Subcommittee on Food Safety Committee on May 4th, 2009

[The Chair, Conservative, Larry Miller]

We'll call this meeting to order.

In our first segment of the afternoon and evening, we have the Dairy Farmers of Canada, and Mr. Doyle and Mr. Bouchard. We also have Mr. de Valk.

Thank you very much for coming here.

Just so we can get right into it, if you could keep your presentation to 10 minutes or less, we'd appreciate it, and we'll then open it up for questions after that.

So thanks again.

[Wayne Easter, Liberal, Malpeque, PE]

Mr. Chair, I just have a question on procedure first, and it relates to Wednesday's meeting.

Remember we had a meeting the other day there, and I think all of us felt that the Agriculture Union should have two specific hours on its own, not mixed in with others, because they're the counter to the evidence.

Are we going to have that two hours with them? It just won't work if they're one witness amongst six. We need that cleared up.

[The Chair, Conservative, Larry Miller]

I don't have it in front of me here, but could we move on with the meeting and answer that before the meeting is over?

[Wayne Easter, Liberal, Malpeque, PE]

Okay. Can you have a look at it? If that's not the procedure, Mr. Chair, I'm going to put a motion to make it such.

[The Chair, Conservative, Larry Miller]

Okay, very good.

Mr. Doyle, are you going ahead? Okay, thank you.

[Richard Doyle, Executive Director, Dairy Farmers of Canada]

Thank you, Mr. Chair. I will begin my presentation in French.

First of all, Mr. Chairman, I would like to introduce my colleague, Dr. Réjean Bouchard, Assistant Director of the Dairy Farmers of Canada. He is the person in charge of most issues having to do with food safety.

You have received a copy of my presentation and a PowerPoint presentation on the Canadian Quality Milk (CQM) Program.

Since we have so little time, I will focus mainly on the CQM Program. I will be making my presentation in English, but I will be pleased to answer questions in both official languages.

Mr. Chairman, the presentation in your hands also deals with other activities that Dairy Farmers of Canada is currently involved in related to food safety. These include traceability; the development of a biosecurity program for dairy farms; and in collaboration with other animal commodities, the elaboration of a national farmed animal health strategy, the publication of a code of practices for the care and handling of dairy animals, ensuring the absence of residues in milk, and assessing new metrics for the application of food safety measures through the whole food chain.

There are some words on those activities in my presentation, but as I said before, I will focus primarily on the Canadian quality milk program, which is the on-farm food safety program. Nonetheless, all of these activities are closely linked to food safety and demonstrate dairy producers' commitment to excellence in producing milk for Canadian consumers.

Over the last 10 years—or a little bit more than 10 years—DFC has collaborated with Agriculture and Agri-Food Canada and the Canadian Food Inspection Agency in the development of the Canadian quality milk program to provide producers with the necessary tools to address food safety and to demonstrate due diligence as an important element of food production.

CQM is an on-farm food safety program designed to help producers prevent, monitor, and reduce food safety risks on their farms. The program is based on the internationally accepted principles of HACCP—I'm sure you're familiar with the term—the hazard analysis critical control point, a science-based and proactive approach to food safety that focuses on preventing and minimizing the risk of food safety hazards. The CQM program identifies areas of critical risk and best management practices to help address those risks.

Producers in the CQM program strive to improve milk and meat safety on their farms by keeping permanent records to monitor critical control points and to address microbiological and chemical contamination, by following best management practices related to milk and meat safety, by developing standard operating procedures to identify tasks and responsibilities for each participant in producing and harvesting milk, and by developing corrective action plans to ensure that family and staff know what to do if something goes wrong.

Dairy producers in the CQM program closely monitor the following key areas of milk and meat safety: the milking of animals treated with veterinary drugs, dealing therefore with the prevention of residues in milk; effective cooling and storage of milk, thereby controlling microbiological growth; the shipping of animals, for the prevention of residues and physical hazards in meat; the use of livestock medicines and chemicals, again to prevent residues in milk; the rigorous sanitation of milking equipment, again for microbiological hygiene; and the assessment of wash water for microbiological parameters.

