Fisheries Committee on March 3rd, 2022

[The Chair, Liberal, Ken McDonald]

I call this meeting to order.

Welcome to meeting number 10 of the House of Commons Standing Committee on Fisheries and Oceans. Pursuant to Standing Order 108(2) and the motion adopted on January 18, 2022, the committee is resuming its study of the traceability of fish and seafood products.

This meeting, of course, is taking place in a hybrid format, pursuant to the House order of November 25, 2021. Interpretation services are available for this meeting. Please inform me immediately if interpretation is lost and we'll ensure it is restored before resuming.

We have a number of witnesses, but before I introduce them, I will say that the clerk has told me the volume in the room is very high. It would be much better if members could keep their mikes turned down and use the earpiece to hear, because it may interfere with the interpreters' ability to follow the meeting they way they would like to.

For our witnesses, as an individual, we have Monsieur Charlebois, who is a professor with the Agri-Food Analytics Lab at Dalhousie University; from Fumoir Grizzly Incorporated, we have Laura Boivin, chief executive officer; and from Safe Quality Seafood Associates, we have Mr. Scott Zimmerman, chief executive officer. That's two names with “Zimmer” in them this meeting. That might be a problem.

We will now proceed with opening remarks from Mr. Charlebois, for five minutes or less, please.

[Dr. Sylvain Charlebois, Professor, Agri-Food Analytics Lab, Dalhousie University, As an Individual]

Thank you, Mr. Chair, committee members, fellow witnesses and participants.

I want to thank the committee for inviting me to speak about the seafood industry and traceability. Being from Nova Scotia, where the fish and seafood industry plays a large role in our economy, I feel very privileged to be speaking to you today.

Over the years, many reports in Canada have suggested that seafood fraud cases are rampant here. We believe that anywhere between 25% to 60% of fish and seafood served at restaurants in Canada is mislabelled, and up to 10% to 15% of fish and seafood products sold at retail in Canada is also mislabelled. While seafood fraud is a global problem, Canada is known to be lagging in food traceability overall when benchmarked to other countries.

For this committee today, I would like to make the following overarching, principal recommendations for a stronger traceability program for seafood in the country.

Recommendation number one is that the fish and seafood industries are a global enterprise. Any comprehensive approach to traceability would need to accept this as fact. The current deficit of standard informational obligations in seafood leads to lack of interoperability. This, in turn, diminishes transparency and thus inhibits traceability. This issue impacts business efficiency and enables the conditions that can lead to illicit activity. Many technologies exist, but they don’t go far enough. If we are to believe that sustainable fishing is possible, programs like the not-for-profit Marine Stewardship Council, which I think you're inviting to this committee, can discipline the entire industry while reassuring the public. Such a model transcends borders. This strict supply chain certification, which uses random DNA tests, helps ensure that MSC-certified seafood is always labelled correctly and kept separate from non-certified options. It is a worthy model. The use of such a model should be encouraged.

Recommendation number two is that traceability is a tool. It already has demonstrated benefits in other industries such as pharmaceuticals, automotive, high tech and aeronautics. At first, regulatory food safety-related requirements pushed more adoption of traceability systems and practices, but the business and financial benefits related to food integrity will drive and sustain its use. Many technologies already exist, but the focus has mainly been one-up, one-down. In fish and seafood that's not enough. Today, food integrity and the threat of food fraud is certainly a motivating factor, and based on our research, food integrity has more market currency today than food safety. Rewarding companies that adopt better transversal traceability practices would be a step forward. Encouraging the use of technologies like machine vision, the Internet of things and blockchain to automate the processes and take human error or deception out of the equation would be key.

Recommendation number three is that seafood businesses that are committed to maximizing the value they deliver to consumers are already using relevant, dependable and readily accessible data about their products to gain a competitive advantage and grow their businesses. While globally there has been some progress on mitigating illegal, unreported or unregulated fishing, recent information suggests that awareness of the consequences of illicit activity is not deterring offenders. Perhaps Canadians are uninformed of the problem, so building public awareness about food fraud would be key.

I'd like to thank the committee for listening to me. These are my main recommendations. I would welcome any questions the committee has at this time.

[The Chair, Liberal, Ken McDonald]

Thank you for that.

We'll now go to Madame Boivin for five minutes or less, please.

[Laura Boivin, Chief Executive Officer, Fumoir Grizzly Inc.]

Good morning, everyone.

Thank you so much for having me here today. It is an honour for me to address you.

