Thank you for this opportunity to testify.
My name is Kathleen Gibson. I'm a policy analyst in Victoria, British Columbia. I'm here today to represent the BC Food Systems Network.
I've spent the last seven years on contract to the BC Food Processors Association working on provincial licensing and inspection of slaughterhouses in B.C. under the meat inspection regulation of the Food Safety Act.
B.C. has four categories of provincial licence: two require a licensed, inspected abattoir facility; and two permit slaughter and sale of meat at the farm gate. The farm gate licences were developed in 2010 based on a risk assessment undertaken by the Ministry of Health. The Canadian Food Inspection Agency has been providing inspection in provincially licensed abattoirs on contract to the province but will be leaving that role at the end of 2013. B.C. is currently developing its own inspection service.
The BC Food Systems Network, which I'm here to represent, was formed in 1999. Its focus is sustainable food systems. It defines a food system as the resources and processes required to feed a population. The network connects hundreds of participants, indigenous and non-indigenous, and links agriculture, food, fish, health, labour, environment, and social disciplines, and about 50 community-based food security organizations in B.C. This presentation complements a brief submitted to you by the Food Systems Network in December 2011 regarding Growing Forward 2, and a presentation made to you on February 29 of this year by Anna Paskal of Food Secure Canada.
I'd like to introduce you to three fictional people who could be your constituents. I'm introducing them because I hope it will help illustrate what it's like for people who work with livestock and meat systems at the provincial level.
Al raises rare breeds of sheep on an island in the Gulf of Georgia. He has a farm gate licence to slaughter and sell his lamb. A retired electrician, he supplements the family income with meat and wool sales. He's focused on contributing to his community rather than growing a business.
Bert raises cattle on a 225-acre ranch in southwestern B.C. He sells 70 carcasses a year—30 through his farm gate store and 40 to local restaurants. He uses a provincially licensed slaughterhouse 200 kilometres away. He bought the ranch when he retired from 30 years in the gravel business. Income from quota for 10,000 egg layers helps support the red meat side of his operation.
Charlie has been managing a family-owned red meat processing business near a major urban centre for the last 10 years. The abattoir can process around 1,000 hogs a day. The business sells meat products wholesale and through its nearby store. Charlie's key concern is to develop and retain markets, since large retail won't take meat from provincially licensed processors. He doesn't want a federal licence, though, because of the staffing costs needed to manage the CFIA's food safety system. He's also frustrated that he can't have his products go through distribution facilities that handle federally registered products only.
Here are some basic facts about red meat value chains. Red meat includes beef, pork, lamb, goat, and ratites, such as ostrich. Red meat markets are conditioned by and vulnerable to international trade pressures. Livestock and meat production, processing, and retail is a world of the very few very large and the very many very small. There is virtually no middle. Profit in livestock and meat derives from value-added meat products and from by-products, such as tallow, bone meal, and hides. Beef waste by-products shifted from the income to the expense side of the ledger after BSE controls were introduced in 2007. Product that crosses a provincial border must be from a federally licensed facility. Product from a provincially licensed facility can only be sold within the province. It can cost $150,000 to set up a food safety system, and it will need several full-time staff to operate it for a federally licensed facility.
In the provincial system, it can cost a B.C. producer at least $2,000 to finish a beef animal for market, and it can cost $1 million to build a small provincially licensed red meat abattoir. B.C. specifically—to give some idea of scale—had about 260,000 beef animals from beef and dairy operations available for slaughter in 2011. The number actually slaughtered in provincially licensed abattoirs was about 24,000, about 10%. B.C. has one pork-only federally licensed and 33 provincially licensed red meat slaughterhouses. We also have 72 farm gate licences in remote rural areas.
There is strong consumer demand here for local and sustainable food, including meat. Lamb and goat meats are particularly in short supply.
