Just so you all know, I've never met these gentlemen before this afternoon. They're reading off the same book and I don't know why I should speak. I have 10 minutes and I'm going to use all of it, so get ready.
Good afternoon to you all. Thank you for providing me the opportunity to present my concerns before this committee. I stand before you representing the many small meat businesses that are dealing with similar detrimental regulations that limit our competitiveness in the retail sector.
I'm Carl Norg, the owner of Carl's Choice Meats in Brantford. We opened our small family business in 1986. It is approximately 2,400 square feet in size, with 720 square feet used for our store, and approximately 500 square feet used for production. We employ three full-time people besides me. We also have a stall at two farmers' markets.
For the past 22 years we have provided many good, wholesome, and high-quality products to our constantly growing customer base. We have consistently passed the welcome scrutiny of our health units. We are now severely challenged by the new regulations since the inspections have been taken over by the Ontario Ministry of Agriculture, Food and Rural Affairs.
Today I'd like to speak to you about unfair competition with respect to income and profitability, and therefore the eventual demise of the local country butcher shop. In my remarks today I'd like to cover two areas of concern. One is the unnecessary paper burden required to complete the work day. Two is structural requirements needed to meet new regulations.
Large companies with 10 employees or more need written procedures to ensure that all employees are able to follow the same guidelines. This method of communication is essential when the number of employees exceeds the ability to communicate with them easily. These protocols are also in place so that when an inspector arrives to do their job they have a way of confirming that everyone is doing what is necessary to meet a consistent standard.
The joy of owning and managing a small meat shop such as ours comes from the variety of work that takes place each day. Though each week resembles the week before, small companies must be ready to make quick adjustments resulting from changes in customer flow, product availability, holiday demands, and even what we have in stock. Because we are customer focused, what we plan to do each day largely depends on the needs of our customers. In a small business, the owner generally sets the standard and sees to it that the employees meet those requirements. If the standards are low, the customer flow will likely diminish, while a business with high standards is more likely to keep the customers happy and healthy, in the case of the meat business.
Adherence to strict and unreasonable protocols is burdensome, difficult, and a waste of precious employee time. The reason for writing protocols is to follow them. In a small business such as ours, working with them is cumbersome and inefficient, which therefore makes them subject to misuse. Most of us have been in business long enough to know how to get the flavourful and safe results we wish to achieve, and the process by which to get there.
With written protocols also come checklists to be filled out each time a task is completed. As with written protocols, in a small meat operation there is very little sense in doing all the checklists that are required--again because of man hours. The multiple checklists alone, which are to be filled out each time a task is completed, interrupt the flow of work in a small business. Inefficiency equals loss in production and decreased revenue. Because of the ease with which this can be manipulated to fool the inspection system, experts at deception are created rather than master butchers. Currently most of us spend a good part of a 40-hour work week completing all the required paperwork. If the paperwork is easy to manipulate--and it is--or if it isn’t completed properly, why bother doing it at all?
The paper burden puts a severe strain on the budget because people need to be paid for these hours. This in turn necessitates an increase in our prices, decreases our available revenue, and reduces our competitiveness in the marketplace. This means less profit and subsequently less flexibility to make changes to improve our facility, hire new help, or increase the wages of our present employees. The current reality is that if a family-run meat business is no longer profitable and unable to support raising a family, it will cause the local country butcher shops to cease existing.
We need to convince our industry that we can be cleaner, safer, and healthier in the meat products we process and produce. This is not done by adding or redirecting employee time with the burden of more paperwork. The government has already realized that with their own paper burden reduction initiative, launched in 2005.
How to resolve this problem: I am convinced the best way to resolve this issue without unduly burdening the small meat business owners with wasted costly paid hours, while still satisfying the intent of the government for food safety, is best done by sampling of services and products. Inspectors should have the jurisdiction to arrive unannounced on any day to take samples of products and swab the surfaces at random. If samples returned clean, there would be no issue. But if one or more tests came back with unfavourable results beyond acceptable ratios, then corrective measures would have to be taken. If too many positive or problem samples were returned with an unacceptable test result, or if this were a occurring problem, then a fine, restricted production, or loss of licence grade could be the result. Licence results could be posted, so the consumer would be informed and therefore be able to make their own decision as to whether to continue to purchase their products at that store or to find another location to supply their needs.
Number two, structural requirements needed to meet new regulations: As stated previously, our building at Carl's Choice Meats is approximately 2,400 square feet, with approximately 500 square feet of production space. We are a small business with room enough to employ a maximum of five or six people. Because we are a small country butcher shop, our busiest time is the weekends at market. We do not have enough customer traffic flow during the week to hire a full-time sales clerk. Customers are seldom lined up to be served, but rather, drop by sporadically throughout the day. This means that there is no need for someone to be present behind the service counter on a constant basis.
When customers do come in, someone leaves the cutting production area to serve them. Now, there's a problem, as the person who has served the customer may now not re-enter the production area without a complete change of head covering, protective coat, and sanitized foot gear. The new regulations also state that we must have a separate room for our fresh cutting area, a separate room for our ready-to-eat production, a specific and separate area to keep our spices and plastic bags, and a passageway that encloses and separates these areas from the store.
Because of our small size, we do not have a designated receiving area. Our receiving area is a common area through which we enter the building, enter a cooler, and it's also a walkway from the cutting room to the cooler or to the store, machine room, or the smokehouse area. In order to meet regulations, we must separate these areas completely. This would entail a reconfiguration of our building to accommodate the perceived requirements and would cost in the neighbourhood of $300,000.
We had a consultant and an engineer assess what was needed to satisfy these regulations and draw up plans. They quoted $300,000. All these changes were within the present structure with no additional square footage added. We see nothing wrong with that kind of spending of money if a business plan were to show that it would be financially feasible. Unfortunately, all business plans showed it would not create any more profits or business to pay off the loan needed to fund such a project.
The other consideration would be that if we were to create more rooms or areas, these little crowded spaces would see little constant use. Rooms with low traffic flow have a tendency not to be maintained as well as rooms that see more work. This then would lead to a less sanitary condition and so become hazardous rather than healthful. In an open concept work environment, not only is everyone safer but also cleanup is frequent and sanitation is much easier and timely to accomplish.
As stated previously, $300,000 is an unacceptable cost to our business, because this is a cost that cannot be recovered.