Thank you, Mr. Chairman, and thank you for the opportunity to provide the perspective of some importers on the subject of food safety.
Our trade association, the Canadian Association of Regulated Importers, or CARI, to use our acronym, is a specialized trade organization representing members who import food commodities for which import quotas have been established. Currently, the main ones are for chicken, shell and hatching eggs, turkey, and of course my friends here, dairy, with cheese. These quotas are in place to protect the respective supply management programs.
CARI is exclusively focused on representing the interests and rights of such importers. Imports of other food products and goods are not covered by CARI, so if you have questions relating to those, you’ll have to ask someone else. As importers of poultry products primarily—also of eggs, and turkey is of course considered poultry, and fowl is also considered poultry—our members operate within the regulatory environment maintained primarily by the Canadian Food Inspection Agency.
Based on our experience, the CFIA enhances the food safety of poultry and processed poultry product imports by maintaining two key policies. The first is restricting poultry and processed poultry product imports to only those countries and plants that have demonstrated equivalency with Canada’s inspection system based on HACCP principles. That equivalency in an inspection system is a key platform in maintaining food safety here in Canada, because our inspection system is a food safety-based inspection system.
The second element of the policy is the restricting of processed poultry product imports to only those products for which a label has been registered and a number issued by the CFIA under its prior approval service. No processed poultry product can enter Canada without a label registration number, which is checked at the border by either CFIA officials or CBSA officials and—and this is very important and critical—by foreign government officials prior to authorizing the export for Canada.
Normally, a copy of the registered label, approved and registered by the CFIA, is sent to the inspector in charge at the foreign plant. So that inspector has something to look at when he's signing the export certificate for Canada. Currently only the United States, Brazil, Thailand, and certain plants in Israel, Hungary, and France are eligible to export poultry products to Canada. In the case of Thailand, only processed poultry products can be exported. You can see that the universe is quite limited.
The combination of the two regulations provides a very effective and efficient means of enhancing food safety, as it allows importers to carry out their responsibility to import safe poultry and processed poultry products from HACCP facilities. We cannot, for example, import from non-HACCP facilities. That’s not allowed under the Canadian regulations.
Last week in Washington, D.C., at a conference I attended, we learned that the United States is considering adding egg products and catfish to USDA coverage, which means only imports from countries with equivalent inspection systems to the United States' system will be allowed. For your information, Canada is the only one that has an equivalent inspection system in the case of egg products, for example. Canada would be the only country that can export egg products to the United States.
So you can see what’s happening here. A similar bill is being considered in the Congress that would expand the use of HACCP to cover FDA products, and those are all the products that the USDA doesn’t cover. The U.S. government, therefore, is increasing the use of inspection equivalency and prior label approval as a means of improving food safety, because as you know, in Washington they’re holding lots of hearings on food safety, just as you are here.
Some have suggested that inspection system equivalency is being used by countries as an import barrier, but so long as the same rules are applied to the domestic industry, the approach is on solid ground. Food safety equivalency based on internationally accepted HACCP principles is one of the best ways to consistently improve the food safety profile of both domestic and imported food products and has the additional benefit of ensuring a level playing field in the marketplace.
The pivotal role played by prior label registration as an efficient and effective means of keeping out imports that do not meet Canadian requirements appears to be underestimated by the current government. As you know, a decision has been made by the government to unilaterally eliminate this requirement. None of Canada's key trading partners are demanding this be done, nor are they contemplating doing this. Although some will argue that labelling is not a food safety issue, keeping out food products that do not meet Canadian requirements is a critical component of maintaining food safety. It is no use removing those products once they've been consumed in Canada. We need to keep them out before they're consumed.
If these hearings by the subcommittee can cause the government to revisit and amend its decision to eliminate the prior label approval service, Canadians and food safety will be well served. Indeed, based on our experience with processed poultry products, we do not understand why the registration of all food labels, both domestic and imported, is not required. Over half of all food product recalls are related to allergens that were not identified on the label of the imported food product. If all labels had to be registered prior to their use in the marketplace, firms would be much more careful to ensure Canadian requirements were met. This would ensure food safety and reduce recalls.
Today's electronic world makes it possible to register all labels quickly and cost-effectively. The CFIA has developed electronic label registration, but for some reason it is not willing to fully utilize it. That's unfortunate.
One other effective way to improve food safety and promote harmonized food safety systems is for the federal government and other levels of government to provide seed funding to encourage the adaptation of HACCP principles. Under the CARD program, CARl requested to develop a generic HACCP plan for food distributors. We were the first application under that program, and it was accepted.
The generic model is now being used by many distributors across Canada, but since there are over 400--maybe as many as 500--food distributors across Canada, funding to encourage adaptation of HACCP by small and medium-sized distributors would improve the food safety profile of food consumed by Canadians. Similar seed funds were provided to encourage federal plants to adopt HACCP, and it was one of the most successful seed funding programs the federal government has ever put together.
Those are my comments, Mr. Chairman.