Subcommittee on Food Safety Committee on June 8th, 2009

[The Vice-Chair, Bloc, André Bellavance]

I would like to welcome you to today's meeting.

Usually, Mr. Miller chairs the meeting. He will be with us in a few moments. He asked me to replace him so that we can start this meeting on food safety.

The second witness has not yet arrived, but since the meeting is supposed to begin at 4:00 p.m., we will begin.

Welcome, Mr. Chambers. Mr. Albert Chambers is the Executive Director of the Canadian Supply Chain Food Safety Coalition. You have 10 minutes for your opening remarks, and after that, the committee members will have an opportunity to ask you some questions. I'll just also mention that you do have access to interpretation.

[Albert Chambers, Executive Director, Canadian Supply Chain Food Safety Coalition]

Thank you, Mr. Chairman and members.

Thank you for inviting the Canadian Supply Chain Food Safety Coalition to appear during your hearings on this important subject.

The coalition was formed in December 2000 and incorporated in 2007 to act as a single, strong voice for industry along the food chain, together with the public and government, on industry-wide food safety issues. Our membership is composed of the national, provincial, and regional associations involved in the agrifood industry and the individual companies that provide services to that industry.

As you can see from the membership list attached to our submission, we represent organizations whose members encompass every link in the supply chain, from input suppliers through to primary producers, transporters, processors, manufacturers, importers, and final marketers at the export, retail, and food service stages.

Our mission is to facilitate, through dialogue within the food industry and with all levels of government, the development and implementation of a national coordinated approach to food safety to ensure credibility in the domestic and international marketplaces.

Over the past eight years we have been actively involved in consultations with ministers and officials at all levels, and in intra-industry discussions, about the future shape of Canada’s food safety system. We see the work of your subcommittee as a valuable opportunity to continue this work and to realize our vision: that Canada's agriculture, aquatic, and food industry will have a world-class reputation for producing and selling safe food.

In March of this year the coalition completed a year-long project to develop a national strategy for industry-led food safety programs. Copies in French and English have been circulated to you prior to this meeting.

The participating organizations, members, and non-members of the coalition who worked on this strategy determined that it should be grounded in a set of four guiding principles.

The first principle is that food safety is a shared responsibility of all participants in the supply chain, all levels of government, and consumers.

Our second principle is that governments at all levels, the agrifood industry, and other stakeholders should foster and facilitate the development of an integrated and coordinated and national approach to food safety policy and regulation, based on sound scientific risk assessment and risk management principles and international standards.

Our third principle is that industry and government food safety initiatives should encourage the implementation of HACCP and/or HACCP-based food safety systems by businesses all along the supply chain.

Finally, our fourth principle is that food businesses, governments, and other stakeholders have a responsibility to adequately resource and proactively manage, update, maintain, and continually improve their individual and collaborative food safety systems and food safety initiatives.

I'll touch on each of these principles in brief.

Businesses involved along the agrifood supply chain clearly recognize that they have a responsibility for food safety, which they share with governments and consumers. This is not a recent recognition or awareness; Canadian agrifood businesses and their associations have consistently and continually advocated this approach, especially over the past two decades of rapid change in the Canadian and global approaches to food safety. We ask you to endorse this principle of shared responsibility in your final recommendations.

We fully recognize that under our constitution, the jurisdiction for food safety is divided amongst the senior levels of government, and in some cases is delegated to the municipalities or other agencies within provinces and territories. However, our members and the agrifood businesses they represent firmly believe that Canada should have one national approach to food safety. Canadians, no matter where they reside or purchase their food, are entitled to the same level of assurances about its safety—assurances that should be based on common standards and expectations.

A corollary of this statement is that agrifood businesses within each link of the supply chain should be asked to operate according to common standards and expectations within and amongst the responsible jurisdictions. Our expectation of imported food products should, as a matter of course, be the same as our expectation of our national system.

