As a Canadian Food Inspection Agency inspector for 35 years, I worked in meat slaughter plants and processing plants and spent a majority of my career as a CFIA border inspector. I was an inspector in charge of two CFIA-approved import meat inspection establishments.
I wrote a CFIA import meat inspection training manual and developed and delivered an import meat inspection training program to CFIA inspectors in the Ontario area. This course was used as the basis for the national import training course. I assisted in the rewriting of the new chapter 10 of the meat inspection manual of procedures, which deals with the importation of meat.
In 2005 I retired from CFIA and am now working within the meat industry on a private basis. During the course of my career with CFIA and now, while working in the industry, I have witnessed first-hand many shortcomings with the way CFIA conducts its meat import program.
First of all, I want to make it clear that the majority of Canadian meat importers want to import meat products that are wholesome and meet all CFIA requirements. In no way do they make an attempt to circumvent the system and put Canadians at risk. However, CFIA has created an avenue for unscrupulous importers and exporters to dump substandard meat products that do put Canadians at risk. CFIA has also put the reputation of Canadian meat importers at risk by not inspecting meat products properly to ensure that they are wholesome and meet Canadian standards. This increases the risk for them to unknowingly receive and distribute meat products that are substandard.
I would like to describe to this committee six major issues I have witnessed while a CFIA inspector and in working in the industry now.
Issue one: there are no longer CFIA inspectors at the ports of entry. As of today, CFIA inspectors are not located at nor do they provide services at border entry points. Only live animals receive CFIA veterinary inspection. I feel that this is a real and growing threat to public security and bioterrorism. Unlike the United States, which is increasing inspections and inspectors at ports of entry, Canada, through CFIA, has eliminated inspectors at all ports of entry.
CFIA has given this responsibility to the Canada Border Services Agency, which has no expertise or training in detecting evidence of unwholesomeness and abuse of a meat product. Front-line CBSA officers are not equipped or do not have the confidence to identify and deal with meat shipments that are out of compliance with the Canada Meat Inspection Act.
When I was a CFIA inspector at the border, I discovered several shipments of meat a month loaded in transport containers that were dirty, had foul odours of chemicals and fish, were poorly constructed with holes in the floor, or had refrigeration units that were not operating properly, and with meat and poultry off condition and meat and poultry not as described on the meat certificate and customs documents.
Issue two: exporters know between 72 hours and 30 days in advance whether their meat shipment to Canada will require visual inspection, full inspection, or no inspection. The result is that exporters to Canada can choose what meat goes into a load that will be inspected. This results in some unsavoury exporters to Canada dumping inferior and unsafe meat product into the Canadian market. An ideal means to carry out an act of bioterrorism is created. Importers are able to misrepresent import poultry shipments, resulting in breaches of Canada's supply management quota system.
Because it is known in advance whether the shipment will be inspected, meat shipments are a means of smuggling contraband. CBSA, for example, has discovered illicit drugs mixed in with imported food products. Exporters of meat products to the United States do not know whether their meat shipment will be inspected until they reach a meat inspection facility approved by the Department of Homeland Security and located in close proximity to the border. It's a contradiction to what Canada is doing.
Issue three: numerous meat shipments assigned a full or visual inspection were not presented by importers for inspection. According to statistics I obtained through the Access to Information Act, from January 1, 2000, to December 2007, 2,936 shipments that had been ordered by CFIA to be inspected were not inspected. No one knows whether these loads contained the declared food or possibly an illegal substance such as drugs, biohazards, etc., and if food, whether it met Canadian food safety standards. There were no penalties taken against these importers of record.
In the United States, the exporter, not the importer, is responsible for presenting the load for inspection. The exporter has to purchase a U.S. customs bond equivalent to three times the value of the shipment. Failure to present the shipment for inspection results in the exporter paying a penalty of three times the value of the shipment, plus costs for recalling the meat shipment.
