Subcommittee on Food Safety Committee on June 8th, 2009

[Albert Chambers]

I think industry would like all the voices reported. Whether it came in one document or in several is immaterial in that sense. There was clearly discussion and consultation back and forth before those reports were finally issued.

[The Chair, Conservative, Larry Miller]

Thank you.

Mr. Bellavance or Mr. Allen, do you have any more questions?

You have one? Okay, go ahead, André.

[André Bellavance, Bloc, Richmond—Arthabaska, QC]

Thank you, I always have another question.

I would like to come back to you, Mr. Chambers. Your members come from the agri-food sector. I imagine they followed last summer's listeriosis crisis very carefully.

Earlier, we were talking about responsibility. Both the government and the industry agree that responsibility for food safety lies with all the stakeholders, even consumers. One of the factors that must be considered is the way in which people prepare their food. That is a comment this committee has heard quite often.

As an observer, you are well aware of this issue, because you represent people from the agri-food industry. I would like to hear your comments on the way in which the crisis was managed, as well as your advice, not as to how what happened could have been avoided, but rather with a view to improving the way in which the crisis was handled.

[Albert Chambers]

Mr. Bellavance, as you correctly pointed out, the coalition represents a large number of organizations--30--representing every segment of the supply chain. We have not, ourselves, as the coalition, done a post-mortem on the listeria situation of last year. I think, though, you would find some important signals in our brief, particularly with respect to the sixth recommendation, which deals with food businesses, governments, and other stakeholders having a responsibility to adequately resource, proactively manage, update, maintain, and continually improve their food safety systems or initiatives.

We have identified in our longer strategy paper where industry needs to move in that direction, and we have given some indications as to where government needs to move in that direction. It has a lot to do with training. It has a lot to do with adequate resources. It has a lot to do with, as Mr. Allen indicated, validating your systems and completing what you set out to do. Governments needs the resources to be able to undertake those actions, and industry needs to make sure it puts forward the resources for its systems. So I think one of the key messages we would like to take out of the 2008 experience was that there would appear to be some improvements needed in resourcing, in training, etc.

[The Chair, Conservative, Larry Miller]

Mr. Allen, you have a little time left.

[Malcolm Allen, NDP, Welland, ON]

Thank you, Mr. Chair.

Actually, Mr. Chambers, you sort of just scored the run before we threw the pitch when it comes to resources, because it was point six that I was going to look at. You quite clearly highlighted in your bullets about promoting awareness, strengthening Canada's food safety, training, and auditing.

One of the things we heard—and this came from the government side as well—from CFIA, when they instituted a new protocol for testing at the beginning of this year, was that they hadn't trained folks to do the testing. And they actually haven't re-instituted it yet because, my understanding is, that training hasn't been completed yet.

As a subsequent question to that, who decides on your consensus model who isn't putting in the resources, and how does a group say to them, you need to pony up a couple of extra bucks because you're not actually pulling your weight?

[Albert Chambers]

I guess I would answer that question in a couple of ways. We haven't gone down to that level of detail because we've suggested very strongly that we need to have a very good discussion as to what that model would look like and what the commitments would be. We're trying to get governments to agree that there needs to be that discussion in the first instance, and then to elaborate that.

Clearly, jurisdictions have responsibilities and budgets, and all these things, which they have to sort through, but if they put food safety as the priority we believe they would if we did have a national strategy and we did have national decision-making mechanisms, then I would hope they would put the resources into it as well.

I'll answer another part of your question by pointing out that during a forum the coalition held with federal, provincial, and territorial officials and industry representatives in 2003, it identified that we needed to have, in a national agreement or consensus, or whatever it's called, a common standard for the qualifications and competencies of food safety auditors, whether they are working in companies in audit and certification programs by third parties, or for governments—federal, provincial, territorial, or municipal.

