropriately and independent of the Minister’s influence. The agencies in fact did their job as they are required to do so by legislation.

Testimony from the Chief Public Health Officer of Canada, Dr. David Butler-Jones, indicates that there was no political interference and the agencies involved were allowed to do their jobs. Dr. Butler Jones said, “no one gave me direction about what information to provide, what questions to answer, how to answer questions, or what actions to take, from the Public Health Agency. No one. If they had, I would have resisted it. This is not a political role. That is clearly why this position was established with that measure of independence on matters of public health. No one from the Prime Minister's Office, the Prime Minister, no minister, no minister's office, said, “I want you to say this. If that was ever an issue I would have resigned.[12]””

The Public

The public, as consumers of food products, also have a responsibility to ensure their food is safe. Testimony placed the number of food borne illnesses in Canada at thirteen million every year. Most of these are due to improper handling of food in the kitchen or undercooking high-risk products like meat. It is incumbent upon the consumer to ensure that they follow the preparation and cooking instructions of the product they are to consume.

However, testimony from several witnesses pointed to the fact that despite efforts on the part of Health Canada and CFIA to educate consumers about proper food handling and cooking, the message still needs to be reinforced. The federal government can play a positive role in this area by promoting such safe practices to consumers.

RECOMMENDATION 9

Due to the complexity of food production the Government of Canada should continue to underscore the importance of the work with the provinces and territories to strengthen the shared responsibility approach to food safety.

RECCOMENDATION 10

The Government of Canada should adopt a plan to increase awareness and education of the public as to the importance of food safety at home.

G. Independent Investigator

The Prime Minister appointed Shelia Weatherill to be an Independent Investigator to assess how the Government agencies involved in last summer’s Maple Leaf Foods listeria outbreak preformed. Mrs. Weatherill is a highly qualified expert who has all the powers and resources to follow the evidence wherever it leads. The setup and practices of the independent investigator are identical to the Auditor General’s authority in an investigation. The Independent Investigator’s mandate requires Mrs. Weatherill to submit her report to the Minister of Agriculture and Agri-Food by July 20^th.The Minister of Agriculture assured the subcommittee that he will make her report and her  recommendations to strengthen our food safety system public.

The Independent Investigator testified that she had the “power, mandate, and resources to fulfill the expectations and conduct this investigation.[13]”

            RECOMMENDATION 11

The Government of Canada should review all findings of the Independent Investigator’s report.

 RECOMMENDATION 12

The Government of Canada should release the Independent Investigator’s report to the public.

FOOD SAFETY IN CANADA

The listeriosis outbreak of 2008, while a tragedy, is not indicative of Canada’s food safety system overall. There is a general consensus throughout Canada, supported by the witnesses that testified at the subcommittee, that we have one of the safest food systems in the world. However, there is always room from improvement. Areas identified for improvement include strengthening CFIA’s inspection resources and regime, the need for clarification between federally inspected plants and provincial ones, CFIA’s role as regulator of imported/exported foodstuffs, Country of Origin Labeling (COOL) restrictions on Canadian livestock exports, traceability of livestock and other agriculture products, and on farm food safety.

A. CFIA Resources and Regime

Budget

There has been testimony that CFIA needs increase its resources and training for inspectors. Bob Kingston has claimed that “as a consequence of a lack of resources, there isn't time to train the inspectors.[14]” The budget and inspector increases do not back up that claim. The budgets for CFIA have increased as follows 2005-06: $489.0 million, in 2006-07: $571.5 million and in 2007-08: $639.4 million. The budget for CFIA was only cut in 1994, 1995 and again in 2005. Additionally, the Government of Canada invested $113 million in the Food and Consumer Safety Action Plan in Budget 2008. In the Economic Action Plan for Canada, Budget 2009, the Government also announced an additional $250 million to upgrade federal labs, including those of CFIA.

            RECOMMENDATION 13

The Government of Canada should continue to make food safety a priority and provide CFIA with adequate budgets to ensure Canada’s food system is safe.

Inspectors

The Government has empowered CFIA inspectors with the most effective methods of inspection through CVS and HACCP.  CFIA inspectors have the necessary resources to do their job. The Government has hired, in its first two years, over 200 new inspectors. CFIA has increased its staff by 14% since 2006.   

            RECOMMENDATION 14

The Government of Canada should hire more inspectors as warranted and provide the proper training and resources for them to do their job.

B. Federal/Provincial/Territorial Regulations

The issue of federal versus provincial/territorial inspection standards was hotly debated among those who testified at the subcommittee hearings. Some witnesses, such as Mr. Peter Stein of Piller Sausages and Delicatessens Ltd. argued that “all plants, both provincial and federal, should be included in the scope of the new listeria policy released this past April 1^st.[15]” Others argued that a single standard would put local abattoirs who simply could not meet the federal requirements out of business. Jennifer MacTavish representing the Sheep industry summed this up: “If it's a reciprocal agreement among provinces so a domestic trade can occur, that would be wonderful. We do not want to put the smaller processing plants in any kind of a position where their livelihood would be threatened.[16]”

A one-size fits all approach to both provincial and federal inspections does not make sense in a country such as Canada. What may be acceptable in Quebec may not be acceptable in British Columbia. It is not the role of the federal government to dictate to the provinces/territories the standards they have to adopt for their own provincially regulated markets. This position is backed up by the constitution which clearly splits federal/provincial/territorial jurisdictions in agriculture. However, as some witnesses indicated this does not preclude the federal government from urging cooperation among all levels of government to adopt equivalency without driving local abattoirs out of business.