Our national strategy sets out some very clear goals with respect to this principle. They include the need to revise the federal-provincial-territorial vision of a national approach to food safety, last looked at in 1994, based on an agreed set of principles. There is a need to establish a national decision-making mechanism for food safety policy and regulation in Canada. We need to clarify the role and the scope of national codes, industry-led food safety programs, food safety objectives, and other food safety requirements, and integrate food-safety-related discussions across departments within each government. We also need to open the lines of communication between government and industry groups in order to encourage collaboration on the future evolution of food safety policy, objectives, systems, etc.

We are aware that the federal, provincial, and territorial officials have been discussing the development of a national food safety strategy since at least 2003. In February of this year the agriculture ministers requested a food safety action plan. We are also aware that this national approach has been taken in Australia and within the European Union, and it is now under very active discussion in the United States. Models and best practices exist within federal systems with joint jurisdiction. These can be studied and perhaps adapted to our needs.

Therefore, we ask the subcommittee to strongly endorse this principle, the establishment of a national coordinated approach to food safety, in your report and make clear recommendations about the process by which it could be achieved.

Starting in the early 1990s, Canadian agrifood businesses and their national associations have cooperated with governments to develop and implement HACCP and HACCP-based food safety systems. You are aware that Canada was a pioneer in the field of HACCP and a major contributor to the development of the international approach through the Codex Alimentarius Commission. HACCP food safety systems have been implemented in federally registered establishments, in some provincial registered establishments, and in larger, more complex non-registered establishments. Canada has also been a pioneer in the development of HACCP-based food safety systems for micro, small, and medium-sized businesses that do not have the resources to develop and implement a site-specific HACCP food system.

Over the past 15 or so years we have seen the members of the coalition and other industry associations work closely with the federal, provincial, and territorial governments to develop and implement national HACCP-based food safety programs for almost every segment of the supply chain. For example, we now have 22 national HACCP-based, commodity-specific, on-farm food safety programs covering approximately 99% of primary production. For other segments of the supply chain, industry associations have developed or are in the process of developing and implementing at least 14 national programs.

The development of these initiatives has involved significant investments by individual agrifood businesses, by their industry associations, and by the federal government. So successful has this collaboration been that governments have renewed their funding initiatives under Growing Forward and the recently announced Canadian integrated food safety initiative for some of the key components of that collaboration.

Industry-led HACCP and HACCP-based food safety systems are now an integral part of Canada’s food safety approach. They are a necessary complement to the capacity of governments at all levels to engage in direct inspection and audit activities.

Our strategic document strongly endorses continued investment by agrifood businesses, their associations, and governments in both the implementation of these systems and in their continuous improvement. We ask you to endorse this concept--the implementation of HACCP and HACCP-based programs by businesses all along the supply chain--in your report.

Establishing principles is a first step. Developing the tools that are needed for a coordinated national approach is clearly a challenge, but a manageable one. But ensuring that these systems are adequately resourced, proactively managed, updated, maintained, and improved will be the real test of the Canadian approach to food safety.

Our national strategy sets out a number of goals and actions for industry, for other stakeholders, and for governments in this area. They include promoting awareness of the Canadian food safety programs; strengthening Canada’s food safety training and auditing infrastructure; increasing the pool of qualified food safety personnel; establishing quality consistency across food safety specialists, including consultants, trainers, etc.; and strengthening federal, provincial, and territorial support for industry-led food safety initiatives. We ask the subcommittee to endorse this principle as well and include recommendations concerning the resourcing of government food safety initiatives and concerning the development of the infrastructure needed to ensure that industry's activities can be updated, maintained, and improved.

In conclusion, the Canadian Supply Chain Food Safety Coalition would like to thank the subcommittee for asking it to make this submission. Your inquiry into food safety comes at an important time in the evolution of the Canadian system. As we have discussed, governments--federal, provincial, and territorial--are actively considering new food safety initiatives. As parliamentarians you are expecting amendments to the Food and Drugs Act to be introduced, I assume, in this session. Your recommendations will have a major impact.

We ask that you carefully consider our recommendations and the detailed contents of the national strategy for industry-led food safety programs, which we have tabled with you. They represent a strong consensus on the part of the agrifood supply chain and of our members about the future direction of Canada's food safety system.