You'll note that in our national strategy, completed at the end of March, we are still promoting that idea, because six years later we have yet to convince a government—federal, provincial, or territorial—this is something that needs to be done.

So there are infrastructure issues like that on which we need to move ahead before we can have the comfort we should have in the quality and competence of the persons working in the industry and government with the responsibility for verification, etc., in these things. I'm not saying these people are incompetent; what I'm saying is that we need to have an agreed upon standard by which that competence can be judged. That in itself will bring greater confidence to our system, from the perspective of Canadians, food businesses, governments, and from our customers outside of Canada.

And that's just one example of the long list of things we have in our national strategy document. Going back to Ms. Bennett's question on what suggestions we have, we have a long list of suggestions in the basic document.

[The Chair, Conservative, Larry Miller]

Is there anything else, Mr. Allen? You have about a minute.

Okay. We'll move to Mr. Shipley.

[Bev Shipley, Conservative, Lambton—Kent—Middlesex, ON]

I just have a quick one. We've talked about national standards, and one of the issues that also gets talked about a lot is the fact that we have federally licensed and provincially licensed facilities.

The outbreak of listeria happened in a federally licensed facility. It actually seems that most of the concerns and the recalls do come from the large and federally inspected facilities. I don't ever want to leave the impression that food safety, either provincially or federally, is insignificant. It is. What we are trying to understand is that each province has its own level of what a provincially licensed facility has to meet. One of the concerns is that if we were to go right across the board and make every plant a federally inspected one, it would require a significant influx of dollars, a significant investment, which smaller plants just can't afford.

The other part of it, though—and this is not about food safety—is that some of those things are aesthetic, albeit that may be the wrong word. For example, the laneway has to be asphalted instead of having some other type of covering. The walls have to be a certain distance from other walls or entranceways, which actually has nothing to do with food safety. But if some plants were to adhere to these now and to come into compliance, they would basically have to abandon their facilities and start over and build new ones.

I guess my concern is whether there is a place, from your perspective, where we could actually work on the food safety issues and have a national standard. But on some of these other issues that actually aren't impacted by this, we want to keep...because of the concern we're going to lose some of these provincially licensed facilities otherwise.

[Albert Chambers]

The answer from the coalition's perspective is, yes, those results can be achieved. There are tools available to us, tools that industry has created. I've made mention of them in my comments—the presentation talks about them—and you've had other witnesses before you who have mentioned them too. You'll have another witness this afternoon from the truckers, who have designed national HACCP-based food safety programs that can be implemented by the largest of trucking firms or the smallest of trucking firms.

We have yet to achieve federal-provincial agreement that those programs will be formally recognized by governments. Even though industry and governments have made significant investments—tens of millions of dollars of investments—over the past decade and a half into their creation, we do not yet have fully agreed recognition mechanisms to bring those within our food safety system. We need to do that.

So there are tools available that we have invested in cooperatively with government that can achieve the kinds of results you're talking about. Simpler, less complex businesses require simpler and less complex food safety management systems. Things can be achieved, but we have to have that broader realization and awakening to that approach and recognition of it, and we need to be able to set clear food safety objectives different from prescriptive practices in order to be able to make that a reality.

[The Chair, Conservative, Larry Miller]

Thank you, Mr. Chambers.

We are now out of time, but we'd very much like to thank both of you gentlemen for coming today to testify before our committee.

We'll adjourn for five minutes or so to bring our next witnesses in.

Thanks again, gentlemen.

[The Chair, Conservative, Larry Miller]

We'll resume the meeting.

I'd just like to get into our next round of witnesses.

Welcome, Ms. Bette Jean Crews, the newly elected president of the OFA. It's good to see you here.

We also have Mr. Ron Lennox and Mr. John Gyoroky.

We have 10 minutes or less, and we'll start with you, Ms. Crews.

[Bette Jean Crews, President, Ontario Federation of Agriculture, Canadian Federation of Agriculture]

Thank you very much.

