Subcommittee on Food Safety Committee on April 29th, 2009

[The Chair, Conservative, Larry Miller]

Thank you.

You time has expired, Mr. Bellavance.

Go ahead, Mr. Allen.

[Malcolm Allen, NDP, Welland, ON]

Thank you, Mr. Chair.

Mr. Holley, I think what you articulated, unfortunately, is what most Canadian consumers, who aren't as well versed as you and Dr. Usborne are, think is actually in the system and that it's doing what you've suggested it ought to do, but what, I would suggest—again, perhaps putting words in your mouth—you're saying it isn't doing at the moment.

I agree with you, by the way, about traceability and recall. That is after the fact. We're trying to go find something that's occurred and where it came from, so we can actually tell folks they shouldn't eat that item. We saw that with Maple Leaf Foods, where we absolutely had to wait until we found out the exact plant. I'm not so sure we had to wait exactly that long, but that's a debate for another day.

So if consumers think the system actually does what you've just said it does not, it raises the question of how many questions and how loud a voice should Canadian consumers be raising about a system that, according to you, is not nearly as safe as what they're led to believe it is—or indeed in which they actually have a belief?

I say this because the system really is based, I believe, and I think consumers believe the same thing, on a matter of trust that's built up over a period of time. At one time, it might have been the corner butcher or the corner grocer—and, as Dr. Usborne said, bigger isn't always better. But we are now faced, unfortunately, with a situation where we have huge manufacturers of food, as I call them, because places like Maple Leaf Foods truly are manufacturing facilities. Their end-product simply is food that we consume. These are huge places; they aren't the corner store that we once had a lot of faith in. And we don't have that sense any more.

If you could speak a little more to that, I'm going to allow you to have some more time to talk to that sense of trust and faith of Canadian consumers. Is it misplaced?

[Richard (Rick) Holley]

I don't think it is. Whether they're small or large companies, these companies are in business to stay in business. In those cases where they're either federally or provincially registered plants, they're working with food safety programs that are founded on the basis of experience, and it's in their best interests to do so. There is always going to be an undesirable element that is going to want to cut corners, but it's in the companies' best interests to operate these programs so that the products, at the end of day, are not going to make people ill. I think Mr. and Mrs. Consumer can have a reasonable level of confidence that those in the industry who are in the business to stay in business—who are, by and large, almost all of them—are doing things to the best of their ability.

I express that confidence publicly, but there are going to be accidents that occur. There has been over the past 15 to 20 years an evolution in terms of the organisms causing these problems. Now, I don't know if this has been spoken of by any of the witnesses you've called in the past, but if you take a look at the food-borne illness statistics, such as they are in Canada—and they are woefully incomplete—you will see there's been a major change in the organisms causing food-borne illnesses. We don't see the frequencies of illnesses being caused by staphylococcus we used to, but we know why. We know it's because we're using better refrigeration systems; they're available to us now and the industry does use them. This organism, quite unlike listeria, cannot grow at refrigerator temperature. But guess what we've done? We've replaced the organism with listeria, an organism that's perfectly adapted to growing in our meat plants. So we have to address that. I'm confident we can do that as we move forward.

But if rules and regulations are brought in to demonstrate that government is doing something, and little other than that, it is very, very wrong. That's my concern, because we're faced with a situation where if you take a careful look at those new listeria guidelines with respect to end-product testing, we're going to see more of these regulations come down in the fall. There's a working group with industry that's making new regulations for non-food-contact surfaces. Those are walls and ceilings, folks, in the whole bloody plant. Yes, you're going to find listeria. Well, I'll tell you right now that you're going to find a lot of other organisms that mimic listeria biochemically—and those are the tests that you use to find them. So it's just going to be a quagmire. We're going to be caught up in circles of analysis, and the food is going to be rotten before we can get it delivered.

I think this kind of activity is going to disenfranchise, or invalidate, or make industry distrust HACCP. I think HACCP can work. I think these food systems that we have in place can be improved so they do deliver what they promise. They don't always deliver what they promise, but I think they can. But sure as heck, if we start testing end products and swabbing anterooms for listeria monocytogenes, the guys in the plant are going to say “Here comes the inspector, and he doesn't know sweet diddly”. That will be a loss of confidence, and that is what's happening in the United States of America, folks. So if we want to emulate them, let's just go forward and do it. But it's a waste of time.

[Ron Usborne]

I'd just like to add that we have to put more effort into training our plant people, too, in human resource development, as I talked about in terms of culture, because that's what's going to get the job done. That takes place before the end product goes out the door. Everybody has a responsibility in sanitizing, cleaning, and checking how the product is handled, how they dress, and whether they wash their hands or not, and whether they come to work sick. But employees have to be trained and be told why what they have to do is important.

[The Chair, Conservative, Larry Miller]

Thank you, Mr. Usborne.

Mr. Anderson for seven minutes.

