That is an excellent question.
I agree with you that these lessons learned should span the industry and the government, and we should look at what those lessons were prior to this. Maybe it would be helpful if I described what the protocols were prior to 2008 versus what they are today. That contrast would help illuminate the response to your question.
As I articulated in my opening remarks, prior to 2008 there was no requirement—zero—to have an environmental testing program inside a processing facility for ready-to-eat foods. Now, I respect the fact that it's possible to say, well, that's an element of deregulation. But I don't think that's an accurate or fair characterization, because that regulation never existed. It never existed and was cut; it never existed and was reduced: that regulation to have an environmental monitoring program never existed.
In the face of that, at the Maple Leaf facility we had an environmental monitoring program. We did have one of those. We were testing at the rate of 3,000 samples per year. We had our own “40 Steps to Food Safety” operating plan. We spent over $20 million on capital, including biosecure access, and we had third-party audits--but against the backdrop of no environmental monitoring program in place.
When there's no monitoring requirement--that was the expectation established not by a government but by industry and the government since the beginning of the food processing industry centuries ago, meaning never--then that becomes the foundation of that expectation. No amount of inspection, higher or lower, would have changed that outcome.
I think there are important policy questions here. There are important policy questions around the role of inspection, around the role of regulation, around product testing versus environmental testing. Those are very important questions. But if you want to go to the exact cause of this outbreak, it was not about a lack of inspection. It was not about a lack of product testing or a lack of inspectors. It was about a failure to analyze test data that we weren't even obligated to collect--a failure on our part to analyze that data and look for root cause analysis, to investigate and follow up on individual trends, to look for patterns, so that we could find the bacteria that we couldn't see inside these facilities and end up with a different result. So it was more a failure to analyze those findings for root cause and a failure of those protocols than it was a failure of inspection, per se.
We believe the CFIA should have, as they're now implementing, the new listeria policy as part of a new mandate. Now, that's not to say that there aren't very important issues in there for this committee to investigate for food safety, as Mr. Easter says, for the benefit of all Canadians and the whole industry. There are important questions in there, moving forward. But if you want to get down to the root cause, to what caused this, we don't believe that was one of them.