Evidence of meeting #9 for Subcommittee on Food Safety in the 40th Parliament, 2nd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was inspectors.
A recording is available from Parliament.
6 p.m.
NDP
Malcolm Allen NDP Welland, ON
--to explain what exactly you're responsible for and the nature of the plants that you would actually audit. Could you encapsulate that for me?
6 p.m.
Inspector, Canadian Food Inspection Agency
What I do is a verification of the company's reassessment of their HACCP program, which is supposed to be done on a yearly basis. When I get into the company, I review their written program for the HACCP system to make sure they have addressed certain criteria. For example, have they done an analysis of the risk that is involved in their process? Who is actually doing the function in terms of the monitoring, and exactly what and how are they monitoring? If the monitoring function fails, it is called a deviation. Then there are the steps taken by the company to ensure that the process is brought under control again.
There is also the verification system in which the company, at a certain frequency, will have to verify that the monitor is doing the job as in the written program, and we'll perform an on-site verification of that task—that is, the company's person—and where this data is recorded each time a function is performed. That is my job.
6:05 p.m.
NDP
Malcolm Allen NDP Welland, ON
I'm sorry for interrupting you, but when you're talking about this system and your audit of the system...is this a paper-based system or do you actually go to the plant floor to verify?
For instance, if someone says, “I read Catherine Airth's name four times because it was written there four times”—sorry for using your name, Ms. Airth—did you actually go down and see that it was written four times? Is that a report that you've verified, in that yes, we have a report, and it's taken as such? Or if it was written only three times and it was a deviation because it should have been written four times, and you ask them to comply with the report so that it is four times, is that a paper-based system or is that something you actually physically go out and look at when you see deviations?
6:05 p.m.
Inspector, Canadian Food Inspection Agency
What I'm doing is a verification of their written HACCP program, which consists of their written HACCP plan, the actual process involved, and also their prerequisite program, which has to do with the environmental factors in the plant. I look at the HACCP program. There are certain guidelines they have to follow in writing up the HACCP program. It ranges from a form 1, which speaks about the product, to a form 10 , which is their HACCP program.
6:05 p.m.
Inspector, Canadian Food Inspection Agency
Yes, there is a bunch of papers. It actually outlines the process from the time the raw product enters the plant to the time it finishes and leaves the door. In between, there is form 8, in which the company is supposed to analyze, based on their system, where they will place the critical control point to make sure that the hazards that could be introduced at a certain point are being addressed and monitored.
There are also forms 3 and 4. Form 3 has to do with the process steps involved in the production of the product. Form 4 deals with the flow of employees as well as product. It is very significant. If you have a raw plant, and the same plant deals with ready-to-eat or cooked product, there should be a distinct flow of their people and they should not be mixed. I go on-site, once I've reviewed the program, to make sure that what they have on paper is exactly what's happening on the kill floor. I verify the accuracy of those plants.
I am doing the verification in that once I've seen that the HACCP written program is okay, the inspector is the one who implements that program. If they don't have a properly written HACCP program, the implementation will fail.
6:05 p.m.
NDP
Malcolm Allen NDP Welland, ON
Just so that I get it clear—and I think I have, besides the 10 forms—the whole sense is that you're verifying the paper-based system, looking for deviations, and then informing plant floor inspectors that you've seen a deviation in what's being reported and perhaps asking them to then go and check to see if this has been done. Is that how that system works?
6:05 p.m.
Inspector, Canadian Food Inspection Agency
I am actually only verifying. I am saying, “Okay, you're producing this product. These are the requirements, the regulatory requirements, the HACCP requirements. You have to fulfill those requirements.”
Once I have completed and I've said it's okay, or there is no deviation, either we give them a card if it's a food corrective action request, if there is a food safety issue, or we give them “acceptable with comment”. That means they're actually performing the task but for one reason or another they can't put that translated into their written program properly, so they will have “acceptable with comment”.
And the inspector is also in with me on this, not fully, but at least at the opening meeting, and on a daily basis I will update him as to the progress of the audit. Once I've completed that, it is the inspector's job now to make sure, based on the CVS system, task number three, that the company is following the written HACCP program. So he is the implementation part.
6:10 p.m.
Conservative
The Chair Conservative Larry Miller
Okay. I'm sorry, I didn't mean to interrupt you. I thought you were finished.
Your time has expired, Mr. Allen.
Thanks, Ms. Fowler.
We'll now move to Mr. Anderson, for seven minutes.
May 25th, 2009 / 6:10 p.m.