Producers also implement best management practices in other areas, such as manure management, feeding, animal identification, medicine and chemical storage, milking, as well as staff training.

The CQM program offers registration to producers who have implemented the program on their farms. Producers undergo an on-farm audit. Once they are registered, they are subject to regular audits to ensure they continue to meet requirements.

Led by Canadian Food Inspection Agency, the federal, provincial, and territorial governments have developed, through industry consultation, a recognition process: the on-farm food safety recognition program. The recognition program provides technical review of producer materials, technical review of management systems, implementation assessment, and ongoing monitoring. The CQM program achieved technical recognition of both its producer materials and its management system in 2006. It has also maintained its recognition status through ongoing monitoring by CFIA.

Dairy producers have recognized the value and strength offered by the CQM program to the industry as a whole and have set a national target of December 31, 2010, for all Canadian dairy producers to be registered with the program. Provinces are working toward the target, and the number of registered producers is growing quickly. Right now, 96% of all our dairy producers in this country have been trained in the program. Nationally, 10% of all producers have been registered or finalized in the process. In some provinces this number is over 90%. That would be in the smaller provinces, I'll admit. In other provinces this number is closer to zero because of the different steps required, particularly in Ontario and Quebec, which have introduced what we call TTR, a time temperature recording, on every single farm, and have gone through these steps. When they now start registering and validating producers and going through the whole process, you'll see these numbers going up fairly quickly.

Once this is achieved, Canada will be in a unique situation in the world by having all producers registered under a certified on-farm food safety program. Many of the countries around the world have it on a company basis, but using our collective system in Canada, I think it's going to be fairly unique to have mandatory on-farm food safety, with validation and audits and certification for all producers.

Due to its HACCP-base, the CQM program has the ability to respond to new science and new food safety demands. The program also has the flexibility to be integrated with programs developed by other food chain partners, such as truckers, processors, and retailers, to ensure that food safety is adequately addressed all along the food chain.

We have worked with the Dairy Processors Association of Canada. We recently organized a conference called “A New Approach to Food Safety”, which focused on the new metric systems of quantifying hazards for the whole food chain. The system is an extension of HACCP-based programs and addresses the entire dairy food chain.

This is where we are in terms of our industry in trying to merge all of the different food safety programs into one single program.

I will stop there, Mr. Chairman. I think my time is up, so I will be happy to answer any questions.

[The Chair, Conservative, Larry Miller]

Okay. You actually have about two and a half minutes left, but we appreciate your finishing early. We'll open it up for questions.

I should have done this at the start. I was thinking we were on a different meeting time. But we have, from the Canadian Association of Regulated Importers, Mr. de Valk, for 10 minutes, please. Thank you.

[Robert de Valk, Executive Secretary, Canadian Association of Regulated Importers]

Thank you, Mr. Chairman, and thank you for the opportunity to provide the perspective of some importers on the subject of food safety.

Our trade association, the Canadian Association of Regulated Importers, or CARI, to use our acronym, is a specialized trade organization representing members who import food commodities for which import quotas have been established. Currently, the main ones are for chicken, shell and hatching eggs, turkey, and of course my friends here, dairy, with cheese. These quotas are in place to protect the respective supply management programs.

CARI is exclusively focused on representing the interests and rights of such importers. Imports of other food products and goods are not covered by CARI, so if you have questions relating to those, you’ll have to ask someone else. As importers of poultry products primarily—also of eggs, and turkey is of course considered poultry, and fowl is also considered poultry—our members operate within the regulatory environment maintained primarily by the Canadian Food Inspection Agency.

Based on our experience, the CFIA enhances the food safety of poultry and processed poultry product imports by maintaining two key policies. The first is restricting poultry and processed poultry product imports to only those countries and plants that have demonstrated equivalency with Canada’s inspection system based on HACCP principles. That equivalency in an inspection system is a key platform in maintaining food safety here in Canada, because our inspection system is a food safety-based inspection system.

