ARCHIVED - Record of Discussion (RoD) – April 24 & 25, 2014

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On April 24 and 25, 2014, members of consumer and health associations joined officials from the Canadian Food Inspection Agency (CFIA) for the seventh meeting of the Consumer Association Roundtable (CAR).

The objective of the meeting was to solicit feedback from CAR members on the CFIA draft policy documents that were further discussed and consulted on at the CFIA Healthy and Safe Food Regulatory Forum, that took place June 17 and 18. The policy documents focussed on the following initiatives:

  • Programs and Regulatory Modernization
  • The Inspectorate of the Future (Inspection Activities) - What to expect in a modernized environment
  • Risk and Food Safety
  • Health Canada's Regulatory Modernization under the Food and Drugs Act
  • Food Labelling Modernization
  • Partnerships for Training and Compliance Promotion
  • Imported Food Sector Product Regulations and Single Window

Neil Bouwer, Senior Vice President, Agency Transformation chaired the roundtable meeting and welcomed CAR members. He opened the meeting by providing an update on the number of initiatives that will transform the way the Agency does business. The CFIA's transformation agenda is focussed on the four inter-connected pillars of the Safe Food for Canadians Action Plan. They are:

  • stronger safety rules;
  • more effective inspection;
  • commitment to service; and,
  • more information for consumers.

He encouraged roundtable members to be open and frank with their questions and comments. Roundtable members were also invited to attend the CFIA Healthy and Safe Food Regulatory Forum, where the actual consultation process will begin.

Paul Mayers, Vice-President, Policy and Programs provided an overview and an update on the proposed Safe Food for Canadians regulations. This approach to program and regulatory modernization encompasses the work of CFIA partners at federal and provincial levels, as well as industry and consumer stakeholders. The Safe Food for Canadians Act provides for new authorities, as well as consolidates existing authorities across the food spectrum. For it to come into force, the regulatory framework has to be updated to reflect the authorities. This proposed framework is intended to be more outcome-based and risk based. It takes a horizontal approach rather than a commodity approach to managing similar risks.

Comments from CAR members included:

  • Members said they would like stronger representation of consumer interests when setting food safety standards, including private standards. Members requested that the CFIA's incorporation of private certification processes be transparent.
  • Members noted that consumer interests can go beyond safety standards. Some consumers, for example, will expect labels to include detailed information about ingredients in order to make their own choices, regardless of Health Canada's determination of risk. Consumers wish to be empowered, not just protected.
  • Some members saw food safety regulatory and labelling modernization as an opportunity to engage more broadly, and supported the CFIA's suggestion that a dialogue be held between consumer groups, the Global Food Safety Initiative, Canadian Standards Council, and others, such as the Competition Bureau.
  • Members noted that industry will require support with compliance and preventive control plans, particularly small businesses that may not have the food safety knowledge of larger businesses. To this end, members welcomed the Agency's plans to develop compliance promotion tools, including interpretive guidance and model systems provided in simple language.
  • Members noted that the intersection of authorities between the federal government and other governments (provincial, territorial and national) can be confusing, and it will be important to clearly articulate the division of authorities and responsibilities in the CFIA's Food Program Framework.
  • It was suggested by some members that the CFIA's Risk-Based Oversight Model include consumer-related information (e.g. consumer complaints) as well as provide consumers with appropriate information about food safety risks. Consumers are expecting greater detail in publicly available information. Members welcomed the opportunity to continue the discussion as consultations unfold in the coming months.

Tom Hauschild, Director, Food Safety Assessment and Recall Operations, presented an overview of the inspectorate of the future and what to expect in a modernized environment. He highlighted the fact that as the CFIA transforms and modernizes, it is working to ensure that its inspection activities are risk-based, appropriate, consistent, and support the implementation of a new inspection model. The key functions of the new model include:

  • centralized inspector training and an overall knowledgeable work force;
  • modern technology and tools to support mobility and connectivity;
  • clear, timely and readily accessible operational guidance;
  • an improved and efficient organizational structure; and,
  • centralized administrative and service functions for improved service delivery.

Inspection activities in the filed for the inspectorate of the future was also discussed. This covered import and export inspections, surveillance activities and compliance verifications.

Comments from CAR members included:

  • Members highlighted the need to be both proactive and reactive in terms of licensing.
  • Members commented on how the training of inspectors should be consistent and robust.
  • Members stressed the importance of truthful and transparent packaging and how it should part of the consumer protection continuum.

