Improved Food Inspection Model
Revised Draft

3.0 Risk-based inspection oversight

Introduction

The CFIA, like all other similar regulatory agencies in the world, uses scientific knowledge and risk analysis to inform its 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, among other things, considers the:

  • biological, chemical and physical hazards that are reasonably likely to occur in relation to a food commodity – Hazard Identification;
  • 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) - Hazard Characterization;
  • volume of production and target consumer groups – Exposure Assessment; and;
  • potential for illness to occur and impact consumers, if hazards are not adequately and properly controlled, reduced or prevented – Risk Characterization.

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 licence holders 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 inspection oversight.

Currently, the eight different food commodity programs are using somewhat different risk management approaches. The current risk management approaches are not accessible and are not structured similarly.

In some cases, inspection activities and oversight are also affected by international requirements. Based on foreign country requirements, some licence holders 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. Canada also applies specific requirements to imported food commodities to establish compliance with our standards. For example, 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 to be considered to meet Canada’s import requirements. Canada ’s regulatory requirements for food specify a consistent expectation for safety of all food commodities.

The CFIA takes the information related to the 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, for example, have daily inspector presence; while establishments preparing lower risk commodities, such as dry pasta and honey products, are inspected only on a periodic basis.

What is being proposed?

To improve inspection oversight, on a risk basis, the CFIA is proposing to:

  1. take a more structured approach to analysing risks related to different food commodities by:
    1. 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;
    2. making the risk information more accessible and transparent; and
    3. applying this approach across all food commodities.
  2. add a common systematic approach to assessing the track record of licence holders (including associated surveillance and recall data and the licence holder’s compliance history) to determine if inspection activities need to be strengthened , enhanced and/or improved. For example, once a licence holder has established a compliance history, the intensity of inspection and/or methods of inspection may be adjusted to correspond with the licence holder’s effectiveness in preparing safe and compliant food.

The CFIA would rank food-hazard combinations from high to low in likelihood to pose a public health or trade impact. This ranking approach would allow the CFIA to apply a base level of inspection by food sector.

On a predetermined basis, the CFIA would review the food commodity risks and licence holder track record history to confirm and/or update its information inventory. Based on the information, the CFIA would direct its inspection activities and resources in a manner that would reflect the consequences that non-compliance could have in relation to the potential for an adverse impact on public health. Of course, 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 initiate an inspection. These include:

  • response to food safety complaints or illness investigations
  • results of concern from an inspection process or sampling
  • information about a potential issue received from
    • a third party
    • another government department
    • an international trading partner
  • a request for inspection by a licence holder (for example, for export marketing purposes)

How would all of this work?

This systematic and structured risk-based approach would help the CFIA enhance its determination:

  • of whether an inspection is required prior to licensing
  • at what intensity the CFIA would inspect domestic food establishments and importers, and
  • of how the CFIA would conduct activities like market surveillance and border blitzes.

Graphic 1 is provided to illustrate how the CFIA would apply the proposed structured approach to conducting a food commodity risk analysis that would lead to the determination of a base level of inspection.

Graphic 1: Factors in determining a base level of inspection

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Graphic 1: Factors in determining a base level of inspection

Description for graph: Factors in determining a base level of inspection

Graphic 1 illustrates how the CFIA would apply the proposed structured approach to analyzing food commodities by risk, leading to determining a base level of inspection.

The graph flows from top to bottom starting with

  • the types of science-based information, with an arrow pointing to
  • the determination of the food commodity risk, with an arrow pointing to
  • the conceptual base level of inspection based on risk of the food commodity grouping

The types of science-based information would be

  • environmental scan information, monitoring and surveillance data,
  • risk assessments, Codex Alimentarius standards,
  • biological, chemical and physical hazards reasonably likely to occur in food commodities, and
  • knowledge of how the process used to prepare food contributes to or reduces or eliminates risks.

The determination of the food commodity risk would include

  • the food commodity type (for example, ready-to-eat, not ready-to-eat), and
  • the potential for acute illness to occur if hazards not controlled.

A base level of inspection would be applied to all food business operations based on the determination of the food commodity risk. Therefore the base level of inspection would be based primarily on the risks associated with the food hazard-process combination. From a risk management perspective, the CFIA would group food commodities and preparation processes with similar levels of risk and apply a base level of inspection to each grouping. For example, licence holders who prepare or import ready-to-eat foods (for example, cheese and chopped salads) that support the growth of pathogens like salmonella (biological hazards) may be subject to a different base level of inspection than licence holders 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.

From the base level of inspection, inspection activities would be adjusted depending on the track record of the licence holder as it respects compliance with food safety and other regulatory requirements. Using the enhanced approach, if a trend in non-compliance was observed at a specific licence holder’s operation, the CFIA could:

  • enhance its inspection oversight by adjusting the frequency, intensity or type of inspection activity (for example, 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.

Any inspection activities required to support export market access would be performed as part of the base level of inspection, as applicable. Graphic 2 is provided as an example to illustrate how a specific licence holder’s track record may impact the base level of inspection.

Graphic 2: Consideration of track record

Click on image for larger view
Graphic 2: Consideration of track record

Description for graph: Consideration of track record

Graphic 2 is an illustration of how international obligations and a specific licence holder’s track record may impact the base level of inspection

The graph flows from top to bottom starting with

  • the conceptual base level of inspection based on risk of the food commodity grouping, with an arrow pointing to
  • the question: “does the compliance history or track record of the licence holder impact on the base level?”, with an arrow pointing to either a yes or no answer
  • if “ yes”, the  arrow points to the answer the “CFIA enhances inspection activities and/or takes compliance and enforcement action”
  • if “no”, the arrow points to the answer “ maintain base level of inspection”

* For export food commodities, the base level of inspection would take into account any specific foreign country requirements.

Food science knowledge and tools available for analysing the risks associated with food are in constant evolution. Canada is committed to using the most modern tools and systems as it respects risk management and delivery of its inspection activities.

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