What We Heard Report

Industry Outreach Sessions

January 31 – February 1, 2012

PDF (932 kb)

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Introduction

The Government of Canada's 2011 Budget committed $100 million over five years to the Canadian Food Inspection Agency (CFIA) to modernize its food inspection system. Building on a strong food safety foundation, funding is being directed to

• develop an improved food inspection model for all food commodities,
• implement Health Canada's Listeria policy,
• develop an electronic delivery interface to improve industry's access to agency services and programs, and
• deliver better training, technology and tools for CFIA inspectors.

Under the improved food inspection model, the CFIA would move from delivering eight separate, independently-evolved food inspection programs to a single approach. This new approach would be based on a common suite of inspection activities and on science and risk. It would be supported by standard processes and tools.

Industry outreach sessions and participants

Two industry outreach sessions were held to

• initiate discussion with industry representatives about current challenges with regulatory requirements and food safety inspection;
• gain insight about participants' inspection concerns; and
• seek recommendations or ideas for best practices.

There were 86 participants, distributed across the two days as follows:

January 31, 2012

• 58 representatives from food associations

February 1, 2012

• 28 representatives from animal and plant health associations

These external stakeholders were identified through the national associations listed on Agriculture and Agri-Food Canada's Agri-Food Trade Service list of Canadian Industry Associations. An expression of interest was further distributed through stakeholder networks.

See Annex 1 for the demographics of the associations represented at the two sessions.

Gauging understanding and confidence

Baseline questions were asked at the beginning and end of each day using clicker technology¹. The baseline questions were designed to gauge participants' understanding of

• the inspection modernization project,
• the process by which a new inspection model will be developed, and
• how they will be able to participate in the development and implementation of the new model.

The CFIA also gauged participants' confidence that their input would be considered.

Participants were asked about their level of understanding of and their confidence in the inspection modernization project at the start and at the end of the sessions; both increased over the course of the day.

Themed presentations and discussions

The sessions were divided into the following three themes:

1. Understanding the status quo
2. The case for change
3. Perspectives on the future

Each of the themes was introduced with a short presentation, which was followed by a series of questions designed to stimulate dialogue.

Participants were seated in small groups, at numbered tables, to facilitate discussion. Each table assigned a scribe, who took notes on a flip chart. After the small group discussions, one table—the lead—presented their flip chart to the entire group. The remaining tables were asked to contribute to the discussion with ideas or information that either the lead table had not covered or that were inconsistent with the information presented.

The following is a summary report of the data collected during the two sessions and reflects only the opinions and ideas of the sessions' participants. Responses are divided by questions. Any sector-specific responses have been indicated.

Theme 1: Understanding the status quo

1. Value of CFIA inspection activities: From the perspective of your industry/sector, what current CFIA inspection activities contribute to food safety, animal health, plant health, market access and consumer protection?

Most participants felt that the following activities were most critical:

• Licensing/registration, for creating a level playing field for industry.
• Licensing of importers, for identification purposes. Some participants also noted that it is important to them that imported products be required to meet the same standards as domestic products.
• Facility inspection, which allows inspectors to identify emerging trends using methods like environmental sampling.
• Export certification.

Many participants felt that a Hazard Analysis and Critical Control Points (HACCP)-based approach is critical for food safety.

Other inspection activities that were flagged as important included: import inspection and clearance, a recall system, product and environmental sampling, and emergency response functions for food safety or animal health.

A discussion arose during the plenary session about environmental swabbing, which some participants felt is an important, proactive way to identify environmental issues and issues with incoming materials. They noted that environmental swabbing is more effective than end-product inspection, which is viewed as a more reactive approach.

2. Value of CFIA inspection activities: From the perspective of your industry/sector, what current CFIA Inspection activities DO NOT contribute to food safety, animal health, plant health, market access and consumer protection?

Some participants said that all CFIA inspection activities add value but that they vary in their effectiveness. Most comments were related to the efficiency and effectiveness of inspection activities.