Martine Dubuc, Vice President, Science and Chief Food Safety Officer, provided an overview of the application of risk analysis in determining the CFIA's regulatory oversight activities. The objective is to make risk analysis (assessment, management and communication) more systematic. The Integrated Agency Inspection Model will strengthen transparency and predictability through a more systematic and transparent risk-based approach for CFIA oversight activities. The frequency, level and type of oversight will be more closely aligned with risk. Oversight activities include, inspections, audits, surveillance, product sampling and testing. These activities take place in a variety of areas along the production chain. For example, before, during and after the product is at market; before and at place of import; and prior to export.

A Risk Assessment (RA) model is under development as a standardized and consistent tool to help inform oversight decisions for food establishments. The RA model will take into account a series of risk factors associated with process/product, the regulated party's controls, and compliance history.

Comments from CAR members included:

  • Members were interested in how the CFIA validated the new model.
  • Members felt that the CFIA should mention that the evaluation will take time.
  • Members stressed the importance of including packaging, labelling and accuracy of contents as a factor in the risk assessment model.
  • Members commented on how the definition of risk has to be all encompassing.
  • Members commented on the need to create a climate of trust by:
    • creating a community of people who are connected;
    • attracting individuals who react to incidents when they happen; and,
    • working with individuals who are more proactive in spreading the word on what they know is true.

Anatole Papadopoulos, Director, Policy Intergovernmental and International Affairs, Health Canada explained Health Canada's role in food safety. The mandate of Health Canada is to help Canadians maintain and improve their health. In this regard, Health Canada is the federal standard-setting body that:

  • establishes policies, regulations, standards and guidelines related to the safety and nutritional quality of all foods sold in Canada;
  • conducts scientific assessments of risk, benefit, and efficacy in support of standard-setting and food safety investigations; and,
  • provides information and advice to the public, industry, health and consumer organizations, and other government organizations.

Comments from CAR members included:

  • Members felt that Health Canada should give practical examples of the type of innovation that Health Canada is working toward.
  • Members outlined the importance of establishing reliable information around the "may contain" statement on a label.
  • Members commented on the importance of understanding and agreeing on the definition of risk.

Daniel Miller, Executive Director, Food Labelling, Claims Directorate provided an update the on the food labelling modernization initiatives, including what has been heard through engagement to date, and how the CFIA and Health Canada are aligning their labelling and modernization activities. Health Canada and the CFIA continue to coordinate their modernization efforts. He explained that food labelling is a shared responsibility between the CFIA and Health Canada and that CFIA's Food Labelling Modernization (FLM) and Health Canada's Nutrition Labelling initiatives are part of efforts to modernize food labelling, and are directly linked to and support Government of Canada commitments, including:

  • improved safety oversight;
  • stronger food safety and nutrition rules and programs;
  • informed choice for consumers;
  • more effective inspection;
  • renewed commitment to service;
  • better international market opportunities; and,
  • increased regulatory cooperation alignment.

He also explained that labelling efforts are also linked to other federal initiatives including:

  • regulatory modernization;
  • food standards modernization;
  • importer licensing;
  • compliance promotion;
  • online labelling tool;
  • Centres of Expertise;
  • Integrated Agency Inspection Model; and,
  • Health Canada's consultations with Canadian parents on nutrition labelling.

Daniel also indicated that CFIA would be engaging with a broad range of stakeholders on options for modernizing the food labelling system.

Cara Prest, Director, Food Safety Communications, provided a demonstration of the CFIA on-line labelling tool. As part of the Government of Canada's Budget 2012 announcement, the CFIA committed to developing and implementing an online labelling tool for industry. The objective of this tool is to help producers, manufacturers and retailers create compliant labels.

The CFIA is also committed to providing consumers with clear, user-friendly information on food labelling.

To meet these two distinct purposes, the CFIA has developed two online tools:

  • A labelling tool for industry, consolidating the current 1,500 pages of labelling content on the CFIA website. The tool will provide industry with the ability to use a checklist to determine if their products meet the core labelling requirements.
  • An interactive labelling tool for consumers that explains food labels. This tool will be part of a new consumer section on the CFIA website that will highlight new and previously developed consumer content on labelling.

Comments from CAR members included:

  • Members were pleased to see that the tool was interactive and user-friendly.
  • Members also noted that the tool made it easy for consumers to find relevant information.
  • There was discussion around how to promote the tool, i.e. suggestion that major retailers might be open to promoting the tool in their flyers.
  • CAR members promised to continue to share creative ideas with the CFIA on how to ensure that consumers were made aware of this useful tool.

Dr. Mary Brodhead, Executive Director, Human Resources, described how the current environment with global supply chains, exponential increases in food-related technology and high consumer expectations for food safety has created a need for a system-based approach to learning through collaboration with all food safety stakeholders.

