Archived - XL Foods Inc. Independent Review Recommendations and Government Action Plan

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• To strengthen prevention strategies and regulatory oversight
• To strengthen surveillance and trend analysis oversight
• To strengthen incident management and recall response oversight
• To strengthen communication with the public and stakeholders about providing food safety messages oversight

To strengthen prevention strategies and regulatory oversight

1. A strong food safety culture must be developed within the processing plant, and adopted by both plant and Canadian Food Inspection Agency (CFIA, or Agency) staff - at all levels.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• October 2012 – The CFIA strengthens supervision at XL Foods Inc. by increasing management capacity in the plant.
• October 2012 – The CFIA includes expected culture of Operations in the mandatory core training that all new inspector recruits attend in their first year.
• December 2012 – CFIA's Vice President (VP) Operations sends a memo to all inspection staff to reinforce the Agency's commitment to a strong food safety culture and to ensure that employees understand the key role they play in protecting the health and safety of Canadians.
• April 2013 – The CFIA adds expected behaviours of inspection supervisors and managers to the 2013-14 performance review process.
• September 2013 – The CFIA launches a Supervisor School, which will be delivered six times this fiscal year on a pilot basis, to strengthen food safety culture through strong and effective supervision.

2. There must be greater emphasis on training and continuing education of CFIA inspection staff.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• October 2012 – The CFIA launches the new core training that all new inspector recruits must attend in their first year.
• May 2013 – The CFIA launches new training materials for meat inspectors so that they can effectively implement the revised policy on E. coli controls.
• September 2013 – The CFIA launches a Supervisor School, which will be delivered six times this fiscal year on a pilot basis, to strengthen food safety culture through strong and effective supervision.

3. Inspectors should devote proportionately less time to evaluating specimens for pathology and more time training on protocols that have maximum impact on food safety.

Implicated department(s): Canadian Food Inspection Agency

Status: On Track

Action Taken

• September 2013 – The CFIA approves Slaughter Modernization Initiative. When implemented, changes to inspection procedures will free up time for inspectors to further focus on food safety protocols.

Action To Be Taken

• 2014 – The CFIA explores implementation and acceptability of Slaughter Modernization Initiative with trading partners.
• 2014 – The CFIA conducts further risk assessment and scientific evaluation to determine appropriate reduction in time allocation for specimen evaluations.

4. The Minister of Health should assess the effectiveness of the Agency's activities related to its meat program.

Implicated department(s): Health Canada; Canadian Food Inspection Agency

Status: On Track

Actions To Be Taken

• June 2013 – The CFIA prioritizes its evaluation of CFIA meat programs, bringing it forward to fiscal year 2014-15. Planning of the evaluation is currently underway.
• Note: On October, 9, 2013, responsibility for food safety was consolidated under the Minister of Health and CFIA was moved to the health portfolio. Oversight for the effectiveness of all CFIA food safety activities, including the meat program, now falls under the authority of the Minister of Health.

5. The CFIA must enforce its oversight responsibilities at the plant.

Implicated department(s): Canadian Food Inspection Agency

Status: On Track

Action Taken

• October 2012 – The CFIA strengthens supervision at XL Foods Inc. by increasing management capacity in the plant.
• December 2012 – The CFIA's Vice President Operations sends a memo to all inspection staff to reinforce the Agency's commitment to a strong food safety culture and to ensure that employees understand the key role they play in protecting the health and safety of Canadians.

Action To Be Taken

• Spring 2014 – The CFIA launches new CFIA audit teams who will be responsible for evaluating inspection integrity in CFIA food inspection programs.

6. The CFIA and Health Canada should continue to expedite the approval of interventions - especially those approved and commonly practised by our food trading partners.

Implicated department(s): Health Canada; Canadian Food Inspection Agency

Status: Complete

Action Taken

• October 2013 – Health Canada issued policy intent document providing for expedited approval of select interventions.
• Ongoing – Health Canada continues use of new, streamlined process for regulatory approval of food additives, including those which control pathogens in meat.