• Multi-commodity facilities are burdened by multi-licensing and multi-inspection.
• The administrative burden of some food safety programs do not contribute to food safety.
• Some inspection activities are not based on risk/science.
• Inspection standards are applied inconsistently.

Participants also indicated that some inspectors lack knowledge, solutions and advice for industry.

The participants also made some suggestions.

• Reduce administrative redundancies and create a level playing field for all sectors.
• Allocate CFIA resources to higher risk and non-compliant operators.

3. Industry readiness: Has your industry sector established voluntary food safety standards, codes or practice, programs, or specifications for the products they distribute, sell or market? If so, please provide examples and an overview.

The participants provided several examples of food safety standards, codes of practice, programs or specifications that they currently use. Some of these are internationally established or accepted, some are industry sector specific, and others are CFIA programs.

• International Organization for Standardization (ISO) 22000:2005, "Food Safety Management Systems – Requirements for any Organization in the Food Chain"
• The Foundation for Food Safety Certification's Food Safety System Certification (FSSC) 22000:2010
• The Safe Quality Food Institute's Safety Quality Food (SQF) 2000 Code
• The HACCP Program
• CanadaGAP (Good Agricultural Practices) for the fresh fruits and vegetables sector, which is HACCP-based and recognized by the Global Food Safety Initiative (GFSI)
• Animal welfare codes/transportation codes for farm animals
• Clean Plants (domestic phytosanitary certification program)
• The Food Safety Enhancement Program (CFIA)
• The Canadian Greenhouse Certification Program (CFIA)

4. Quality assurance: Please provide examples of how members of your industry sector manage regulatory compliance.

Approaches for managing regulatory compliance included

• using a systems-based approach, such as HACCP plans and programs, quality management and assurance programs,
• using third parties to manage regulatory compliance,
• using internal audits, and
• relying on communication or interaction with the CFIA.

One concern raised during the plenary session discussion was that small companies may not have the resources to handle regulatory compliance issues.

5. Quality assurance: Under what circumstances, if at all, would your members use private inspection/audit services?

Private inspection/audit services have been used to

• achieve international certification by organizations such as the GFSI,
• implement HACCP programs and quality assurance programs for small companies, and
• meet association, customer or third-party requirements if these requirements exceed those of the CFIA.

A suggestion was that the CFIA should stop taking on the responsibility for quality assurance design, development, and implementation. It should instead focus on monitoring and should provide support and feedback to industry as it develops and implements quality assurance protocols.

Theme 2: The case for change

1. Environmental scan: Based on the current environment (consumers, economy, media, etc.) what do you think are the pressures for

a) increased inspection of food, animals and plants (including products and agricultural inputs)?

The participants identified many ongoing pressures to increase inspection, such as

• increased public expectations resulting from increased media coverage of foodborne illness outbreaks,
• foreign market demand, and
• increases in international trade.

b) decreased inspection of food, animals and plants (including products and agricultural inputs)?

The participants suggested a number of situations/pressures to decrease inspection, such as

• when an industry's control programs are in good standing, or
• when there is duplication of inspection for multi-commodity operations or with other countries.

Participants also recommended that inspection efforts focus on the system, as opposed to the product, and be based on risk. They felt that more emphasis should be placed on non-compliant companies and less on high-achieving companies.

2. Environmental scan: Do you think the CFIA's current level of inspection activities is

a) Too much?
Some participants felt that the CFIA's inspection activities are too focused in low-risk sectors or non-food safety areas. Some participants felt that the CFIA's level of inspection is too focused in the meat sector, including abattoirs.

b) Appropriate?
The participants felt that the CFIA's level of inspection is appropriate for animal welfare, meat importers and certain Compliance Verification System (CVS) elements.

c) Too little?
Some participants indicated that they felt that the CFIA's level of inspection is too little for imported products and inputs, ready-to-eat non-meat operations and products at the production/process level.

The participants made some suggestions about the level of CFIA inspection activities.

