Thank you. Mr. Chair, I am going to make my comments in French.
Good morning, everyone. My name is James Laws and I am the Executive Director of the Canadian Meat Council. Thank you for the invitation to speak to you today about Bill S-11, the Safe Food for Canadians Act.
The Canadian meat sector is the largest in the food processing industry. It employs close to 70,000 people. Its annual gross sales of pork, beef, veal, lamb and poultry exceed $24.1 billion. Last year, Canada exported more than $1.3 billion in beef and $3.2 billion in pork to over 125 countries throughout the world. In total, there are close to 740 federally registered meat establishments that slaughter, process, quarter, bone, package, preserve or provide storage for meat and are inspected by the Canadian Food Inspection Agency.
Food safety is the top priority of meat processors. We support measures aimed at consolidating and modernizing the legislative framework governing food products. The CFIA currently runs eight food inspection programs. Each of them uses different inspection methods and tools.
Proposed Bill S-11 will improve food surveillance by instituting a more uniform inspection regime for all food products and increased control measures for imported food products. The government and the industry have known for some time that Canadian legislation governing food products needs to be modernized and strengthened.
In July 2009, the independent body tasked with investigating the 2008 listeriosis outbreak recommended that the government simplify and modernize the federal legislation and regulations that have a significant impact on food safety. That is the very objective of Bill S-11. We have long maintained that the meat industry in Canada is treated very differently from other food sectors.
That is why we support the consolidation and modernization of the legislation presented in Bill S-11, which is causing the repeal of the following acts: the Fish Inspection Act, the Meat Inspection Act, the Canada Agricultural Products Act and certain provisions of the Consumer Packaging and Labelling Act.
We believe in the importance of a modern approach to inspection based on the audit and compliance system. Grouping various powers and provisions in a single act will harmonize inspection and enforcement powers, make them coherent for all food products and allow inspectors to be more effective, and the industry to reach higher compliance levels.
Bill S-11 gives the government the power to create regulations to strengthen the act. For instance, subsection 51(1)(m) of the bill will require that certain persons prepare, keep or maintain documents and provide them to the minister or the inspector or that they give them access to them. Thus, consumers will benefit from a safer food supply system.
The bill repeals the Meat Inspection Act, a 17-page document, and replaces it by this new act, a document of over 60 pages. The bill contains several notable provisions, among them clauses 52 to 55 which describe incorporation by reference. Clause 52 states:
52. A regulation made under subsection 51(1) may incorporate by reference any document, regardless of its source, either as it exists on a particular date or as it is amended from time to time.
The meat industry is the most regulated sector in the food industry in Canada. Aside from the requirements that apply to meat and food under the Food and Drugs Act and its related regulations, and the Consumer Packaging and Labelling Act, we must comply with the Meat Inspection Act and its related regulations, as well as with the standard and comprehensive requirements of the Meat Hygiene Manual of Procedures, published by the Canadian Food Inspection Agency. The manual has 19 chapters and over 1,200 pages of text, and is already incorporated by reference in the meat inspection regulations, which are themselves 120 pages long.
The agency often changes sections in the manual without consulting the industry. Incorporation of documents by reference, under the regulations, is an important power according to which regulations will remain updated and could be modified. Indeed, section 55 of the bill states:
55. For greater certainty a document that is incorporated by reference in a regulation made under subsection 51(1) is not required to be transmitted for registration or published in the Canada Gazette by reason only that it is incorporated by reference.
We hope that incorporation by reference will be applied through a process that will guarantee consultation among the stakeholders. In that way, those who are affected by a change will have an opportunity to express their opinion. We think that this risks becoming a vicious cycle, because at least the Canada Gazette process, which is slow, is clear and well-explained.
Allow me also to point out that the new legislation applies only to meat processors that are inspected by the agency and that export or sell their meat through interprovincial trade. The new legislation will not create a unique standard, a national standard for meat inspection. We will continue to have hundreds of meat processors in Canada operating under different inspection regimes in the provinces. We think that all the provincial meat inspection standards should be consistent with the federal meat inspection standard.
Canadians should expect that all the meat products they consume are compliant with the same rigorous standards, regardless of where they live or make their purchases. We are willing to work closely with the government representatives and officials to make sure that the new act establishes a regulatory framework that will ensure that we are competitive in the international arena and will encourage the Canadian meat industry to attain the highest standards in food safety.
Thank you for your attention. I will be pleased to answer your questions.