7. Although it has only limited jurisdiction in this area, the CFIA should work towards strengthening requirements in the plant's prerequisite plan on the question of purchasing livestock.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• May 2013 – The CFIA publishes revised policy on the control of E. coli O157:H7 contamination in raw beef products.
• June 2013 – The CFIA launches consultation on the regulatory framework for the new Safe Food for Canadians Act which will strengthen requirements at the plant for incoming livestock (i.e. mandatory Animal Information Document).

8. Health Canada must complete its risk assessment of mechanically tenderized beef (MTB) as quickly as possible, and make known its recommendations concerning the handling of the product.

Implicated department(s): Health Canada; Canadian Food Inspection Agency

Status: On Track

Action Taken

• May 2013 – Health Canada publishes its health risk assessment for MTB in the International Food Risk Analysis Journal.
• July 2013 – The CFIA requires all MTB cuts prepared at federally-registered meat establishments inspected by the CFIA to be labelled as tenderized and with cooking instructions for consumers.

Action To Be Taken

• Fall 2013 – Health Canada initiates consultations on regulatory proposal to expand MTB labelling (identification and safe handling) to non-federally-registered sector (including retail).

9. All major stakeholders (both governments and industry) should work with the academic sector to encourage continued research on pre-harvest interventions that may help reduce the prevalence of E. coli O157:H7 in food animals.

Implicated department(s): Agriculture and Agri-Food Canada

Status: On Track

Action To Be Taken

• Provinces and territories launch cost-shared programming which will include awareness and training activities and support to facilitate the implementation of national government reviewed food safety systems.

10. The CFIA should adopt an initial benchmark of 5% for E. coli O157:H7 in beef trim, at which point inspectors would intensify their inspection activities and evaluate the matter more closely.

Implicated department(s): Canadian Food Inspection Agency; Health Canada

Status: Complete

Action Taken

• May 2013 – The CFIA publishes revised policy on the control of E. coli O157:H7 contamination in raw beef products which includes requirements for companies to develop and implement procedures to ensure that E. coli contaminated product does not enter the food supply on those production days when there are an unusually high number of positive samples planned. The plant must also take steps to determine the root cause of the problem and take any corrective actions.

11. The beef industry should submit a proposal to Health Canada to approve irradiation as an effective food safety intervention. Health Canada should give the application prompt consideration.

Implicated department(s): Health Canada

Status: Complete

Action Taken

• May 2013 – Canadian Cattlemen's Association submits a petition to Health Canada for the approval of irradiation as a tool to reduce E. coli O157:H7 in raw beef.
• November 2013 -The submission was assessed by Health Canada. While the scientific assessment has been completed, Health Canada will be considering its regulatory instruments to enable this application.

12. The CFIA should expand the scope of contaminant testing to include E. coli non-O157:H7 Shiga-Toxin-Producing Escherichia coli to establish a baseline for its prevalence in beef.

Implicated department(s): Canadian Food Inspection Agency; Health Canada

Status: Complete

Action Taken

• September 2012 – The CFIA implements verification sampling plan for E. coli non-O157 Shiga-Toxin-Producing Escherichia coli in federally inspected meat plants.
• Note: Information generated from regulatory sample launched this fiscal year will be bolstered by a comprehensive microbiological baseline survey on E. coli O157:H7 and non-O157 verotoxigenic E. coli on beef carcasses and raw beef, planned for fiscal year 2014-15.

13. The CFIA must require that processing plants document the criteria they apply to define a high event period (HEP). If a HEP occurs, the plant must perform and submit to CFIA inspectors a root cause analysis. Agency staff must be confident that the plant's proposed corrective actions will mitigate the risk.