• The CFIA should improve efficiency of inspection activities and focus on areas of higher risk.
• The CFIA should provide more training and improve communication between inspectors from different sectors, to ensure consistency.

Where is the priority need for change and why?

There were a couple of suggested priorities for change.

• The CFIA should analyze the risk for each sector and move from a reactive approach to a risk-based approach.
• The CFIA should increase investigation and enforcement to deter non-compliance.

3. Foreign requirements: How, if at all, do any foreign country's requirements impact your sector's business or practices?

• Export is difficult and costly because foreign thresholds or tolerances for products are not standardized and foreign requirements are varied.
• Some foreign requirements are not supported by science, resulting in trade barriers.
• Multiple layers of foreign country audits and inspections are onerous for industry.

One group commented that it might be easier to both import and export products if Canada adopted international standards.

4. Non-food safety: With regard to non-food safety requirements in areas other than pest and disease control (such as labelling, net quantity, grades and quality, composition and packaging), what, if any, would be the advantages/disadvantages of government oversight?

The participants felt that the main advantages of government oversight of non-food safety requirements are that it

• provides uniformity and, therefore, a level playing field,
• contributes to consumer protection and consumer confidence, and
• decreases economic fraud.

The participants felt that the main disadvantages of government oversight of non-food safety requirements are that it

• is inflexible and stifles industry innovation,
• is costly, and
• needs to be prioritized based on risk.

5. Non-food safety: How else, other than CFIA oversight, can/could regulatory compliance with technical standards be ensured?

The participants provided alternatives to CFIA oversight that might allow industry to achieve regulatory compliance with technical standards, including

• more industry responsibility,
• greater third-party and industry/trade association oversight, and
• additional penalties and effective enforcement for economic fraud.

Some participants suggested that government should perform oversight if non-food safety requirements are included in legislation and regulations. Non-food safety technical standards were seen as a problem for industry. One suggestion was to apply an administrative monetary penalty for non-food safety violations. Another suggestion was that the CFIA should focus on effective enforcement methods that use fewer CFIA resources.

Theme 3: Perspectives on the future

1. Roles and accountability: In a modernized inspection system, what should be the roles of industry, the CFIA, and others in ensuring food safety, consumer protection, animal health and plant health?

The role of industry

• conduct applied research and innovation
• work with the CFIA to develop standards and programs
• adopt and implement regulations and best practices
• ensure compliance with regulations and market demands for domestic and exported products
• carry out staff training, monitoring, surveillance, assessments and performance evaluation
• perform risk assessments
• share knowledge and information

The role of the CFIA

• conduct fundamental research and scientific validation
• develop regulations and inspection framework
• establish appropriate outcomes for industry
• perform regulatory oversight of industry's self-monitoring processes
• consolidate surveillance data
• be accountable to industry and public within the CFIA's mandate
• cooperate and work with industry and auditors
• communicate to consumers and industry
• make policies and materials transparent
• collaborate with provincial counterparts
• negotiate with other countries and exploit existing international processes

The participants also highlighted the need for an appeal process.

The role of others

• Consumer groups: communicate about the food safety system
• Markets: set the standards
• Third-party auditors: work with the CFIA to ensure compliance
• Educators: educate people about food safety and animal and plant health
• Trade associations: consult with members
• Academic: conduct scientific validation

2. Future model: A future model for inspection could be outcome-based or prescriptive.

a) What does outcome-based mean to you?
The participants defined an outcome-based model as one that is verifiable and that establishes the end goals rather than the steps for achieving those goals.

b) What does prescriptive mean to you? What types of requirements should be prescribed? Why? For whom?

The participants defined a prescriptive model as one that establishes exactly what to do and how to do it. A prescriptive model is detailed and less flexible than an outcome-based model.

Types of requirements that should be prescribed

• HACCP
• sanitation
• labelling
• recall (reporting and escalation)
• registration requirements
• licensing requirements
• traceability requirements
• requirements for keeping records

3. Risk-based: From the perspective of your industry/sector, provide a working definition, rationale, and at least one example of an activity that you would consider to be risk-based:

The participants defined a risk-based approach as one that is determined based on the potential to cause foodborne illnesses.

