Improved Food Inspection Model
Final Model
3. Risk-based oversight
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Introduction
The CFIA, like other similar regulatory agencies in the world, uses scientific knowledge and risk analysis to inform its oversight and inspection activities. It is well understood that different food commodities and different preparation or processing approaches pose different risks.
Risk is generally determined by the scientific process of risk assessment in line with the Codex Alimentarius Working Principles for risk analysis. This process considers the following:
- Hazard Identification: identification of biological, chemical and physical hazards that are reasonably likely to occur in relation to a food commodity;
- Hazard Characterization: a process used to prepare the food commodity (for example, the likelihood a hazard could be introduced during preparation and/or the likelihood a hazard is controlled or reduced through the effective application of preventive controls);
- Exposure Assessment: assessment of the volume of production and target consumer groups; and
- Risk Characterization: the potential for illness to occur and impact consumers, if hazards are not adequately and properly controlled, reduced or prevented.
Food commodity risks posed by biological, chemical and physical hazards must be managed or eliminated during food production, processing, importing and distribution. It is the responsibility of regulated parties to produce safe food and mitigate food safety risks associated and demonstrate a commitment to a food safety culture within their operations by preventing, eliminating or reducing the risk to an acceptable level either through processing controls (for example, heat treatment) or through cross- contamination controls (for example, sanitation and hygiene).
The CFIA uses various information sources (for example, environmental scanning information, Codex Alimentarius standards, effectiveness of preventive control plans as demonstrated through inspection data and compliance data) and has implemented a number of monitoring and surveillance programs to expand the mapping of food-hazard combinations. This type of information, along with risk assessment, assists the CFIA in informing its approach for risk management, part of which is risk-based oversight.
Currently, the programs for the different food commodities are using somewhat different risk management approaches. The current risk management approaches are not accessible and are each structured differently.
In some cases, inspection activities and oversight are also affected by international requirements. Based on foreign country requirements, some regulated parties are subject to specific oversight requirements for eligibility to export to certain countries. Generally, these considerations flow from some countries having different standards for commodities. Similarly, Canada establishes requirements for imported food commodities. For example, to be considered to meet Canada's requirements, imported dairy products must be manufactured from sound raw materials, prepared under sanitary conditions, and, at the time of shipment to Canada, must be sound and fit for human consumption. Canada's regulatory requirements for food specify a consistent expectation for safety of all food commodities.
The CFIA takes the information related to risk and national and international standards (such as those developed by Health Canada or the Codex Alimentarius Commission), as well as international obligations into consideration as it organizes its inspection activities. Consequently, under the current food inspection system, establishments preparing or handling high risk commodities, such as ready-to-eat meat have inspectors present daily, while establishments preparing lower risk commodities, such as dry pasta and honey products, are inspected only periodically.
3.1 Risk-based oversight in the model
The CFIA has always used a risk-based approach for its inspection activities. As part of its modernization efforts, the CFIA will take a more structured and transparent approach to allocating resources without compromising food safety. The CFIA has developed a framework to provide a standard and consistent approach to improve its oversight activities (inspection, audits, directed sampling and testing, surveillance, etc.) on a risk basis.
The CFIA will:
- Take a more structured approach to analysing risks related to different food commodities by:
- updating food commodity risk information on a regular basis to take into consideration any developments in science, experiences in Canada or other countries, or new information;
- making the risk information more accessible and transparent; and
- applying this approach across all food commodities; and,
- Add a common systematic approach to assessing the preventive control plansFootnote 7 and the track record of regulated parties (including associated surveillance and recall data, certification to a private food safety standard that is recognized by the CFIA, and the regulated party's compliance history) to determine if inspection activities need to be adjusted. For example, once a regulated party has established a compliance history, the intensity of inspection and/or methods of inspection may be adjusted to correspond with how effectively the regulated party has prepared safe and compliant food.
The CFIA would rank food-hazard combinations from high to low in how likely they are to pose a public health impact.
On a predetermined basis, the CFIA would review the food commodity risks and regulated party track record history to confirm and/or update its information. Based on the information, the CFIA would then determine the frequency, intensity and type of oversight activities required and allocate its resources to those areas and regulated parties that represent the highest risk to public health. The CFIA would also continue to take into account any specific requirements of other countries to facilitate access to export markets.
In addition to the risk factors and the international obligations to maintain access to export markets, there are a number of triggers that could impact onCFIA oversight activities as elements of a risk management strategy. These include:
- response to food safety complaints, illness investigations or recalls;
- results of concern from an inspection process or sampling;
- information about a potential issue received from:
- a third party; including
- another government department; and
- an international trading partner;
- a request for inspection by a regulated party (for example, for export marketing purposes).
3.2 How does a risk-based approach work?
This systematic and structured risk-based approach would help the CFIA enhance its determination of:
- whether an inspection is required before licensing;
- the intensity at which the CFIA would inspect domestic food establishments and importers; and
- how the CFIA would conduct activities like market surveillance and border blitzes.
Figure 3 illustrates the factors and criteria CFIA considers using to conduct a food commodity risk analysis and the assessment of regulated parties to determine the frequency, intensity and type of its oversight activities.
From a risk analysis perspective, the CFIA would group food commodities and preparation processes with similar levels of risk and determine a level of oversight to each grouping. For example, regulated parties who prepare ready-to-eat foods for interprovincial or export trade, or who import them (for example, cheese and chopped salads) that support the growth of pathogens like salmonella (biological hazards) may be subject to a different level of oversight than regulated parties who prepare or import ready-to-eat foods that are shelf-stable (for example, honey products and bakery products) and do not support the growth of pathogens.
A number of criteria pertaining to individual regulated parties are then considered jointly with the food commodity risk to determine the level of oversight activities applied to that regulated party. These criteria include, for example, volume of production, consumer target groups, preventive control plans, and the track record of the regulated party as it respects compliance with food safety and other regulatory requirements. Any inspection activities required to support export market access would also have to be considered in the determination of the level of oversight. Using the enhanced approach, if a trend in non-compliance were observed at a specific regulated party's operation, the CFIA could:
- enhance its oversight activities by adjusting the frequency, intensity or type of inspection activities, the use of enhanced directed sampling and testing when there is a recurring microbiological issue; and/or
- apply other compliance and enforcement tools to support continued compliance.
Following the principles outlined on risk based oversight in this section, the frequency, intensity or type of CFIA oversight activities may also be adjusted where:
- a regulated party implements and maintains a preventive control plan that exceeds minimum requirements; and
- the effectiveness of the plan, in preventing and mitigating risks and achieving regulatory compliance, is demonstrated through the regulated party's compliance history.
Other food inspection systems around the world, such as those implemented in the United States, Australia, and New Zealand are also adopting risk-based approaches that compare risk across food commodities. Food science knowledge and tools available for analysing the risks associated with food are constantly evolving. Canada is committed to using the most modern tools and systems available for risk management and delivery of its inspection activities.
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