Cypress Hills—Grasslands, CPC
Did you want to go any further with that? I didn't want to stop you, because you were laying out how it happens. But if you're at the end, that's fine.
6:10 p.m.
Inspector, Canadian Food Inspection Agency
No, not quite.
So once the HACCP audit is completed, either the company will have a corrective action request or they'll have “acceptable with comment”. There are certain time intervals within which the corrections have to be made. If the corrections are not made for an “acceptable with comment” after 30 days, on the 31st day it will turn into a card if they have not fixed that problem.
For a corrective action request, it's a card, and they have a limited number of days to present a corrective action plan. If it is not acceptable for a long period of time, it becomes a very, very big issue, with decertification, etc.
6:10 p.m.
Cypress Hills—Grasslands, CPC
Mr. Irons, I'd like to go back to the first question Mr. Easter asked about the reviews and the changes to the reports, the clarification. He seemed to be implying that because they were done at the same time, there was something strange about that. But it would be reasonable, if the audit is being done and these questions arise at the same time, that the clarifications would be made at the same time. Is that right?
6:10 p.m.
Food Processing Supervisor, Complex 3 - Toronto, Canadian Food Inspection Agency
I would look at it in that light, that if they were having the in-depth review, the in-depth review team would look at a number of records dating back, in that instance, maybe six months to a year. While they're reviewing those records, if any areas are unclear to the auditors, they may ask the inspector for clarification as to what he meant on a report and they may have instructed him just to put those clarifying notes on the report. My understanding was that those reports were dated the day it happened, so the inspector was not trying to hide anything.
6:10 p.m.
Cypress Hills—Grasslands, CPC
Okay, thank you.
I think Mr. Bellavance talked about inspectors. What are the requirements to be an inspector? It seems to me, from our testimony, that it has moved from being a position that was at one point fairly general to being something that's more specialized all the time. But I wonder, in general, what the requirements are to be an inspector. Are there any specific requirements in terms of education or those kinds of things?
6:10 p.m.
Food Processing Supervisor, Complex 3 - Toronto, Canadian Food Inspection Agency
There are now. Normally when there is a posting for an inspection position, there is a statement of qualifications. To be quite honest, I don't know what they all are. It would depend on which position you're applying for. Being the long-term employee, I haven't really applied for too many positions lately, so I don't really screen them, to tell you the truth. But I know now they are asking for post-secondary school and some kind of specialty relating to the food industry.
6:10 p.m.
Cypress Hills—Grasslands, CPC
The reason I ask is that the last witness criticized us—or I took it as criticism—because we were hiring other than inspectors.
This may be for Ms. Airth, but he seemed to imply we shouldn't be hiring biologists. But the reality is that you've got inspectors across a broad range. You've got scientists across a broad range. We put money into supporting the labs. So could you tell me a little bit about that? How do you see this in terms of hiring employees? Is it in silos or are you trying to work it out as a group thing, or what?
6:10 p.m.
Associate Vice-President, Operations, Canadian Food Inspection Agency
We would like to hire the best qualified people possible. Clearly it's in our best interests to have very highly qualified people. It's a complex environment in the food processing areas. I feel it takes people who have specialties in chemistry, microbiology, food science—a variety of disciplines—to help provide a more comprehensive approach. So we require people in labs, we require people who can look at things from a science basis, and we require people on the front lines. To me, it's kind of a team approach, and we require those ranges of expertise.
In fact, what we often find now is that we have some very highly qualified people coming to us as inspectors, even. We have people who come to us with animal science degrees and with science degrees of another nature, and clearly we welcome those sorts of attributes to the agency.
6:10 p.m.
Cypress Hills—Grasslands, CPC
I have another question about some of the testimony we heard earlier. If it's necessary to grant overtime in order for people to do their job, do you do that?
6:10 p.m.
Associate Vice-President, Operations, Canadian Food Inspection Agency
Yes. Again, going back to the team approach, we would encourage inspectors to speak with their supervisors. If they believe there's something inadequate, something that may be going wrong in that plant—I believe that inspectors have sort of a sixth sense about these things—I would encourage them to talk to their supervisor. Where it appears that they should go in at an odd time, perhaps when the plant might not be expecting them, or take a look at their pre-op processes for sanitation, I believe that we would recommend that it proceed.
6:15 p.m.
Cypress Hills—Grasslands, CPC
I'd like to talk a little bit about CVS. Now you've talked about HACCP and CVS, so I assume everybody supports that and sees that as a tool they can use in the plants to their advantage. Is that correct?