I am Laura Boivin, president and co‑shareholder of Fumoir Grizzly for 12 years now. Fumoir Grizzly is a small business located in the province of Quebec. We currently have 95 employees and we produce several species of salmon as well as tuna, mostly smoked salmon and tartars that are distributed to most retailers and to restaurants, hotels and institutions.

We process five species of fish, including wild sockeye salmon, wild chum salmon, coho salmon, Atlantic salmon, farmed trout and tuna.

Today, I would like to highlight a few important things about Fumoir Grizzly as a fish processing company. I don't necessarily have an array of recommendations for you, but I will instead have some requests for you to consider.

First, what is confusing for the consumer is where the fish comes from. On the packaging of imported products, the origin related to the processing, farming or catching of the fish will be indicated. This is not clear and there is a lot of confusion. I myself have seen several labels on grocery shop packages that didn't have the right information on them, which means that the end consumer was misinformed.

Some labels on packages also contain claims that cannot be verified or are not verifiable. So you can say just about anything. I'm just thinking of the words “no antibiotics” or “with antibiotics” that are sometimes found on the packaging. At what stage in the company's value chain were antibiotics used or not used? There are no clear rules on this, and in my opinion, the rules can be confusing to the end consumer.

Then there is also the naming of the fish itself. In our industry, we have Atlantic salmon. There have already been advertising campaigns to inform the end consumer, but the name Atlantic salmon is not linked to its provenance, but rather to the different genetics that is specific to the Salmo salar species. It may come from British Columbia, Chile or Norway. The end consumer is not aware of this.

As for genetics, there can also be confusion regarding Pacific salmon, as a farmed salmon could have grown up in the Pacific Ocean in Chile. A wild salmon may be sockeye, king or chum. The packaging may simply state that it is wild Pacific salmon, when it could just as easily be a fish that is found in abundance in the ocean as a rare fish, with very different prices.

I would like to address the issue of transgenic salmon. I don't know if members of the committee have heard of it. We became aware of this salmon a few years ago. There was a lot of outrage from grocery shop chains that refused to sell it. The situation with transgenic salmon is unique in Canada in that there is no requirement to label it as transgenic salmon on the package, whether in restaurants, at the counter in fish shops, or wherever it will be consumed. The end consumer therefore does not know whether they are consuming transgenic salmon or not.

That being said, there are no health problems associated with transgenic salmon. I don't have a formal position on that, other than to say that it's not mentioned and that it should be addressed, in a context where we want to place importance on the traceability of fish.

In general, I will end by telling you that there are many standards that fish suppliers and processors must meet in terms of traceability. Fumoir Grizzly follows Hazard Analysis Critical Control Point, or HACCP, standards, and is also certified by the Safe Quality Food, or SQF, program and the Aquaculture Stewardship Council, or ASC. In addition, our suppliers are certified by the Marine Stewardship Council, or MSC, and by the Best Aquaculture Practices, or BAP, program. There are many rules related to traceability, and this requires integrated systems in the processing plants.

My only comment this morning is that we shouldn't add to the processing costs, which are already very high. Adding rules as to traceability, given the certification systems that are already in place, would probably add costs and not prevent us from needing those certifications.

Fumoir Grizzly submitted an application for ASC certification last week related to traceability. It has been audited and the only thing we had to change in our process was the position of the logo on our supplier's boxes. Certification with this organization will mean additional costs of 0.05% of sales volume. At the end of the day, it was found that traceability was well assured at Fumoir Grizzly.

It should be taken into account that certification bodies already exist, and we are joining them as a processing company. We need to avoid additional costs, and most importantly, we need to ensure that our existing regulations and certifications are applied to all products, including those exported to Canada.

Thank you for your attention. I would be happy to answer any questions you may have.

[The Chair, Liberal, Ken McDonald]

Thank you for that.

We'll now go to Mr. Scott Zimmerman.

You have five minutes or less, please.

[Scott Zimmerman, Chief Executive Officer, Safe Quality Seafood Associates]

Good morning, everybody. Thank you for inviting me to speak with you. I find it an honour to speak with the Canadian government, so I appreciate your time.

My name is Scott Zimmerman. I own a company here called Safe Quality Seafood Associates. We're a consultancy. I'm basically an external quality assurance and quality control person. I work for the industry, I work for FDA and I address compliance issues specific to the seafood industry.

Today I'm going to speak briefly with you folks about FDA regulations, NOAA regulations and third party requirements for traceability in the United States.

The first topic I want to touch on is a new proposed rule by the FDA that covers requirements for additional traceability outside of the “one-up, one-down” required through the bioterrorism act. This new regulation is under the new U.S. Food Safety Modernization Act, which came about in 2011 and is still being implemented. The goal of the new traceability requirements is to reduce the time needed, during an outbreak especially, to identify contaminated product. That will address one of four different core elements in FDA's new smarter era for food safety.