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

Thank you.

Mr. Usborne, I have a couple of questions for you. You talked about the fact that you don't think the inspectors all needed to be vets. I'm just wondering how that's received in the industry and by the union, and what comments they would have on this. The union has been fairly aggressively involved here, and it seems like they're trying to make some political points and are trying to establish their ground, but I'm wondering how they receive that kind of information.

[Ron Usborne]

I haven't talked to the union.

I don't think they're all vets in the union, unless there are two unions. I think there are a lot of inspectors who are not veterinarians. All I'm saying is why would you go to vet school to learn physiology and pathology and how to do surgery and all that to become a meat inspector? I think we need some, but in order to raise the bar, in terms of training and understanding, we need to include others in that pool.

A lot of inspectors were former butchers, and I'm not sure if they're just out of high school. That might be a question to ask the CFIA, what qualifications you have to have to be an inspector. So I really don't know what the vets think about that.

I do have to tell you that I was on the advisory committee to the dean's council at OVC, but this topic didn't come up.

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

Okay.

I want to talk a bit about the systems that you're talking about. First, you said that there were summaries of data that were developed early on. I think you said Dr. Todd was the person who developed the framework, and then it was set aside.

Do you want to tell us a little more about that framework? You seemed to think it was an important one.

[Ron Usborne]

Yes, Dr. Holley mentioned pooling a lot of data.

He got beyond the pool and actually was in touch with many of the public health jurisdictions across the country to find out where outbreaks occurred, whether it was in a school or hospital or church dinner. He found out what the food was, whether it was wieners or potato salad, and the number of people who were ill, that kind of data, which he published. I think it's in the Canadian Institute of Food Science and Technology Journal. So it is published. Actually, I used this data in teaching, when I was at the University of Guelph, to show what the hazards were, what kinds of foods had the highest hazards, what kinds of organisms, that type of thing.

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

One of your points was that bigger is not better. We've talked about this a couple of times at committee here with a couple of different witnesses, and we actually challenged Mr. McCain on this.

Do you have any vision for how we can ensure that some of the smaller companies are able to participate? If we're going to see through some of the things that you folks are talking about, it seems we're talking about a pretty comprehensive system, and often the smaller firms can't afford those kinds of costs.

[Ron Usborne]

One of the things I mentioned in my remarks was having it outcome-based. We used to put a lot of emphasis on standards for building materials and the like, but the modern thinking in inspection is to have it outcome-based. As was mentioned before, we don't want to make people sick, we want product to leave the plant without the hazards in it.

A lot of times, I think, for the smaller plants--because they know their employees, it's easier to do training--once they see the results of their program, they can produce a better product. It's a lot easier for them to do it. Everybody speaks the same language, for example. Often there are family members working together.

In the larger plants, language can become a problem if you are hiring different ethnic groups. To train them you have to go to quite an extensive program and make sure it's in all the languages so they'll understand.

I guess we maybe have to put some parameters around “bigger” and “smaller”. They often refer to them as SMEs, which are small to medium enterprises, as opposed to the larger plants. But it seems that in Canada we're getting a consolidation of our meat plants, not only the slaughter plants, which are becoming fewer and fewer, but also some of the processing plants.

I've heard some of you mention that you go to the farmers market. There's often very good product there. Now, whether they follow the food safety standards, we don't always know, because they're not federally inspected. It was mentioned before that this should apply to all plants, but don't forget that CFIA deals only with federally registered plants, they don't deal with the provincial plants. What they do doesn't necessarily affect the provincial plants. I did mention that if a province develops a program, like they did in Ontario--the HACCP advantage program--and it is equivalent to CFIA's FSEP, there should be some recognition of that for the provinces.

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

Mr. Holley had something to say.

I also want to know.... Do you think, then, Mr. Holley, that all plants should be under the same standard, or is it acceptable to have provincial standards that work, primarily because those plants are serving a much smaller market? Or do you think everybody should have the same requirements?

I'm asking both of you that, I guess.

[Ron Usborne]

I think that's a challenge, because you will put a lot of the smaller plants out of business. One of the requirements, of course, is that if you export, you have to meet certain requirements. In order to do that, then, you need the same standard. But I think there are market opportunities in provinces, like buying local, whereby you do have a safety standard, which I said was equivalent to the federal standard, in that they have a HACCP program.

They have good manufacturing processes, but they may not be enforced to the same degree with the records. They can produce meat to sell, even within the province, but there are a lot of retail chains.... We heard earlier about the retail stores not giving much attention to the producers of produce. This happens in the meat industry too. There are a lot of chains where, if you're not federally inspected, you can't get into those stores. On the other hand, they do violate that, because it's often hard to buy federally inspected lamb. I know in Ontario you can buy provincially inspected lamb.

I think there has to be some flexibility and continued discussion with, as I said, the federal-provincial-territorial committee on how we can come up with a meat safety system that will protect all the consumers in Canada.