            RECOMMENDATION 15

The Government of Canada should ensure that its food safety standards are applied consistently across Canada in all federal inspected components of the supply chain.

RECCOMENDATION 16

The Government of Canada should encourage its provincial/territorial partners to adopt an equivalent food safety standard in all provincial/territorial abattoirs without putting undo pressure on smaller operations which may cause them to go out of business. 

C. Imports/Export

Testimony revealed that “exporters know between 72 hours and 30 days in advance whether their meat shipment to Canada will require visual inspection, full inspection, or no inspection.[17]” While it is reasonable for CFIA to give warning to Canadian importers that the product they are expecting may be detained for inspection, such a system should be enforced with the threat of random, unannounced spot checks.

            RECOMMENDATION 17

CFIA should review its policies and procedures with respect to advance warning for imported meat products to Canada.

There was a general consensus that “imported products must meet the same standards and regulations that we face here in Canada.[18]” The CFIA meets these standards through equivalency agreements with our trading partners. We only import products from countries that have food safety standards equal to those of Canada.

            RECOMMENDATION 18

The Government of Canada should continue to ensure imports meet the same standards as domestically produced products.

D. Pre-Market Labelling

Testimony on pre-market registration for meat products stated that it is not a food safety issue. Ensuring what is on the label is not a food safety issue. “Getting a label pre-approved—that's the important part—by somebody sitting in Ottawa who may never have been into a meat plant in their entire lives has nothing to do with safety.[19]”

There was conflicting testimony throughout on pre-marketing labelling with the Beef Information Centre Executive Director, Ms. Lisa Mina, testifying that, “rigorous monitoring and enforcement of product labels play a role to maintain confidence in the perceived safety of food products, such as meat, in Canada.[20]”

RECOMMENDATION 19

The Government of Canada should review the present system of pre-market labelling to protect the integrity of imported agricultural products while providing greater flexibility for Canadian companies to provide these imported products to consumers in a timely and safe manner.

E. Country of Origin Labeling (COOL)

COOL restrictions have been put in place by the U.S. Government as a ‘food safety’ measure. However, the general consensus is that COOL is not a food safety program but rather a non-tariff trade barrier to Canadian and other food exports to the United States of America. The Government of Canada has challenged the unfair COOL restrictions at the WTO in order to reach a negotiated settlement. The Government will continue to stand up for Canadian producers to ensure they are treated fairly. Livestock industries on both sides of the border are concerned about COOL.  These restrictions are detrimental to the free flow of trade with the U.S.

The president of the American Meat Institute, James Hodges testified that the Canadian Government’s stance on COOL is beneficial to the cattle industry in both countries “Trade action related to COOL is an appropriate remedy. It is a regulation that is not food safety. It is a regulation that is an impediment to trade.[21]”

RECOMMENDATION 20

The Government of Canada should continue to challenge COOL at the WTO and strive for a negotiated settlement.

F. Traceability

Traceability is a theme raised from all sectors of the supply chain. The ability to trace a product, be it a live steer on the farm or a box of asparagus at the grocery store, from a specific outbreak to its origin will not only allow faster product recalls it will boost confidence in Canada’s food supply.

One area that Canada is making progress in traceability is that of live cattle, especially in the wake of the initial BSE cases in 2003. Witnesses testified that BSE dealt a severe blow to the confidence of international markets in Canadian livestock and led to the closing of many borders to our cattle. One of the ways of restoring that confidence in the safety of our cattle is by being able to show potential customers the traceable history of that particular cut of meat or live animal. It is clear from the testimony that traceability is a key component of Canada’s food safety system.

In the new Growing Forward Framework for Agricultural there is almost $100 million for food safety systems and traceability initiatives.  The Government has invested in traceability under Growing Forward as another way to improve food safety.

            RECOMMENDATION 21

The Government of Canada should continue to invest in traceability to further protect the initial stages of the food supply chain and increase competiveness by ensuring these costs are not passed on to Canada’s primary producers.

G. On Farm Food Safety

The first step of food safety begins on the farm. The Government of Canada supports on-farm food safety program. Many producer groups testified that the food safety system begins with HACCP based systems on the farm. HACCP systems allow producers to focus on the most vulnerable areas of food safety. “Thousands of on-farm food safety manuals have been distributed on farms across Canada, I must note that the accomplishments would not have been possible without the collaboration and support, in financial resources and technical expertise, of both Agriculture and Agri-Food Canada and the Canadian Food Inspection Agency. The Government of Canada has made considerable investment in helping industry develop the program. The importance of this support cannot be emphasized enough.[22]”

The Government’s commitment to on-farm food safety needs to be in the domain of an efficient and streamlined regulatory system. “There needs to be some incentive for producers to participate. In the best case scenario, producers will be implementing the program in response to market incentives where they get paid a premium.[23]”

            RECCOMENDATION 22

The Government of Canada should support farmer’s efforts to produce safe food, implement farm HACCP systems, and ensure producers can operate in the most competitive environment possible.

CONCLUSION

Food safety is the responsibility of all Canadians. The listeria outbreak has shown that even with the most sophisticated risk-based approach to food safety, sometimes things can literally fall between the cracks and grow into large problems. The emphasis needs to be put onto all levels of government to ensure that the food they inspect is safe for consumption and that when a health incident does occur; cooperation takes precedence over turf wars. It is equally incumbent upon industry to ensure that the food they grow, process, transport, sell, and cook for Canadians is safe. Finally, it is up to the consumer to ensure that the food they eat is handled and prepared properly. It is when all of these groups work together, we can all be sure that our food is safe.