The second element of the policy is the restricting of processed poultry product imports to only those products for which a label has been registered and a number issued by the CFIA under its prior approval service. No processed poultry product can enter Canada without a label registration number, which is checked at the border by either CFIA officials or CBSA officials and—and this is very important and critical—by foreign government officials prior to authorizing the export for Canada.

Normally, a copy of the registered label, approved and registered by the CFIA, is sent to the inspector in charge at the foreign plant. So that inspector has something to look at when he's signing the export certificate for Canada. Currently only the United States, Brazil, Thailand, and certain plants in Israel, Hungary, and France are eligible to export poultry products to Canada. In the case of Thailand, only processed poultry products can be exported. You can see that the universe is quite limited.

The combination of the two regulations provides a very effective and efficient means of enhancing food safety, as it allows importers to carry out their responsibility to import safe poultry and processed poultry products from HACCP facilities. We cannot, for example, import from non-HACCP facilities. That’s not allowed under the Canadian regulations.

Last week in Washington, D.C., at a conference I attended, we learned that the United States is considering adding egg products and catfish to USDA coverage, which means only imports from countries with equivalent inspection systems to the United States' system will be allowed. For your information, Canada is the only one that has an equivalent inspection system in the case of egg products, for example. Canada would be the only country that can export egg products to the United States.

So you can see what’s happening here. A similar bill is being considered in the Congress that would expand the use of HACCP to cover FDA products, and those are all the products that the USDA doesn’t cover. The U.S. government, therefore, is increasing the use of inspection equivalency and prior label approval as a means of improving food safety, because as you know, in Washington they’re holding lots of hearings on food safety, just as you are here.

Some have suggested that inspection system equivalency is being used by countries as an import barrier, but so long as the same rules are applied to the domestic industry, the approach is on solid ground. Food safety equivalency based on internationally accepted HACCP principles is one of the best ways to consistently improve the food safety profile of both domestic and imported food products and has the additional benefit of ensuring a level playing field in the marketplace.

The pivotal role played by prior label registration as an efficient and effective means of keeping out imports that do not meet Canadian requirements appears to be underestimated by the current government. As you know, a decision has been made by the government to unilaterally eliminate this requirement. None of Canada's key trading partners are demanding this be done, nor are they contemplating doing this. Although some will argue that labelling is not a food safety issue, keeping out food products that do not meet Canadian requirements is a critical component of maintaining food safety. It is no use removing those products once they've been consumed in Canada. We need to keep them out before they're consumed.

If these hearings by the subcommittee can cause the government to revisit and amend its decision to eliminate the prior label approval service, Canadians and food safety will be well served. Indeed, based on our experience with processed poultry products, we do not understand why the registration of all food labels, both domestic and imported, is not required. Over half of all food product recalls are related to allergens that were not identified on the label of the imported food product. If all labels had to be registered prior to their use in the marketplace, firms would be much more careful to ensure Canadian requirements were met. This would ensure food safety and reduce recalls.

Today's electronic world makes it possible to register all labels quickly and cost-effectively. The CFIA has developed electronic label registration, but for some reason it is not willing to fully utilize it. That's unfortunate.

One other effective way to improve food safety and promote harmonized food safety systems is for the federal government and other levels of government to provide seed funding to encourage the adaptation of HACCP principles. Under the CARD program, CARl requested to develop a generic HACCP plan for food distributors. We were the first application under that program, and it was accepted.

The generic model is now being used by many distributors across Canada, but since there are over 400--maybe as many as 500--food distributors across Canada, funding to encourage adaptation of HACCP by small and medium-sized distributors would improve the food safety profile of food consumed by Canadians. Similar seed funds were provided to encourage federal plants to adopt HACCP, and it was one of the most successful seed funding programs the federal government has ever put together.

Those are my comments, Mr. Chairman.

[The Chair, Conservative, Larry Miller]

Thank you very much, Mr. de Valk.

Mr. Easter is next, for seven minutes.

[Wayne Easter, Liberal, Malpeque, PE]

Thank you, Mr. Chair, and thank you, folks, for coming.