1. Low risk
   From a food perspective
   • Food that is always cooked before it is eaten
   From an animal and plant health and agricultural input perspective
   • Pests/diseases that do not pose an immediate risk but that can damage the reputation of the CFIA or of a company
   • Feed products for animals, not destined for human consumption
2. Medium risk
   From a food perspective
   • Food that does not need to be cooked before it is consumed
   • Food with documented lower risk and safe use
   From an animal and plant health and agricultural input perspective
   • Pests/diseases that cause (economic) loss, but for which there are known solutions/controls to manage the risk.
3. High risk
   From a food perspective
   • Read-to-eat food intended for a vulnerable, high-risk population
   • Ready-to-eat food that does not require cooking before consumption
   From an animal and plant health and agricultural input perspective
   • Pests/diseases that are hard to detect, spread rapidly, and cause high economic loss
   • Feed products with medical ingredients

4. Risk-based

a) Food: Please define the basic operational procedures and controls that every food business should have in place to ensure food safety and regulatory compliance.

In general, the food association participants felt that the CFIA should adopt a HACCP or GFSI approach to food safety. They also provided the following basic operational procedures and controls that are necessary to ensure food safety and regulatory compliance:

Food safety

• sanitation and pest control
• preventative maintenance of equipment
• training
• recall and traceability
• monitoring and audit procedures
• corrective actions
• allergen program
• annual system re-evaluation to ensure ongoing compliance
• documentation
• records and records control
• clearly-assigned individual responsibilities
• support from upper management

Regulatory compliance (non-food safety)

• quality control
• internal and external audits
• labelling (general)
• grading

b) Animal and plant health and agricultural inputs: Please define the basic operational procedures and controls that every business should have in place to ensure regulatory compliance with respect to animal and plant health requirements.

The animal and plant health and agricultural input participants felt the following procedures and controls are essential for ensuring regulatory compliance:

• quality and control programs, such as HACCP, CanadaGAP, and Clean Plants, including standards and procedures that cover all aspect of operations
• biosecurity
• traceability
• auditing process and procedures
• labelling

5. International Alignment: How, if at all, are the controls or inspection approaches required for importing food products or agricultural inputs, animals, and plants and their products different from those that are prepared, processed or produced domestically? Please provide an example.

Some participants felt that, to maintain high levels of food safety, there should be more consistency and balance in inspection approaches and processes across both foreign and domestic markets.

6. Information requirements: food continuum. If the CFIA required the ability to identify all regulated parties.

1. How might this be achieved?
   The CFIA could identify regulated parties through
   • the creation of a common, single database of all federally and provincially regulated operators, including importers
   • traceability, such as records and identification tags
2. Are there any mechanisms in place that could assist the CFIA in identifying and locating those who are subject to the legislation?
   The CFIA could identify potential regulated parties through
   • licensing and registration
   • co-operation with industry associations to identify members and partners who may be subject to the legislation
   • traceability programs

Next steps

The information gathered during the two industry outreach sessions has been shared with the CFIA's working group that is developing a draft improved food inspection model. The feedback has been reviewed, analysed and will be included, when possible, in the draft model.

External consultation opportunities

External consultation on the draft model will begin in the summer of 2012. The CFIA maintains a list of those interested in participating in future inspection modernization initiatives. If you would like to participate or if you would like to recommend an industry or association that should get involved in future outreach activities, please send an email with your contact information.

Annex 1

Demographics of the food association participants on January 31, 2012 (58 participants).

Description - Demographics in the room (food association)

Demographics of the animal and plant health association participants on February 1, 2012 (28 participants).

Description - Demographics in the room (animal and plant health)

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¹ Clicker technology involves using hand-held electronic devices to anonymously capture the participants' responses to multiple-choice questions.