I'm here today representing the Canadian Federation of Agriculture. I sit as co-chair of their Food Safety Committee.

Let me start out by saying that the Canadian agriculture and agrifood industry does produce safe, high-quality food to sustainable environmental standards. Since the early 1990s, Canadian farmers, in partnership with governments, have taken leadership in developing national systems to strengthen our food safety commitment and in working in partnership with Agriculture and Agri-Food Canada and the Canadian Food Inspection Agency to develop the Canadian approach to on-farm food safety.

The Canadian approach entails the development of auditable, national commodity-specific programs and the creation of strategies and the necessary tools to educate producers and to implement national on-farm food safety initiatives consistent with the Codex Alimentarius' hazard analysis and critical control point--HACCP--definitions and with CFIA's on-farm food safety recognition program.

Agriculture and Agri-Food Canada has co-funded and assisted in the development and implementation of the national on-farm food safety programs since 1997. While no food safety system can assure zero risk, it's a primary goal of the Canadian Federation of Agriculture to ensure the continued development of strong, sustainable, industry-led food safety, traceability, and animal health systems for the greater public benefit of Canadians. We thank you for the opportunity to address the members on some of the key requirements that we feel are needed to ensure this continues.

Canadian farmers have taken leadership in developing national systems for food safety, but the implementation and ongoing management is costly. These initiatives contribute to the public good and greater welfare of Canadians, but have returned little or no value from the marketplace. There are no premiums for safe food. With already low incomes, the sustainability of these food safety systems is strained. In order to support the continuation and strengthening of these systems, ongoing financial commitment and partnership from the public and from governments is required. The Canadian Federation of Agriculture also advocates for government support for enhancing Canada’s reputation as a provider of high-quality, safe food through a government-funded communications plan that raises awareness at domestic and international levels on the strong food safety and quality systems that Canadian production has implemented. This plan would help in achieving marketplace value for the initiatives the industry is putting in place, and it would support the competitiveness of Canadian agriculture.

On industry leadership and industry-government partnerships, first, through a program called the Canadian on-farm food safety program, which ran between 1997 and 2004, and later through the Canadian food safety and quality program, Canadian producers, in partnership with AAFC and CFIA, have proactively led and designed the science-based Canadian approach to on-farm food safety. It's through this industry leadership that 19 commodity groups, with 22 commodity-specific programs covering 99% of all Canadian production, have now completed or are completing the development phases of their HACCP-based on-farm food safety systems.

Producers are wary of increased costs in a very competitive marketplace. They are also extremely concerned about government downloading of costs, administration, and regulation. Producers, however, are also keenly aware of the need to ensure the safety of their products. It’s for these reasons that industry must continue its leadership in on-farm food safety and that its development be a strong industry-led partnership with governments.

Through CFA, the national commodity organizations, and the Canadian On Farm Food Safety Working Group, development of on-farm food safety systems has been a success, efficiently allocating funds, conducting industry research, building buy-in from producers through their own organizations, and maintaining accountability to Canadians through yearly third-party financial and compliance audits.

Without that partnership, the CFA believes the strong progress, producer buy-in, and ultimately success in developing strong on-farm food safety systems would not have occurred. To date, this has been an excellent example of how industry-government partnerships can be a very effective tool in delivering services while saving costs to taxpayers.

On-farm food safety programs are only effective if they are implemented. CFA believes it is imperative to have a well-funded, strong on-farm implementation program available to national producer organizations and their provincial counterparts to use, to implement the national food safety systems. CFA welcomes the establishment of incentive-based programs for food safety initiatives and strongly believes flexibility and incentive-based programs are much more effective at achieving progress compared with inflexible regulatory approaches. However, the recent shift to provincial delivery versus federal under Growing Forward has raised concerns that access to funding may vary across provinces, creating a patchwork approach to the food safety program.