Going beyond one step forward and one step backward, any food that has been listed on the food traceability list, which in the case of seafood is just about every type of seafood, will require key data elements, such as temperature and traceability codes, that are collected during critical tracking events. That is especially when product is moving from one hand to another in the chain of custody. This is increasingly needed for especially ready-to-eat foods that don't have a “kill step” before the consumer opens the package and eats it.

The critical tracking events that FDA will focus on include the growing, which would include aquaculture operations, or the receiving, which would include taking raw material off a fishing vessel. The production of the food would require traceability as a critical tracking event. Different types of key data elements, such as temperature, for example, would be required to be collected at that step. Any step where raw material product is transformed would require traceability data, including shipping. FDA is going to expect all of that traceability to be collected in a sortable spreadsheet, such as an Excel spreadsheet, in order to be considered compliant.

The next traceability program I want to talk about is the National Oceanic and Atmospheric Administration's seafood import monitoring program. This is a program that's relatively new. It's required under the Magnuson-Stevens Fishery Conservation and Management Act here in the U.S. to combat illegal, unreported and unregulated fisheries or misrepresented seafood from entering the United States and entering commerce.

NOAA officers are required to conduct these audits of importers here in the U.S. and make sure that there's critical information collected at each point of movement, or the chain of custody. Currently this seafood import monitoring program is restricted to 13 imported fish and fish species groups, which means, if you look at it from a greater perspective, 1,100 unique species of fish are being traced by NOAA at this time. But there are lobbying efforts taking place here in the United States to include additional species to the seafood import monitoring program, or SIMP.

SIMP and NOAA have recognized that there are groups of importers in the United States who have maintained compliant programs. They've created a compliant importers list as a function of that. That's going to recognize those importers here in the U.S. that have demonstrated a history of compliance.

The last traceability component I'd like to talk about is not regulatory. It's voluntary. That's through third party certification. There are several different standard owners, such as the MSC, the ASC or Aquaculture Stewardship Council; the BAP or Best Aquaculture Practices; the BRC, which is the British Retail Consortium; and SQF or Safe Quality Food, just to name a few.

[The Chair, Liberal, Ken McDonald]

Mr. Zimmerman, I'm going to have to leave it at that. We've gone over the five-minute mark by quite a bit. Hopefully anything else you would like to add will come out in the rounds of questioning. All members have a copy of your opening remarks as well.

We'll now go to questions.

We'll start off with Mr. Perkins for six minutes or less.

[Rick Perkins, Conservative, South Shore—St. Margarets, NS]

Thank you, Mr. Chair.

I apologize in advance to the witnesses for this slight diversion. I'd like to move a motion:

That the committee urge the government to remove Russia from the Northwest Atlantic Fisheries Organization, cutting off another important source of revenue for Russia’s illegal invasion of Ukraine, and; that this motion be reported to the House.

[The Chair, Liberal, Ken McDonald]

Before I can ask for any discussion or take part in anything to do with that motion, we're not actually in committee business. We're in the study and we have witnesses here. For a motion to be introduced at this time, it has to be agreed to by unanimous consent.

[Bobby Morrissey, Liberal, Egmont, PE]

Mr. Chair, on a point of order, maybe if he would delay it to the last half hour of the meeting, we could have a discussion then so that we're not taking time away from the witnesses now.

[Rick Perkins, Conservative, South Shore—St. Margarets, NS]

That's fair.

[The Chair, Liberal, Ken McDonald]

Okay.

You're up for your questioning.

[Rick Perkins, Conservative, South Shore—St. Margarets, NS]

Thank you, witnesses.

This has been a fascinating study. I think we all agree on that. It's been pretty enlightening about the situation.

As committee members know, I've been focusing a bit on the consumer side of it at the point of sale. I particularly would like to welcome a fellow Nova Scotian, Professor Charlebois. My first question is for him.

We've heard a lot of testimony about testing of the accuracy of the labelling at retail. You mentioned the 10% to 15% of fish and seafood is mislabelled at the retail level and up to 40% in restaurants. We've had similar testimony from Oceana and other witnesses.

Let's focus on the retail side of it. CFIA has very minimal requirements for three basic things they require on the packaging. What additional items do you think should be mandatory on packaging for consumers?

[Dr. Sylvain Charlebois]

I think Ms. Boivin alluded to this issue of provenance. I think it's important, especially right now. A lot of people are looking for local foods. They would be reassured if the information and the data on packaging and labels is actually accurate in giving information about where the product is actually from.