Implicated department(s): Health Canada; Canadian Food Inspection Agency

Status: Complete

Action Taken

• May 2013 – The CFIA publishes revised policy on the control of E. coli O157:H7 contamination in raw beef products which includes requirements for companies to develop and implement procedures to ensure that E. coli contaminated product does not enter the food supply on those production days when there are an unusually high number of positive samples planned. The plant must also take steps to determine the root cause of the problem and take any corrective actions. The CFIA reviews all corrective action plans and only accepts them once they are confident that the actions will mitigate the risk.

14. During the high shedding season for Shiga-Toxin-Producing Escherichia coli, the CFIA must exercise extra vigilance by enhancing the sampling and verification testing used by its inspectors.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• April 2013 – The CFIA increases number of planned samples and focusses sampling activities during season when high shedding of E. coli O157:H7 is commonly observed.

To strengthen surveillance and trend analysis

15. The CFIA should require that data analysis (e.g., trend analysis, process control) be done at a frequency consistent with plant protocols and that, in the event of a HEP, the Agency be notified immediately.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• May 2013 – The CFIA publishes revised policy on the control of E. coli O157:H7 contamination in raw beef products which requires all slaughter and processing establishment handling raw beef to develop a program for trend analysis which takes into account all E. coli results.

16. CFIA inspectors must carry out the range of tasks in the Compliance Verification System (CVS) with the regularity indicated in the tool, to ensure that regulatory compliance processes are working.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• March 2013 – The CFIA implements weekly reporting of outstanding Corrective Action Requests (CARs), in addition to monthly reporting of the inspection task delivery rates (planned vs. delivered), to Regional Directors. CVS task delivery rates and outstanding CARs are reported quarterly to senior executives.
• June 2013 – The CFIA completes CVS Uniformity Project across all 18 regions to assess the quality and uniformity of delivery of inspection activities and identifies eight key findings which are being addressed.

17. The CFIA should require that inspectors adjust the frequency and thoroughness of plant sanitation inspections based on their ongoing findings. These evaluations should occur especially before start-up, to ensure that cleaning protocols are adequate.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• May 2013 – The CFIA completes training of inspection staff at XL Foods Inc. on how to adjust the frequency and thoroughness of sanitation inspections.

To strengthen incident management and recall response

18. The CFIA must require that the processor have meat labelling and distribution information at the plant and in an accessible format.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• May 2013 – The CFIA publishes updated requirements related to product distribution records as part of Chapter 3, Meat Hygiene Manual of Procedures.

19. When a recall occurs, the CFIA should explain publicly and post on its web site that further recalls may be required once all products from the first production days have been traced through the distribution channels.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• February 2013 – The CFIA tests revised format for food recall warnings with focus groups and the Consumer Association Roundtable.
• October 30, 2013 – The CFIA implements revised food recall warnings. The Honourable Rona Ambrose, Minister of Health, announced this improved communications tool on October 30, 2013.

20. The CFIA should improve the readability of Health Hazard Alerts (HHAs).

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• February 2013 – CFIA tests revised format for food recall warnings with focus groups and the Consumer Association Roundtable.
• October 30, 2013 – CFIA implements revised food recall warnings. The Honourable Rona Ambrose, Minister of Health, announced this improved communications tool on October 30, 2013.

21. CFIA should ensure that a technical expert is available, along with the national liaison officer for the National Emergency Response Team, to deal with the media and other stakeholders.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• August 2013 – The CFIA finalizes list of subject matter experts, including key technical experts, who may be called upon in times of need such as media briefings.
• August 2013 – The CFIA develops communication documents for stakeholders that articulate the roles and responsibilities of the various members of the National Emergency Response Team.

22. The CFIA should pursue the development of confidentiality agreements with key stakeholders now (before the next recall) to allow for freer and timely exchange of important information.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• During a major recall, the CFIA will share information with stakeholders to the fullest extent possible, subject to provisions of the Privacy Act and the requirements on confidential business information. This will include providing information to stakeholders under embargo prior to public release and undertaking formal confidentiality agreements in appropriate circumstances. When establishing confidentiality agreements the CFIA will use the processes in place for other such arrangements such as the agreement between the Agency and its Expert Advisory Committee.