As we move from the APF to the Growing Forward program, CFA recommends the following: significantly streamlining the approval, processing or agreements to improve the ability to obtain contracts or extensions in a timely fashion; and much greater flexibility for use of funding in the areas of training, human resources, purchase of equipment, and full audit cost recovery. CFA also recommends that Canada pursue clearer language on equivalency that will make it more incumbent on countries to allow imports where the food safety protection afforded by exporting countries’ inspection programs is at least equivalent to that of the importers, even if the modus operandi is different in certain aspects.

Traceability is the ability to track movements of animals and goods through the supply chain. It is an important tool for agriculture. There is a significant public good in the development and implementation of traceability systems in the areas of the protection of plant and animal health and in the area of food safety. Many initiatives are currently under way to implement traceability systems at the farm level and throughout the chain. However, traceability standards alone do not make food any safer; they simply make it easier to track.

CFA welcomed the decision of federal, provincial, and territorial ministers of agriculture to develop and implement a national agriculture and food traceability system in Canada and has called for a system comprising all food production, including primary producers and along the value chain, and building on national standards.

In addition to the obvious benefit to government in protecting the public, a national identification and traceability system would constitute a risk management tool that can greatly improve the competitiveness of the industry as it would allow for identification of contamination sources, reduction of response time in the event of a crisis, and minimizing the economic impacts of a foreign animal/plant disease outbreak or a food safety crisis disease outbreak in Canada. Reduced economic impact results in less industry reliance on government risk management programs. A successful agricultural industry reflects on the economy of the country.

A national traceability system would allow the industry to seize opportunities for reinforcing our domestic and export market access while responding to the growing need of consumers across the globe to know the origin of their food. It would also support Canada’s on-farm food safety systems and aid efforts in eradicating domestic animal/plant diseases and elimination of foreign animal disease incursions.

It is therefore important that governments provide leadership and support to ensure that the various traceability initiatives work and are able to communicate with each other. Governments must also assist industry in the event of an incident with trade loss or when receiving compensation. With respect to implementation, CFA again encourages the use of incentive-based systems as opposed to an inflexible regulatory system.

CFA supports a national traceability system that is compatible across the country, across commodities, along the value chain, and technologically compatible with international standards. In conclusion, we'd like to thank the committee for the opportunity to present to you on this very important issue.

The recommendations you make in June will have a significant impact on the food industry, and it's our hope that you'll bear our comments in mind and build on the strong, science-based Canadian on-farm food safety programs. The CFA and its members remain committed to working with government and all stakeholders to further strengthen the food safety system in Canada.

Thank you.

[The Chair, Conservative, Larry Miller]

Thank you very much, Ms. Crews.

I'll now turn to Mr. Lennox.

[Ron Lennox, Vice-President, Trade and Security, Canadian Trucking Alliance]

Good evening, Mr. Chairman and subcommittee members.

My name is Ron Lennox. I'm a vice-president with the Canadian Trucking Alliance, a federation of Canada's provincial trucking associations representing some 4,500 carriers and trucking industry suppliers nationwide. CTA is a member of the Canadian Supply Chain Food Safety Coalition, who appeared before you earlier this evening. With me is John Gyoroky, corporate dock manager and HACCP coordinator with Erb Transport. Erb is a family owned carrier based in New Hamburg, Ontario, specializing in refrigerated transportation, operating a fleet of 1,000 refrigerated trailers, 500 tractors, 150 straight trucks, and employing some 1,200 people and 140 owner-operators.

Erb was the 2008 recipient of Canadian Transportation & Logistics magazine's Shippers Choice Award, as well as the Premier Carrier Award from food giant Sysco Corporation. Erb Transport was also one of the first carriers in Canada to implement CTA's HACCP-based trucking food safety program, which I will speak to in a moment.