Mr. de Valk, you mentioned labelling, and I have labelling questions for Mr. Doyle as well. Are you saying there are different requirements for labelling by domestic producers in the Canadian market compared to labelling requirements for exporters from other countries into the Canadian market?

[Robert de Valk]

No, I'm saying those are exactly the same requirements. But if we have a plant in the United States that wants to export to Canada, the way our inspection equivalency works is that the USDA inspector at that foreign plant in the United States in effect becomes a CFIA inspector. He has to interpret the Canadian regulations and ensure that the export that is being prepared there meets Canadian import requirements. One of the most effective ways he can assure himself that the particular export meets Canadian requirements is to have a label that is registered by the CFIA. Then he knows that someone in Canada has already looked at it and said this meets Canadian requirements.

[Wayne Easter, Liberal, Malpeque, PE]

I'm still not clear, and I don't think I'm the only one. What was it you pointed out that the government eliminated? Explain specifically the requirement the government eliminated. I am a bit lost here.

[Robert de Valk]

It isn't eliminated yet, but it's scheduled for elimination.

[Wayne Easter, Liberal, Malpeque, PE]

What specifically?

[Robert de Valk]

Prior label approval. Right now, if you want to export to Canada, you must submit your label to the CFIA for registration.

[Wayne Easter, Liberal, Malpeque, PE]

I've got you now. I'm on the same planet.

[Robert de Valk]

That same requirement is in place domestically. Before you can sell your processed poultry product on the Canadian market, you must get your label registered with the CFIA.

[Wayne Easter, Liberal, Malpeque, PE]

That's scheduled to be eliminated on what date?

[Robert de Valk]

The rumours say it'll be gazetted in June or July and eliminated by September.

[Wayne Easter, Liberal, Malpeque, PE]

Richard, I think you're saying that the dairy industry's food safety conditions, which you detailed for us, and the programs that dairy farmers are involved in with Agri-Food Canada, like the milk board, are working well. Most of the industry is now on that program. But there is another side of the coin that came up when we were looking at Bill C-27, and that is the labelling issue. Are consumers getting the product they assume they're getting? Is cheese cheese? Is milk milk? Is ice-cream ice-cream? What have you got to say? When we're dealing with this issue, if there are problems, then we should be addressing them. It's not a food safety issue per se, but it definitely is a consumer's right to know issue.

[Richard Doyle]

It is an issue of protecting the consumers from being misled. This is important.

To build on what Robert was talking about, we haven't quite addressed the prior approval issue. Every week we find products improperly labelled and in the marketplace. This occurs for all kinds of reasons: lack of bilingualism, lack of information on nutrition, misinformation with regard to the product quality, and misuse of dairy terminology. We're checking this a lot. My favourite case is the butter tart. Many of the butter tarts are made with absolutely no butter. Why they're called butter tarts remains a mystery to me, since butter is a regulated food. You would think that if you enforced your regulation you would also protect the name. That's the purpose of having these things. We're progressing in discussions with CFIA on some of these issues. A lot of work has been done with regard to guidelines on the use or misuse of terminology on the label. There have been huge improvements since the bill you referred to. There's still some concern that we're not as far ahead as we would like to be.

Prior approval may be useful, but we still note a lot of imported products that have not received a prior approval, or that just come in somehow with labels that do not meet the Canadian regulations. This remains a concern for the Dairy Farmers of Canada.

[Wayne Easter, Liberal, Malpeque, PE]

They get on grocery store shelves?

[Richard Doyle]

Yes, indeed. The problem is, the way the mechanism works, you have to make a complaint. You have to find them and then report them to CFIA. That's all you hear about it, so you never know what follow-up has taken place. You have to keep trying to see if those products are still coming in.

[Wayne Easter, Liberal, Malpeque, PE]

Mr. de Valk, you named six or seven countries that send poultry products to Canada. What percentage of the market is coming in from those countries?

[Robert de Valk]

It's about 8% of the market.

Remember, we have a quota system that regulates to 7.5--