As a final point, we would like to say on behalf of our members that the coalition is ready to engage further with this subcommittee or with other committees of the House as changes are made to the Canadian food safety system.

Thank you very much.

[The Vice-Chair, Bloc, André Bellavance]

Thank you, Mr. Chambers.

I'd like to mention that in the French version of your speaking notes, you say that appendix A includes the list of your organization's members. I believe that we have that list only in English; the French version does not appear. If you could provide that to the clerk, please, we could include it with your document. It's not a serious matter, but—

[Albert Chambers]

My apologies, Mr. Chair.

[The Vice-Chair, Bloc, André Bellavance]

No problem. I just want to make sure that we receive it.

Mr. Anderson.

[David Anderson, Conservative, Cypress Hills—Grasslands, SK]

We don't have that list in our paperwork, or I don't have it in mine, so I would appreciate it if we could get it in English as well.

It may be just a problem with distribution.

Thank you.

[The Vice-Chair, Bloc, André Bellavance]

Our research analyst has a copy of that, put if you could forward the list of your members, it could then be distributed to the committee members.

Thank you very much.

Our next witness is Mr. Brewster Kneen from the Canadian Health Coalition. Welcome to our committee. You have 10 minutes to give us your comments, and then we will move on to questions.

[Brewster Kneen, Representative, Canadian Health Coalition]

Thank you very much for the opportunity to be here and to address you on behalf of the Canadian Health Coalition.

I won't say very much about the coalition. It's national, largely voluntary, has a small staff, and is very active in several provinces, particularly Ontario and British Columbia, in addressing issues of public health in the broadest sense.

I've just been asked to fill in for Michael McBane, who is elsewhere today. I am an independent writer, author of half a dozen books on food, agriculture, genetic engineering, and corporate control. My wife and I have published for 30 years now The Ram's Horn, a monthly newsletter of food systems analysis.

Many issues concerning food safety have been in the news, of course, in recent years. I am sure you have considered and heard about many of them, from bovine spongiform encephalopathy--a still-unsettled controversy, I should say—to listeria, salmonella, bird flu, and the current so-called H1N1 swine flu pandemic.

It's very tempting to get drawn into a discussion of particular diseases and how they have been dealt with or not dealt with. I don't intend to do that, because I think they are all manifestations and consequences of the way we have allowed our food system to be organized and constructed. To look at particular diseases and public health issues one by one strikes me as kind of like that story about picking babies out of the water, out of the river, without ever asking who's throwing them in.

Public Safety Minister Peter Van Loan summed up very simply the issue that I wish to focus on when he tried to explain why the government decided to shut down six prison farms: “...it's simply a fact that the type of agriculture practised on the prison farms is totally unrelated to modern, high-technology, capital intensive agriculture.”

While Mr. Van Loan's statement may be true, it is not modern, high-technology, capital-intensive agriculture that actually feeds most of the global population, either today or at any time. In fact, it is a growing diversity of foods for the local population that is actually how people feed themselves. The prison farm style of agriculture, which supplied the prison population and the community, is closer to this global practice than it is to the high-tech industrial agricultural system that Mr. Van Loan pointed out.

The CFIA was created in 1997. I remember the discussions about its creation and all the issues therein. I would say that it has remained true to its not explicitly stated mandate to serve modern, high-technology, capital-intensive agriculture. Therein lies the source of the problems of food safety and public health that are being investigated by this committee. It is the structures and practices of industrial agriculture and food processing and distribution that are the source and multipliers of the public health problems the CFIA attempts to address but is handicapped from doing because of its mandate, which is to promote and protect this industrial food system. Instead, it has sought to polish its public image by trying to clean up, through HACCP and other means, and more and less regulate out of existence, small-scale, local, and regional food production, processing, and distribution in favour of large-scale, centralized, export-oriented corporate agribusiness.

This is unequivocally illustrated by the CFIA's treatment of small-scale local abattoirs, or its outlawing of the sale of fresh eggs at farmers markets unless they have been through the grading process, which has been mandated for eggs produced in 60,000-bird layer factories. The same thing could be said of pork, beef, and everything else.