I had the pleasure last week of speaking before the full agriculture committee as part of its study on the competitiveness of the Canadian agrifood industry. During my remarks, I made the point that you can't have a competitive agrifood industry unless you have a competitive transportation industry as well. The same holds true here. Virtually every food product we consume is moved on a truck at some point, probably several times for that matter. If you want a full picture of the state of food safety, you have to look at every link in the supply chain, and trucking is a key component.

I'll keep my remarks fairly general. I want to give the subcommittee a sense of the regulatory landscape that the trucking industry operates in, as well as some background on CTA's HACCP-based program.

Most of you here this evening heard my description last week of the highly competitive nature of the trucking industry in Canada: 10,000 carriers employing a quarter of a million drivers, 375,000 people overall, and generating about $30 billion in annual revenue from the for-hire sector. The industry provides service to virtually every town and city in Canada and the U.S. and is responsible for about two-thirds by value of Canada's trade with the United States.

Erb Transport alone provides temperature-controlled service for 1,800 shippers delivering their food products to 24,000 consignees throughout Canada and the lower 48 U.S. states. It is often said that trucking is the most regulated deregulated industry in Canada. The days of economic regulation of trucking rates and routes are long behind us. The carriers nevertheless face the daunting task of compliance with federal, provincial, and state regulation in areas such as road safety, environment, and labour. While most of Canada's trucking industry falls under federal jurisdiction, we are nevertheless impacted by provincial and state regulation in areas such as vehicle weights and dimensions, where no fewer than 63 sets of requirements exist in Canada and the U.S.

Food is no different, where both provinces and the federal government set standards and regulate. The challenge for a trucking company is to ensure that they are familiar with and comply with the standards in all of the jurisdictions in which they operate. Government regulation is of course just one fact that will influence carrier practices in the safe transportation of food products. The second important consideration is the market. Carriers sell their services to food shippers, and if they want to win new freight contracts and retain existing business, they must meet the service standards they negotiate with their clients.

When it comes to the food business, there is probably nothing more important than meeting shipper requirements dealing with food safety. We have seen the irreparable damage that can be done to a food manufacturer or retailer, and the health risk to the public, if a food product is subject to chemical, biological, or physical contamination.

Food shippers have a very clear interest in ensuring that the carriers they use have standards and procedures in place to ensure vehicles are adequately cleaned and sanitized, that there is no cross-contamination of food products with other commodities, and that the cold chain is maintained throughout the transportation process, from the loading dock to the receiving dock. On the receiving end, consignees also need to satisfy themselves that food that arrives on their dock has not been contaminated during transport, and that they have procedures in place to monitor, for example, the temperature of loads during transport.

I'm certainly not here to suggest that the market is somehow a substitute for food safety regulation. But going back to what I said to the full committee last week, there is probably not a more competitive industry in Canada than trucking. A carrier is not going to last very long in this business if they fail to live up to their obligations to shippers in vitally important areas like safe food handling practices. It's not just about price.

In a similar vein, there are various things carriers can do to go beyond regulatory and shipper requirements for food safety, the most notable one being HACCP. I'd like to take a few minute to describe CTA's involvement in this area.

Back in 2001, CTA was approached by the Canadian Food Inspection Agency regarding the Canadian food safety adaptation program. It provided funding for HACCP-based programs to national associations representing the off-farm sector all along the supply chain. Our first question, naturally, was what HACCP stood for, because nobody on staff at CTA had heard of it. We were also reeling at the time from a spate of new security programs being introduced in the wake of 9/11, and the last thing we really needed was another project.

However, the more we talked to CFIA, the more we realized two important things. First, if CTA didn't get engaged in the development of a HACCP-based program for trucking, somebody else would do it for us, so better to steer the ship than just be along for the ride. Second, HACCP programs were beginning to spread among the customers we served, so we felt it important to give carriers a program they could adopt that would dovetail with shipper programs. We wanted to create a situation where a carrier would not have to comply with multiple shipper programs, but instead would have one that was uniquely tailored to our industry.