There are four key areas of public policy involved in livestock and meat at federal, provincial, and municipal levels. Two operate throughout the chain—from farm through slaughter to retail. The first is public health, protection against food-borne illness. Concerns include micro-organisms that are resistant to antibiotics. New mutations such as E. coli 0157:H7 are constantly appearing.
The second is the environment, the handling and disposing of solid waste. In addition, the CFIA's enhanced feed ban requires that all specified risk materials—certain parts of beef carcasses—have to be separated from the solid waste stream and specially handled to control BSE. Disposal options in B.C. are very limited.
Two policy areas operate at the farm and slaughterhouse levels only: animal health for detection of animal-borne diseases—some of which can infect humans—and animal welfare, specifically, humane handling and euthanasia of meat animals.
So, how does this play out for folks in the business at the provincial level? The very big and the very small differ in size, but also in approach. The very big seek economies of scale. The very small tend to be place-based, more holistic, and more diversified. For the last 50 to 60 years, the very small have increasingly been operating in a world framed by government policies and programs designed for the very large. Regulators tend to introduce global-level standards without considering whether or not they are workable. The trouble with this is that the very small find policy requirements, at best, a poor fit, and at worst, functionally unworkable. If they can't make it work, these businesses go broke, or they go underground.
Some of you may be thinking that the big players should simply take over and forget the very small as too insignificant or too much trouble to support or regulate. We don't agree. We believe that ignoring or abandoning our subnational livestock and meat businesses—and Al, Bert, and Charlie—is unwise. There are seven reasons why. One, diversity is key to resilience, and thus to sustainability. Two, consumers want choice. Three, chefs long for a variety of meat products and cuts that they can't get from the big suppliers. Four, community-based meat producer and processor businesses are key participants in community economies. One provincially licensed processor can serve over 100 producers and 10 or more butcher shops as well as restaurants and retailers. Five, the provincial system can be an incubator for businesses that may choose to scale up. Six, smaller, decentralized facilities can rapidly be isolated in case of disease outbreaks. They also have a relatively small environmental footprint and low fossil fuel requirements. Seven, B.C. geography means that if you try to centralize too much, the activity becomes economically unviable, goes underground, and becomes untraceable, with negative implications for public interests.
We have three high-level recommendations for the federal government, as well as some specifics. First, put food back on social policy radar. Food systems are not only about profit. That's why we have the example of Al in the Gulf Islands. They are about society-wide health and well-being, which are the responsibility of governments. We echo the request of Food Secure Canada and the recommendations to Canada of Olivier De Schutter, United Nations special rapporteur on the right to food, for a national food strategy.
Second, acknowledge, support, and help promote subnational food production, processing, and retailing businesses in meat. This includes five things. It includes policy frameworks and tools that are appropriately scaled—that is, based on an assessment of risks to the public. In B.C. we have examples of that. It includes extension, networking, training, case studies, and pilots for market and value chain development. Some of the tools that the Canadian Agri-Food Policy Institute has developed could come in here. Third is to define “local” at several levels. Don't just say local means Canada. Fourth is research and development support and prototypes for small-scale, efficient, clean technologies for handling slaughter waste; and finally it includes a solution for the distributor cross-docking problem.
Third, our last recommendation is to undertake a formal and thorough review of the four following matters. First, review hazard analysis critical control points as the framework for food safety and meat processing and the approach used by the CFIA in federally licensed facilities, so that our friend Charlie can manage under a federal licence. Does this effectively address food safety priorities?
Second, review CFIA practices. Interactions with industry are often dysfunctional, resulting in poor relationships and costly delays. Implementation of the appeal mechanism is a good step.
Third, the assumption that every bovine carcass is contaminated with BSE needs to be re-examined.
Fourth is supply management, not just the pros and cons of the existing system, but of the potential alternatives. Red meat may offer a picture of what chicken and turkey could become without supply management. Is that good for Canada? Bert's layers, for instance, form a key part of his farm financial plan and support his beef operation.
We look forward to your response on these recommendations and to any questions you may have.
Thank you.