The fact is that diseases like avian influenza are the products of intensive, large-scale, industrial poultry production, whether in Malaysia or in Canada, and not backyard flocks anywhere in the world. Just ask the farmers of the Fraser Valley of British Columbia.

Bacteria and viruses, such as listeria, salmonella, BSE, avian flu, and swine flu, are all virtually inevitable products of large-scale factory production of meat, eggs, and even vegetables. Monocultures of any sort invite attack by opportunistic bugs. In addition to monocultures are the conditions of intensive production, as in poultry, swine, and feedlot beef, and the conditions are ripe for the spread of all kinds of unwelcome guests.

No amount of downstream sanitation and regulation is going to alter this condition. If public health, efficiency, and sound ecology were to be the mandate of an agency charged with protecting and enhancing the health of Canadian people and the food we eat, this agency would have to call for a radical deconstruction of our current industrial production system and its control by a handful of giant corporations.

In each and every sector of the food system, from seeds to supermarkets, there are essentially three corporations that rule the roost, and these corporations are required to serve the interests of their shareholders, not the public. That's their legal, fiduciary responsibility, after all. It is the interests of these giant corporations that are served and protected by Agriculture and Agri-food Canada and the CFIA. This is what modernization of the seed regulations, streamlining of the regulatory process, removing the obstacles to innovation, and self-regulation are all about: corporate wealth, not public health.

Farmers and gardeners growing food for themselves, their neighbours, and their local markets are not going to poison themselves and their customers. They are highly unlikely to be breeding diseases. They would quickly be identified and soon be out of business if they were. Trust, after all, is the foundation of any functioning economy.

Factory farms and giant meat factories can write off the millions of dollars lost as a result of a disease outbreak caused by its products and carry on as before, with only some modifications to its operations as requested by the CFIA--another inspection process or two--and the CFIA no longer has the capacity to ensure that its rules are being followed. The only question is, when and where will the next disease outbreak occur?

I suggest very strongly that it's time--well past time, in fact--for a radical deconstruction of the global industrial food system for the sake of public health and the environment around the world. It is time to create a public agency dedicated to ecological farming, including animal and plant biodiversity, healthy food, food production for local and regional markets--not export--and the assurance of adequate nutrition for all. A genuine food system, in other words, dedicated to public health.

l realize this is a big challenge, but it is time for Agriculture Canada and the CFIA to get out of the corporate bed. It is time to make healthy soils, clean water, and ecological farming the basis of our food and agricultural policies. The problems currently identified as issues of food safety would largely disappear, and rural communities and local economies would thrive as they provide healthy food for all of us. It's a big but essential challenge that l am presenting, I realize, but I think the times call for it.

I would be pleased to discuss this further with anyone, and I thank you for the opportunity to present this to you.

[The Vice-Chair, Bloc, André Bellavance]

Thank you very much, Mr. Kneen, for those remarks.

Now we will begin the first round of questions and answers.

Ms. Folco, you have seven minutes.

[Raymonde Folco, Liberal, Laval—Les Îles, QC]

Thank you, Mr. Chairman.

I would like to congratulate the two witnesses, Mr. Chambers and Mr. Kneen, for their very succinct presentations. My remarks are particularly intended for Mr. Chambers, because he touched upon a number of topics that I was already intending to ask questions about.

Mr. Chambers, in your presentation you did not talk about the federal government, but it's clear that you see very clearly that the federal government has a responsibility toward the people of Canada. Within the framework of this responsibility, you mentioned a national inspection system with various protocols. Well actually, you did not mention protocols; I'm the one who is talking about protocols. I would like to hear your opinion on the issue of standardized protocols that would have to be complied with throughout Canada. I think that's somewhat related to what you said in your presentation.

In addition, there is the possibility of having a more diversified system within this area of federal responsibility, perhaps an alternative that would take the form of a diversified system that would be more specifically in keeping with the needs of each region. Such a system would be more reflective of the local processes of food production. I'm not asking you to recommend either one option or another, but rather, I'd like to know if you see a completely standardized system, or more of a standardized system that does have some regional variations?

[Albert Chambers]

Thank you, Mr. Chair and honourable members.