I won't go into all of the details, but CTA applied for and received funding from CFIA, and later from Agriculture and Agri-Food Canada under its food safety and quality program, to develop a HACCP-based food safety program geared specifically to trucking operations. We assembled an advisory team consisting of carriers, CFIA technical experts, and national food associations such as the Canadian Meat Council, the Canadian Council of Grocery Distributors, the Canadian Produce Marketing Association, and the Canada Grains Council. While CTA had overall responsibility for the project, the actual work of developing the program was contracted to Kasar Canada, a Nova Scotia-based company with significant expertise and experience in the development and implementation of FSEP and HACCP.

Work began in 2001 on the development of a strategic plan. A draft food safety program was put together with the input of the advisory committee. It was piloted by 10 carriers from across the country operating in different parts of the food industry such as meat, dairy, grain, and dry goods. It was revised according to the lessons learned during the pilot phase, and ultimately submitted to CFIA for technical review.

I'm pleased to note that in February 2005, CFIA advised CTA that our trucking food safety program, consisting of a set of core elements and supported by 10 product-specific modules, met the agency's technical requirements. CTA subsequently contracted with Kasar to deliver the program on its behalf and assist carriers on a consulting basis to integrate the trucking food safety program into carrier operations and to oversee implementation through annual audits.

I'll be perfectly blunt with you in saying that we've fallen short of expectations in moving our HACCP program into the marketplace. As of today, we have 14 certified carrier participants. Some, like Erb Transport, and Midland of Moncton, New Brunswick, are major players in the food trucking business. Other, smaller carriers in different parts of the country have also come on board. What accounts for this? There are several reasons I can suggest.

We believed from the outset that the major push for HACCP would come from the food shipping community, but it seems this took longer than expected to materialize. A lot of carriers got in touch with Kasar to learn about the trucking food safety program when it came out, but many backed off, saying, “We already comply with regulations. We're already meeting any additional requirements that our clients place on us, so we'll do HACCP if and when shippers demand it.”

One other thing carriers noticed when exploring HACCP was that they already did most of what was required, but they didn't have the detailed record-keeping systems in place to demonstrate compliance with HACCP principles.

Though my information is only anecdotal, I would say that the tide seems to be turning in this regard. As Mr. Gyoroky will attest, food clients are increasingly demanding signed food safety agreements from their carriers, including HACCP programs, perhaps in reaction to high-profile food safety incidents, perhaps in response to the huge attention given to food and product safety generally in the United States, and perhaps in response to inquiries such as these. Whatever the reason, we're beginning to see positive signs.

We had also thought that if the federal government were to confer official recognition on off-farm HACCP programs such as CTA's, they would have more cachet with shippers. While there has been a number of discussions between industry--under the auspices of the food safety coalition--and government representatives from CFIA, the discussions have not yielded anything concrete thus far.

Thank you, Mr. Chairman and subcommittee members, for allowing us to appear today. Both Mr. Gyoroky and I would be pleased to respond to any questions you may have.

Thank you.

[The Chair, Conservative, Larry Miller]

Thank you very much, Mr. Lennox.

We'll now move to questioning.

Mr. Easter, seven minutes.

[Wayne Easter, Liberal, Malpeque, PE]

Thank you, Mr. Chair.

Thank you, folks, for coming and giving your presentations.

Two questions, I guess, to both the trucking association and the Federation of Agriculture.

How does our regulatory environment on food and food products compare in Canada versus the United States? As a trucking association, you're operating in both countries.

Bette Jean, you're well aware, I think, of the cost structure in the United States. How do we compare as a country?

Certainly I'm of the view that food safety should be a public responsibility, to a great extent. There's no question that what you have to do in the trucking industry adds costs. Who do they get passed on to? I suspect they get passed down to the primary producer at the end of the day. The same with the CFA in terms of costs at that level.

How do you think we compare with the regulatory environment in the United States? What is the impact of these costs on the primary producer, from where all food has to start?

