Good evening.
The recommendations of the Canadian Meat Council, that Olymel is of course part of, are eight in number. The first recommendation deals with antimicrobial interventions. In our opinion, the industry in Canadian should have access to the same antimicrobials and interventions that our American counterparts have.
Health Canada approved the use of sodium diacetate in combination with sodium or potassium lactate in ready-to-eat meats in September 2008. Schneider Foods had officially requested permission to use this antimicrobial six years prior to that, in September of 2002. According to the American Meat Institute, since this antimicrobial has been widely in use, there have been no recalls of ready-to-eat meats due to listeria-related illness in the USA for the past five years.
Our second recommendation is to create a single food safety authority for Canada and the United States. In our opinion, Canada should work with the United States to develop a single authority with the responsibility of overseeing food safety. The Europeans have done it; Australia and New Zealand have done it. Not only that—the Europeans have developed a common economic union that allows for free movement of goods between a number of countries without the need for border inspections. The new Obama administration has announced that it is reviewing the American food safety system after the salmonella in peanut butter incident. Now is the time to act.
Our third recommendation is that Canada should create a single meat national inspection standard based on outcomes and guidelines, rather than on normative standards and criteria. We believe that all provincial meat inspection standards should meet the federal meat inspection standard. Canadians should expect that all the meat they consume meets the same rigorous standards regardless of where they live and shop. Canada's federally registered meat processors are inspected regularly with standards that meet both high domestic and international requirements.
Provincial meat inspection standards do not meet international or national Canadian requirements and such plants can only sell products in the province in which they operate. Some provinces, like Ontario, have recently introduced new, stronger meat inspection regulations while others still have meat processors that are rarely, if ever, inspected.
Here is our fourth recommendation. The Canadian Food Inspection Agency should be exempt from Treasury Board guidelines on the common look and feel of the federal website so they can get information up on a timely basis. The information is either actually part of the regulations we have to use every day, or refers to them. The Manual of Procedures is constantly being updated, but those updates are often too slow to get onto the website and into the system. For instance, when the new Compliance Verification System was imposed on the industry on April 1, 2008, we had to wait until December of 2008 for chapter 18 of the Manual of Procedures to be finally published on the website and available to the industry.
Even today, there are many sections of the Manual of Procedures that state: “This chapter is currently under review. For more information on its availability, please contact...“ This even includes the entire chapter 19: Poultry Inspection Programs. The industry needs to have access to all sections of the Manual of Procedures because it is the basic tool with which we make changes to and inspections of our plants while they are in operation. When a chapter is under review, the current rules should be posted until new ones are made. Even the Government of Canada website on lawmaking states:
A fundamental principle of law is that everyone is presumed to know the law; this principle cannot be applied or be effective unless it is supported by a system that enables those affected by a law to have reasonable access to it.
Our fifth recommendation is that the Public Health Agency of Canada and the Canadian Food Inspection Agency be the voices during crisis events. The Public Health Agency of Canada and the Canadian Food Inspection Agency should be the official voices that regularly update Canadians during a food safety outbreak. During the listeriosis outbreak last summer, what our industry really needed was a voice and a face that Canadians could rely on as we had during the BSE crisis and the SARS crisis.
What we really needed was a voice to regularly update Canadians on the listeriosis outbreak and on the new rules that were being put in place.
Our sixth recommendation is to invest in better training for inspectors. We believe that CFIA inspectors need to have better and more regular and consistent training. It was evident to us after the new control policy was implemented on April 1, 2009, that this was not always the case. In fact, we met technical teams and teams of inspectors who were having difficulty with the new standards and the new inspection system and with the changes that had been made. Veterinarians are trained in animal physiology and surgery, but they have no training in food science or quality control. That is a problem.
Our seventh recommendation is to make food safety expenses eligible for the Agri-flexibility program. We should put the funding of new food safety technologies on the list of the new program's eligibility criteria. We feel that this is essential.
Our last recommendation is to educate consumers. Health Canada and the Canadian Food Inspection Agency should continue to educate retailers and consumers on safe handling, storage and preparation practices. A proactive and concerned federal government should target consumer education collaboratively between several ministries. Special attention should be paid to high-risk groups such as the elderly, the immunocompromised, and pregnant women.
Thank you for allowing us to be a part of this committee's work.
Thank you on behalf of Olymel.