I would think that the best starting point for our answer, from the coalition's perspective, is that we are realists, even though we have put some very challenging suggestions before the committee and before governments about having a national coordinated approach. I don't expect to have any hair left, perhaps, when we can get all the governments in Canada to agree on a single approach to food safety.

[Raymonde Folco, Liberal, Laval—Les Îles, QC]

It depends on which side of your head, I think, Mr. Chambers.

[Albert Chambers]

Well, I've been growing this one for a very long time and losing this one for almost as long.

What we're looking for is a commitment on the part of governments to move towards that kind of an approach. There have been various initiatives in the past where governments have assigned officials to develop national codes, whether they were for horticulture, for dairy, or for retail and food service. What we saw happening then was provinces falling out of step with that objective, for various reasons. Some of them have to do with getting time on the agendas in provincial legislatures; some of them have to do with other things. But we don't see much progress down that road.

Starting with ministers of agriculture or agrifood and ministers of health, we would like to see them make that very strong comment to the principle of a coordinated approach, and secondly, then, launch a process that would involve themselves and their governments, and industry stakeholders and other stakeholders, consumers and others, in the discussion as to how to get there.

We see, as the brief pointed out, some very interesting examples as to how that could be done. Whether they would fit in the Canadian context, with all of our challenges and our history, that's another question, but I think great progress could be made down that road. In the end it probably would see some differences still remain, and whether those would be regional, that's possible, but it more likely would be provincial in that sense. What we'd like to see, though--I really don't like to use the phrase “minimum standards”--is a good, strong set of basic national food safety standards and approaches. That way, industry all across the country, whether farmers, input suppliers, manufacturers, or retailers and food service, would be able to say, “Okay, this is what we're trying to get to”, and everybody is trying to get there.

[Raymonde Folco, Liberal, Laval—Les Îles, QC]

Mr. Kneen, if I've understood your answer, what you are presenting us with is a complete overhaul of the ??agri-food?agrifood?? and food safety system throughout Canada. Unless I'm mistaken, you are showing us a completely different philosophy toward the entire food safety system.

How do you see that federal government's role in relation to the recommendation that you have just made?

[Brewster Kneen]

Thank you for your question. It's very much to the point.

I should say that my wife and I have farmed for 15 years. We raised our children on the farm. We raised sheep and lambs for the market. Very early on--we started with no experience--I got the local agriculture representative to come out and I asked him what we should do. He said we should grow corn. Well, we happened to be farming on glacial till of Nova Scotia, and the last thing you want to do is stir up those rocks. But that was a uniform program for the province. Corn was what was on the menu that year. So it really didn't matter where you were.

That was a pretty good lesson for us, a good introduction.

But we've seen, over the years, the movement back from agriculture of the federal government. Now if I were to ask an agriculture rep for some advice, I would get some consultant who might work for Cargill or one of the other agribusiness industries, who, obviously, would have a product to sell. I think that sums up where we've gone in 30 years.

So the government, in a sense, has privatized any public responsibility it had for agriculture. It's now engaged in plant breeding, or across the board trying to.... If you want to do research, you have to have a corporate partner. This means that it's the corporate agenda that is followed in every instance.

What we're calling for is actually a federal agricultural policy, an agriculture and food policy that has as its basis the health and welfare of the Canadian people and the economy, based on local production for local consumption, and reducing....

My first book, actually, talks about the characteristic of our industrial system as maximizing the distance between where your food came from and your mouth. And what we're seeing now is a move across the country with local food to reduce that distance, to shrink it back.

The federal government has a tremendous responsibility that it needs to take up on behalf of the Canadian people to redesign.... I shouldn't say redesign, because I think we do have to start all over again and rethink what agriculture is all about. Their current policy is about export and balance of trade, not public health. I think that's fundamental. That basic mandate needs to be reorganized.

It would mean shifting, for example, in plant breeding and animal science, and so on, to much stronger public support for public programs and public science, for the benefit of everybody. It would mean a different kind of education--and again, this should be directed in concert with the provinces right across the country--not to have a uniform program, rather to have programs that would meet certain criteria, standards in a sense, but that would have to be tuned, as with any farm, to the local ecology. What do you actually do on the prairies? What do you do in the Maritimes, or in the coastal fisheries in B.C., or the inland fisheries in Manitoba?