This whole issue of species is quite confusing. I really enjoyed Ms. Boivin's testimony because I think it speaks to how confused consumers are. There are so many species out there, it gets confusing. It also gets confusing for retailers.

Going back to Ms. Boivin's testimony, she did talk about the genetically modified salmon. We saw many retailers, including Sobeys and Loblaws, boycotting the AquaBounty salmon, but that doesn't mean they're not selling it. They may actually be selling the product as an ingredient embedded in other products they're selling at retail.

This is why I think it's important to really start with the consumer and figure out exactly what kind of information they need at the point of sale and then work your way back to the source to make sure the data actually flows through the entire process.

[Rick Perkins, Conservative, South Shore—St. Margarets, NS]

It's been suggested by some of the other witnesses that we should include things like the scientific name, the gear with which it was caught and the location, perhaps, where it was caught. Other information around processing should be mandatory.

What are your views on that?

[Dr. Sylvain Charlebois]

It is a good point. Metro in Germany, which is equivalent to our Costco in Canada, would offer a QR code. You can use your phone at the point of sale to scan the QR code and you will know exactly who caught the fish and when, when it was processed and what ingredients were added to the product before it was sold at retail. All that information is given to the consumer. Whether they want it or not, it's actually available.

[Rick Perkins, Conservative, South Shore—St. Margarets, NS]

Maybe I can pose this to both Professor Charlebois and Mr. Zimmerman.

We've had a lot of discussion about the European standards and how they've evolved, and the United States's standards appear to be a little different. If we were to make recommendations to improve where we're going with our labelling at retail and traceability, could it be done by assessing or taking up the U.S. or, more importantly, the EU standards, while at the same time reducing the burden? We also have yet a third standard: the Canadian standard. Which one would you recommend in particular? We have heard that the European Union's standards are state of the art.

[Scott Zimmerman]

My wheelhouse is U.S. requirements, so I'm not going to say that I know much about Canadian or EU standards. I do know that there's a wealth of resources for consumers and regulators to turn to at the FDA to get that information. There are videos and labelling guides.

We've been at it for a long time in the seafood industry. We like to think the guidance published by the FDA.... I don't speak on behalf of the FDA, but I do enjoy their materials and find them consumer friendly. I teach those materials on a monthly basis for the Association of Food and Drug Officials. I find them very easy to digest. I think there's a lot to be gained by going through the FDA's website, along with their guidance documents. I think it's quite clear what is expected of the industry here in the U.S.

[Dr. Sylvain Charlebois]

If I may—

[The Chair, Liberal, Ken McDonald]

I'm sorry, Mr. Charlebois, but the time has expired. Hopefully somebody will get back to some similar thoughts and you'll be able to respond, or you can submit a response in writing to the committee.

We'll now go to Mr. Cormier, for six minutes or less, please.

[Serge Cormier, Liberal, Acadie—Bathurst, NB]

Thank you, Mr. Chair.

I thank the witnesses for being with us today.

Mr. Charlebois, it's nice to see you in person. I read your opinions religiously in L'Acadie Nouvelle, in New Brunswick.

You made my job easier, because I wanted to ask you what your recommendations were for the committee, and you made three.

I would like us to talk more about the rules that are being put in place and the new certifications. The famous case of right whales being hit by ships in the Gulf of St. Lawrence has had a certain effect. I wouldn't say it was catastrophic, but it forced us to adapt.

You mentioned the new MSC standard, which has been in place for several years. Industry players seem to be saying that it is important to keep it, but that it has not had any effect.

Do you agree with the industry players that abandoning this certification would have no effect in terms of crab or lobster?

[Dr. Sylvain Charlebois]

In my opinion, Mr. Cormier, the real problem is not necessarily the companies that are seeking MSC certification, but rather the ones that are not seeking it.

I think it's a shame that companies like Ms. Boivin's, for example, follow the rules and comply with good practice, while others do not. Unfortunately, it takes police and surveillance to ensure that we get rid of companies that are doing great damage to the reputation of the industry.

I was talking about food fraud earlier and I want to emphasize that very much this morning.

[Serge Cormier, Liberal, Acadie—Bathurst, NB]

I wanted to talk about food fraud a little later, but you can continue in this direction.

[Dr. Sylvain Charlebois]

Fraud is a really big problem. It's not the compliance-minded companies that are causing it, it's the companies that are not being monitored.

I have visited many companies. The ones that follow the rules are not in a position to report anything. Yet that's why—

[Serge Cormier, Liberal, Acadie—Bathurst, NB]

For the industry, it is important to continue using the MSC standard.

Is this correct?