The CFIA is reframing how it does its internal training and compliance promotion. In addition, it is partnering with industry, provinces and territories, and academia to explore the idea of adopting a version of the US Global Food Protection Institute's learning arm, the International Food Protection Training Institute (IFPTI). The proposed entity Safe Food Canada: the Learning Partnership would be established to develop and implement:

  • national food safety competency-based curriculum framework;
  • training for personnel at the international, federal, provincial, territorial and municipal levels; and,
  • certification scheme implemented by a private entity to help ensure comparable and competent food safety staff in industry and government.

The key components of this system would be:

  1. Not-for-profit entity to determine core competencies, as well as the required knowledge and skills for specific career tracks. This Advisory Board and Board of Directors would include representatives from industry, academia, and government (federal, provincial, territorial and municipal bodies).
  2. Personnel certification in food safety and protection based on international competency standards and requirements for industry and government delivered by a separate entity.
  3. Standards of quality for training could be set by the non-profit entity in partnership with the US and international standard setting bodies (ISO, SCC, etc.). Various entities could be recognized to develop and deliver training (i.e. agencies, associations, institutes, academia, and training companies), provided that they follow the prescribed content and standards.

Where industry and regulators' competencies overlap, training could be offered by various providers and taken by everyone in the food safety sphere.

A set of Canadian requirements could be developed for the qualifications and competencies of food safety auditors and other personnel involved in the audit and certification of food safety management/assurance systems.

Compliance promotion activities could raise awareness of regulatory requirements and help medium-sized enterprises understand how to apply requirements, such as preventive controls, to their own businesses.

Comments from CAR members included:

  • Members recognized how important it is to develop a community of food safety experts and the role they would play in consumer protection.
  • Members were supportive of the concept of universities and colleges offering training to individuals who would eventually become professional experts in food safety.
  • Members questioned the composition of the leadership team and highlighted the point that nutrition experts need to play a significant role. Experts in allergies and nutrition need to be in on the planning very early and on the development of the curriculum.
  • Members were supportive of the direction the CFIA is taking in terms of training and compliance promotion, and interested in playing an active part in this transition.
  • Ken Whitehurst of the Consumers Council of Canada offered to be the representative for the group and the point of contact for CFIA.

Colleen Barnes, Executive Director, Domestic Food Safety Systems and Karen McIntyre, Executive Director, Operations Strategy and Delivery, discussed the strengthened oversight of imports through the proposed imported food sector products regulations and the single window initiative.

The proposed Imported Food Sector Product Regulations have been published for public comment in Canada Gazette, Part I. These regulations are being proposed under the Canada Agricultural Products Act (CAPA) to introduce licensing and improved food safety requirements for importers in the Imported Food Sector (IFS).

These proposed regulations are the first stage of the food regulatory modernization initiative under the CFIA's Safe Food for Canadians Action Plan. The proposed regulations will introduce importers of certain foods to licensing and food safety requirements.

IFS products are sourced from over 190 countries and include the US, countries in the European Union, India and China. The regulations apply to any importer of IFS products. This can include retailers, brokers, distributors and food manufacturers or processors who use imported ingredients. Only one person involved in the import of the IFS product needs to have a licence.

Importers of IFS products would be required to:

  • meet the General and Mixture prohibitions;
  • hold a licence to import;
  • prepare, keep and maintain a written recall procedure and implement it if a recall is necessary;
  • maintain records, including product safety, traceability, complaint and recall records.

The Single Window Initiative (SWI) is a single window through which industry can electronically submit information pre-arrival to comply with Government of Canada import requirements.

Comments from CAR members included:

  • Members asked if the CFIA expected to see an increase in recalls.
  • Members offered support in getting the message out to importers and reinforcing the benefits of this licensing regime.
  • Members raised questions about whether the CFIA has enough front-line staff.
  • Members pointed out that farmers are not always factored in when changes are made to regulations. It was felt that they often pay the price of the manufacturing cost.
  • Members commented on how reliable labelling and content analysis were important elements of food safety and that the inspectorate needs to make that a key component of their surveillance work.
  • Members asked for more information on the role of the CFIA now that it is aligned with Health Canada.
  • Members had questions around how the CFIA measures results in terms of consumer protection.
  • Members were very supportive of the direction that the CFIA was going in terms of training.
  • Members appreciated the direction of the CFIA in terms of consumer protection. They recognized that a lot of work is being done and that it is very positive.

Going Forward

  • The next CAR meeting will take place Fall 2014.
  • CAR members would like to invite the Minister of Health to the next meeting.
  • CAR members were formally invited to the CFIA Healthy and Safe Food Regulatory Forum, June 17 and 18.
  • The CFIA will have a conversation with Health Canada on co-chairing opportunities at CAR meetings.
  • There was a discussion on user fees as a potential topic for the next CAR meeting.
  • There was interest in a planning a telephone call or a meeting with the Global Food Safety Initiative (GSFI) to discuss the CFIA approach to private standards.
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