I would suggest that this would need to be done in conjunction with Health Canada. Our understanding of health has to begin with healthy food. It's interesting. Almost invariably, the people we talked to who have been through cancer treatments have switched to organic diets.

[The Vice-Chair, Bloc, André Bellavance]

Could you please finish, Mr. Kneen.

[Brewster Kneen]

It's amazing. They've discovered, as we all know, that cancer is an environmental disease. And what better place to start than with healthy food. But you can't have healthy food if you contaminate it all with agro-toxins and genetic engineering.

It's right across the board. I'm sorry, it's not a simple answer. But I want to indicate what I mean by that.

[The Vice-Chair, Bloc, André Bellavance]

Your time is up. Thank you.

Mr. Chambers, I am going to continue along the same lines as Ms. Folco's questioning about national policy.

We have noticed that during and after crises such as listeriosis or bird flu, which unfortunately happened here, government authorities blame each other. The federal side says that the provincial government should have done something or other, and did not. Conversely, the provincial side may put the blame on the federal government. I think I follow your idea about coordination, but as regards national policy generally, we always have to be very careful about respecting areas of provincial jurisdiction—here I am expressing my own view, which perhaps you share. It is wrong to think that the federal government always has the one and only right solution. I will give you an example of what I mean, and ask for your comments.

Because of its agri-traceability system, Quebec has been ahead of other jurisdictions for a number of years. I do not mean by that that we are better at everything. Other provincial governments may also be ahead in other areas. When we talk about national policy, I always hear, and this is shared by quite a few people in Quebec, that at some point, there may be a tendency to set standards based on the lowest common denominator. A province, in this case Quebec, that has developed a much more demanding approach, will not want to move backwards.

[Albert Chambers]

Mr. Bellavance, I think you're quite right, that we have a very uneven system in terms of food safety across the country and in terms of traceability at this point as well.

What the coalition is seeking is opportunities for governments and industry and other stakeholders to come to a consensus about where we should be trying to get to in the future. It may be that the best practices are currently enshrined in a provincial program in a particular province, or they may be best practices at the federal level already, or they may be best practices in what industry is already doing, which is ahead of federal, provincial, or territorial governments.

So we'd like to see that consensus-building, decision-making process, but you also have to understand that many food businesses function across provincial boundaries, and what they find themselves faced with is different sets of requirements in different provinces. Some may be industry-leading, some may be lagging behind, and others may be quite different. They may achieve the same objective, but they may require the company to do quite different things in order to get there, which means that those companies have to retool and redesign their food safety management practices in order to meet these different jurisdictions.

And it's not just an issue between provinces and the federal system. It can also be a matter of concern within provinces, where at some levels, in some provinces, jurisdiction has been devolved down to local regional authorities and you can, so I'm told by some of my members, without actually leaving greater Toronto, cross between food safety requirements on one side of a street that are different from those on the next side of the street.

So our desire, from an industry perspective—and this goes from the farm level all the way through to the final marketers—is to have as close to a consensus as we can on what those standards should be and the opportunity to meet them on an equal playing field across the country.

[The Vice-Chair, Bloc, André Bellavance]

But you are not saying that when it comes to managing a crisis, it is important that all the players be involved, that no standard be imposed on one jurisdiction by another. In fact, my impression from your opening remarks was that you wanted all stakeholders to have a say and to assume certain responsibilities.

[Albert Chambers]

We certainly want that, and we certainly want a high degree of coordination and communication in times of crisis. Industry has seen some very good practices on the part of government in certain crisis situations in which there has been very good communication, but in other situations, as the case studies of these kinds of things will no doubt show, there has been less than optimal communication between governments and with the industry players. There are challenges there.