[Ron Lennox]

Mr. Easter, John and I were having a chat at lunchtime about regulation. The fact of the matter is that there really isn't that much direct regulation of trucking specifically on food safety. Most of the regulation applies to the producers, to the distributors, and at the retail level.

There are certain regulations in terms of segregating products, for example, under the Transportation of Dangerous Goods Act, but there really isn't a lot of direct regulation on the trucking industry. We take our direction from the shippers we carry for, who are, in fact, regulated in most cases.

As to how they compare with the United States, I'm not familiar enough to say that I know that ours are more stringent or less stringent than in the United States, but I think their system is relatively similar to ours in that the regulation isn't directly on us.

I'm sorry; you had a second part to your question.

[Wayne Easter, Liberal, Malpeque, PE]

Well, that basically covers it on U.S. and Canada on the trucking side. The second part of the question was on who really pays for the cost of any of these changes. It never seems to go up to the consumer. It always comes down to the producer.

[Ron Lennox]

As I said to the committee last week, and you were there, Mr. Easter, programs aren't free. We were talking about security programs last week. To put in place a HACCP program is not free either.

I'm not sure what Erb Transport paid to do their program and what they pay on an ongoing basis to be audited, but, yes, carriers are in a very competitive business. When they put in place programs like this, it's sometimes difficult just to absorb those costs. So they do get passed down to their shipping clients.

[Wayne Easter, Liberal, Malpeque, PE]

Bette Jean...or John, sorry.

[John Gyoroky, Corporate Dock Manager and HACCP Coordinator, Erb Transport, Canadian Trucking Alliance]

We run the same HACCP program across all of our divisions. On our limited side, it services Canada, and on our international, it goes down to the U.S.

I'm not well versed as to what's required in the U.S., but what I do know is that we apply the same program to our conveyances, to our freight and how we handle it. It's handled in the same facilities, in the same warehouses, subject to the same cleaning for the trailers.

We did our best, and I think the senior management of Erb Transport felt that it was a necessity of business, being in the handling of food, to maintain a standard and protect the integrity of our customers when shipping their freight. We tried to absorb that cost within our operations and how we do business day to day. It is an extra cost there, but we're trying to work it in as best we can with our operations.

Thank you.

[Wayne Easter, Liberal, Malpeque, PE]

Thank you, John.

Bette Jean.

[Bette Jean Crews]

I don't know what regulations are commodity by commodity in the States, but I do know, on a traceability basis, when BSE hit in Canada, we were ahead of the States in being able to trace our animals. We've improved phenomenally since then, but as far as actual regulatory requirements went, we were ahead of the States at that point. Having said that, I'm given to understand there is significant assistance to farmers in the States by their government to implement what is being mandated to them now.

I do, though, want to speak to the cost coming back to the producer, because there are small profits. We hear that all the time, but there are also very small margins. We are competing on a global market. One of the things I mentioned in the presentation was a government-led communications protocol or program to the consumer to tell them what we do now, why it is good to buy Canadian, the fact that our food is safe and of high quality, but also tell them about environmental standards and labour standards that we meet in this country. If we can get that promotion through the industry but also through government, then we will get more loyalty from the consumer.

Right now, if we are regulated and mandated for very costly food safety protocols that are not market-driven, that are simply perception-driven, the industry cannot absorb that. There is no way to pass it on because of the cheap food policy and the competition from the global marketplace of foods that come in at different standards from those we produce.

[Wayne Easter, Liberal, Malpeque, PE]

You're basically saying, then, that the public should be responsible for more of the costs of food safety than is currently the case, I suspect.

The other point you mentioned, Bette Jean, in your presentation was the whole issue around products--some of which are food--imported into Canada, which CFIA is responsible for inspecting as well, but which compete against Canadian products. Everything I think we've heard to date at this committee is that they don't face the same strict inspection rules that Canadian producers have, or the same production standards, for that matter.

What are your thoughts there?