Issue four: CFIA laboratory sampling schedules for bacterial analysis, residue monitoring, etc., for import meat are not carried out by CFIA import meat inspectors. This increases the risk of the introduction of pathogens that can cause illness or death and also increases the potential threat of bioterrorism. Through ATIP, I learned that from January 1, 2006, to November 13, 2008, only 370 samples of imported ready-to-eat fermented meat products were submitted by CFIA inspectors for microbiological analysis. This was far from the minimum standard required by CFIA. Of these samples, eight tested positive for listeria monocytogenes, four tested positive for salmonella, one tested positive for staphylococcus, and four tested positive for another type of listeria.
Issue five: CFIA has developed a non-productive internal culture. The inspectors do not always follow proper procedures for inspection of import meat shipments, because of apathy, shortage of staff, and lack of training. Inspectors have to try to incorporate imported meat inspection duties into other demands for service, such as inspection of processing in slaughter plants, and other commodity requirements.
Recently, CFIA established a time-consuming compliance verification system, and you heard testimony earlier that inspectors had to cut corners to get this particular activity done.
Ironically, it is a U.S. requirement that a CFIA establishment be visited daily by a CFIA inspector during its operations to allow that establishment to export its meat products to the U.S. This increases the inspection and travel time of the CFIA inspectors. It seems that CFIA is putting more emphasis on exports than imports.
Managers encourage import meat inspectors to cut corners to satisfy client demands, as I mentioned, and most import meat inspectors are not properly trained. To be an effective CFIA meat inspector, an inspector must have received training. He must have knowledge of pathology and dressing defects, and he must have successfully completed the CFIA meat processing course and the metal can integrity course, and he must be certified by Health Canada. In addition, he must have completed the CFIA meat cutters course and the CFIA national training course for import meat inspection, and he must know the CFIA label requirements of meat products. He must be able to esthetically take samples and submit them to a laboratory, along with proper documentation. He also must know the shipping requirements of import meat products and have knowledge of CBSA and CFIA service centre operations and procedures for clearance of imported meat shipments. He must be certified as a poultry grader to inspect imported graded poultry and have knowledge of the multi-commodity activities program, MCAP, and the import control and tracking system, and have complete knowledge of chapter 10 of the Meat Hygiene Manual of Procedures.
This training requires hours of classroom time and months of hands-on training in meat processing and slaughter plants, as well as practical experience shadowing an experienced import meat inspector. The current practice is that after only a few weeks of training, people are given the assignment of doing import meat inspection.
Issue six: there's a conflict of interest. Many meat processing plants do import meat inspection. Fresh meat shipments are often just-in-time deliveries, and CFIA inspectors are pressured to quickly inspect the meat shipment and not to follow procedures. In some cases when defects are found, instead of refusing entry, the inspector is pressured to allow the reworking of the product. According to section 9 of the Meat Inspection Act, no meat product can be reworked to meet Canadian standards; it must be refused.
There are other issues of concern, such as the risk of foreign audits. If we do not do our import inspection properly, and if imported meat products are used in processing our own meat products and are exported, this could create a problem if we don't inspect them properly.
There are also problems with the CFIA import tracking system, and there is incorrect code in the harmonized system, HSS, a system that is used electronically to describe import meat shipments in the CBSA database. By just switching one number of a 10-digit number, you can change a commodity from just being soup to vegetable beef soup, which requires more certification and inspection.
There is a huge incentive to misrepresent the amounts of chicken and turkey in import shipments. Canada's poultry system is protected by a controlled supply system, with high tariffs on imported poultry to protect Canadian producers. To bypass these tariffs, importers have quotas available and can secure a permit from DFAIT, the Department of Foreign Affairs and International Trade, stating the amount and kinds of poultry they can import. This should be of concern to poultry producers in Canada, because importers can misrepresent the poultry. They can put down types of poultry that don't require a quota.
I guess I should wrap this up. In conclusion, I would like to read the following excerpts from the CFIA report to Parliament: “Since the Agency’s creation in 1997, imports and exports of products subject to CFIA regulation have increased by 45.6 percent.” And I'll give you another one from the report: import meat samples have not been and continue to not be sampled according to the sampling plans outlined in chapter 10, Meat Hygiene Manual of Procedures.
Thank you.