From our perspective, I believe the members would say that we see an opportunity to create best practices for all levels of government--and for industry and consumer input--that would allow us to get through those crises in a much better fashion. Let's be clear that when we talk about national, we're not talking about an imposition by, say, the federal government on the provinces. We're talking about creating a new mechanism. We're not prescribing what that might be. The Australians, who have a similar jurisdictional structure for divided jurisdiction, went out and created a whole new set of decision-making mechanisms into which they all have input, and they all participate, and the standard is arrived at. Industry and others have a formal role in that process as well. We're not saying we could move that directly here, but we're saying we should at least have a look at those kinds of mechanisms so that we can have national approaches in a federal system.

[The Vice-Chair, Bloc, André Bellavance]

Thank you very much.

Mr. Allen, for seven minutes.

[Malcolm Allen, NDP, Welland, ON]

Thank you, Mr. Chair, and thank you to the witnesses.

Mr. Chambers, following your line of thought around some sort of a national standard that's cooperatively achieved--I think that's what you are saying--through some sort of consensus-building, bringing together all of these players from different jurisdictions in a political context, there may indeed be divergent viewpoints on what the standard should be when it comes to the industry, because you represent an industry that's quite divergent. There are those who might be at the processing end and those who might be in the retail end. It would seem to me they would have divergent views when it comes to finding a consensus, although that is a lofty goal.

It leads me to my first question. Discounting the fact that we have that many players, if we simply break it into two jurisdictional components, one being the industry and the other being the regulator, which we can call either level, or levels, of government, when a dispute comes about in your consensus model, who gets the final say?

[Albert Chambers]

First of all, I'll deal with the issue of the consensus model.

I've been working in food safety with various associations and governments for almost 20 years now. I have seen remarkable consensus achieved within industry and within groups that represent large and small players. Occasionally, when government officials are allowed out with enough leash to actually come to a consensus with industry, there has been remarkable consensus on what needs to be achieved.

It's not only consensus, but it's based on the science that's there and on internationally accepted tools, in terms of risk assessment and risk management, and the use of standards. I think we can come to those. Then each jurisdiction has the responsibility, if we have that kind of a standard, to make sure that it's enforced within its jurisdiction. The final decision then in terms of enforcement rests with the government that's responsible. It also rests, obviously, in terms of compliance, with the individual food businesses.

We're looking for an opportunity to have consistent standards across the country that can be reached by small, medium, and large-sized businesses that are using the most modern tools, but not to have different rules in different provinces that have no scientific basis.

[Malcolm Allen, NDP, Welland, ON]

It always intrigues me when folks come before us. Everyone talks about a science-based food safety system and everyone leans on HACCP in a lot of ways, in the sense of that being...I don't want to call it the crutch, but it seems to be the support mechanism by which they say this is a science-based system.

We had a witness here last week who talked about systems and systems analysis. In fact, that's what he did for a living for a long time. He was probably hired by many of your members over the years to actually come in to look at their systems. He talked about how systems fail.

This overreliance, in my words, on this science-based system gives one, in my estimation, a false promise in a lot of ways, in the sense that simply because it's science-based, that makes it work. Let me just point to this HACCP system, which has what they call a CVS piece to it, a compliance verification system, which was run out as a piece of the model that all accepted. In fact, I would suggest that members of your coalition were probably quite keen to do so, and yet they ran it out as a pilot and no one ever verified if it worked.

Now, I took science in university, but I'm not a scientist by any stretch of the imagination. It seems to me that if you're going to have a system that you try and it is supposed to give you a certain result, it's like the hypothesis you used to get when you started out to do an experiment. You started out with a hypothesis, you had a methodology, you did the experiment, and then you verified it and came to a conclusion. But if you leave out the verification, how do you know it worked?

If you're talking about science, and if part of your science-based program is to verify, but you don't ever find out whether the system that talks about verifying actually indeed works, do you really have science? Do you have a science-based system or do you have a system that really has the name “science-based”? So everyone out there who hears the terminology goes, “Oh, it must be safe because it's about science.” In reality, what you have as a system is a shell with nothing inside it.

How do we get to the point where we actually build the system, where everyone says this is how we do it, and then we verify it and we all agree upon the verification of it, so that we indeed have a science-based system that truly is based on science, not on someone's wishes?