23. The CFIA should provide press releases under embargo to major stakeholders, and afford them observer status on technical briefings with the media.

Implicated department(s): Canadian Food Inspection Agency

Status: Complete

Action Taken

• As part of the CFIA's standard operating procedures for crisis and emergency communications, the CFIA will continue to share press releases under embargo as appropriate and the CFIA will ensure a "listen only" line is established for all technical briefings with media.

24. During recall events, Health Canada and Public Health Agency of Canada officials should attend the CFIA's daily conference calls for stakeholders as well as any technical briefings it holds with the media.

Implicated department(s): Canadian Food Inspection Agency; Public Health Agency of Canada

Status: Complete

Action Taken

• October 2012 – The CFIA enhanced its communication with industry during national emergency responses by providing a "listen only" line during media technical briefings and ensuring appropriate technical expertise is available for conference calls with industry stakeholders.

25. Federal, provincial and territorial health authorities must collaborate on a priority basis to develop mutually acceptable definitions, along with messaging to explain them.

Implicated department(s): Public Health Agency of Canada

Status: Complete

Action Taken

• During all 2013 outbreaks, federal, provincial and territorial health authorities worked jointly through the Outbreak Investigation Coordination Committee to develop case definitions for each outbreak investigation and there is commitment to continue collaborating during future outbreaks.

26. If a contamination event results in a recall, the CFIA must immediately formalize any requests to the plant in writing for labelling and distribution information on the suspect product. All subsequent requests related to the recall in question should be prioritized and directed to the Plant Recall Coordinator.

Implicated department(s): Canadian Food Inspection Agency

Status: On Track

Action To Be Taken

• March 2014 – The CFIA updates Food Investigation and Response Manual to include protocols for communicating with regulated parties during a food safety investigation and recall situation.

To strengthen communication with the public and stakeholders about providing food safety messages

27. Government food safety partners must reach agreement about what they communicate, and who communicates it.

Implicated department(s): Public Health Agency of Canada; Health Canada; Canadian Food Inspection Agency

Status: Complete

Action Taken

• The Federal Food Safety Communications Protocol, developed in 2009, guides the coordination of public communications among federal food safety partners during food safety events.
• Ongoing – The Food Safety Communications Protocol is being further strengthened to reflect the new reporting structure for the CFIA, which will improve coordination among federal partners.
• The Canada Foodborne Illness Outbreak Response Protocol was revised in 2010 and includes a Communications Annex which continues to guide how federal, provincial and municipal levels of governments work together in responding to and communicating about outbreaks that span more than one jurisdiction.

28. Federal food safety partners (the CFIA, Health Canada, and Public Health Agency of Canada) must establish an expedited approval process to address the need for rapid communications during a national foodborne illness outbreak.

Implicated department(s): Public Health Agency of Canada; Health Canada; Canadian Food Inspection Agency

Status: Complete

Action Taken

• The Federal Food Safety Communications Protocol, developed in 2009, includes an expedited process for approvals of public messages.
• Ongoing – The Food Safety Communications Protocol is being further strengthened to reflect the new reporting structure for the CFIA, which will improve coordination among federal partners.

29. Public Health Agency of Canada must clearly be seen as the lead in communications with the public during a national foodborne emergency.

Implicated department(s): Public Health Agency of Canada

Status: Complete

Action Taken

• Public Health Agency of Canada revised the Foodborne Illness Outbreak Response Protocol including its Communications Annex, which guides how governments work together in responding to and communicating about outbreaks that span more than one jurisdiction and clearly identifies Public Health Agency of Canada as the lead when multi-jurisdictional human illness is present.

30. Health Canada should work with the Retail Council of Canada to vigorously pursue opportunities to educate consumers about proper meat handling methods.

Implicated department(s): Health Canada

Status: On Track

Action To Be Taken

• Ongoing – Health Canada continues to work with the Retail Council of Canada and other partners to educate consumers about proper meat handling methods, building on the "platform" of appropriate labelling.