[The Chair, Conservative, Larry Miller]

Your time has expired.

Perhaps you can answer very briefly and directly, Mr. Holley.

[Richard (Rick) Holley]

There were two issues I wanted to speak to. The first has to do with the double standard.

I would reiterate what Dr. Usborne has said, but until we resolve this issue, I think there should be a single standard. We are going to always face problems in terms of imported products coming into Canada that meet the provincial but not the federal standard. If they're manufactured in Ontario, they can't be sold in Manitoba, but they could come from China and be sold from one end of this country to the other. That has to be straightened out, because we are signatories to the WHO agreements on sanitary and phytosanitary standards.

The second thing was that about 45% of the food in Canada is inspected by the federal government. Sorry, that number is reversed: it's 55% of the food is inspected by the Canadian Food Inspection Agency. Things like cereals, cooking oils and spices, are not inspected by anybody. If you guys think that inspection is going to be the be-all and end-all of food safety in this country, think again.

The third thing was to provide information with respect to food-borne illness surveillance programs that are currently in place. FoodNet is a program in the United States. It has ten sentinel sites and monitors the health of 45 million people, like Todd used to do in Canada. We have a fledgling system in Canada, operated by the Public Health Agency of Canada. It's monitoring the health of one million people in the Kitchener-Waterloo area, and they're moving forward to set up another sentinel site, which may come about this year in Alberta and/or British Columbia.

[The Chair, Conservative, Larry Miller]

Thank you.

Ms. Duncan, five minutes.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

Thank you, Mr. Chair.

Thank you, gentlemen.

I'm sorry I missed the beginning of your remarks, but I want to pick up on something you said, Dr. Holley. Can you provide a list of what's not inspected in Canada, please?

[Richard (Rick) Holley]

Yes. In a broad sense, things like bakery products, cereal products, biscuits, cookies, pasta, peanut butter, infant formula, unpasteurized juice--I can go on--spices. Anything that is not covered by the Fish Inspection Act, the Meat Inspection Act, or the Canada Agricultural Products Act is not inspected by the federal government, the CFIA. They don't have time to do it. It is their responsibility, but they don't do it; they can't, and they have my sympathy.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

Thank you.

What are the ideal growing conditions for listeria, in terms of temperature, humidity? What is ideal? Is it a large range, is it a small range, so if we altered, we could change it?

[Richard (Rick) Holley]

The organism is what we call a psychotroph. It will grow very, very slowly at refrigerator temperatures, so four degrees is not a problem, and it will get to very, very high numbers over a period of 59 days, which is the shelf life of a cooked, cured meat product in a vacuum package. It does not need oxygen. It will grow without oxygen.

It's relatively pH insensitive. It will grow at very high pHs--pH 9, pH 4.5. That's not a problem for it. And it will also grow at body temperature, and we know that, because it kills people.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

If we changed the parameters, is there any way to alter the environment that would reduce the chances of developing it?

[Richard (Rick) Holley]

Absolutely. Keep it clean. It's a no-brainer, and I don't mean to make fun.

The more we know about the limits associated with the ability of this organism to grow, the more we'll be able to control it. Health Canada brought out, September 8, permission, which they had been sitting on, to allow the use of sodium diacetate in these kinds of products that cause people, mostly in Ontario, to die from listeriosis.

That was something approved a long time ago in the United States. In the United States, they brought it in three years ago, because at that time they had the biggest recall--about 26 million pounds of cooked, cured turkey roll contaminated with listeria--so they allowed it then. It was an uneven playing field. Health Canada was reluctant to do it, but during the course of the outbreak, they passed an IMA allowing its use.

Now we know how to stop the organism from growing, and we can take 100 similar kinds of products that have the antimicrobial.

[Kirsty Duncan, Liberal, Etobicoke North, ON]

That was my next point. You're saying that this product will stop the growth. I was going to say that there has to be some sort of early warning sign. What would be early warning signs?

[Richard (Rick) Holley]

That's a good question. The early warning sign is the safety system.

The new attempt by the CFIA to get early warning of impending problems--that is, buildup of these organisms on the equipment and growing in the crud that occurs in the bearing traces and in the joints inside the machine--by swabbing the food contact surfaces on a regular basis will provide a history. Over a course of months--and correct me if I'm wrong, Ron--you'll see in a food plant....

You have maybe ten machines working in a row. If you're monitoring all ten of those machines that make hot dogs, and you see a problem developing in one of them, which shows listeria, then you know that it's time to take that machine out of the line. At the same time you identify a problem you start testing the end products. Don't misunderstand me. I'm not saying don't test the end products, but don't test the end products in a random fashion.

It's the food-contact-surface swabbing program that is the early warning.

[Ron Usborne]

If you collect records, why would you not use them? This was where one of the deficiencies was in the Maple Leaf program. That's what I heard. They collected records, but they didn't study them.