Thank you for inviting Freeborn & Associates Inc. to participate in the Standing Committee on Industry, Science and Technology's study regarding the impacts of Canada's regulatory structure on small business.
We have been in business since 1997. We're a team working in the high-tech environment, creating educational materials to train and certify food handlers. Our mission is to help food service operators serve safe food to their customers. Our vision is to create a culture of food safety wherever food is being prepared and consumed. With these goals in mind, we provide interactive educational tools to educate people at all levels of the organization, from those who manage food service operations to those who prepare and serve safe food.
By way of introduction, we'd like to say that we appreciate the opportunity to address the impact of regulations on small business. I will elaborate on our experience as it relates to the committee's mandate. I will briefly describe the current situation and requirements for recognition of food handler certification; look at opportunities to improve efficiencies and reduce costs; and the alignment of interprovincial, territorial and international standards. I will also suggest an improvement to the pathway to market.
Currently, in nearly all jurisdictions in Canada, food handler certification is regulated by provincial or territorial government legislation. For a business to develop a nationally recognized training and certification program, it must be presented to each jurisdiction for approval. While all the health authorities reviewing the applications follow a document called the “National Guidelines for Food Safety Training Programs in the Food Retail and Food Service Sector”, there are small variations between each jurisdiction.
These reviews are often carried out by health inspectors, also known as environmental health officers, who are tasked with many day-to-day responsibilities for the protection of public health. Once a program is approved, recognition is posted on each jurisdiction's website, so the business can verify the program's credibility to its clients. We would tell a client that our program has been approved by directing them to a listing on each jurisdiction's website. Recognition is posted there. It's also important to note that the people we work with throughout the approval process are great folks. They're thoughtful, caring individuals who are performing to the best of their ability within the paradigm they've been given.
Regarding some opportunities for improved efficiencies, having every jurisdiction review these programs is a lot of duplication of effort. There is an opportunity to significantly reduce the duplication by centralizing the review process. Currently, programs can take up to a year to be reviewed. Improving efficiency can reduce the approval process to weeks. If the approval process were streamlined, food service businesses would have faster access to state-of-the-art national food safety training and certification resources. They would also have access to more current resources; the more often we update these, the more current the resources available will be. Having better resources manages risk for business, and reduces the likelihood of food-borne illness for the public.
Concerning some opportunities to reduce costs, the costs to business would be reduced by requiring preparation of only one application for approval, instead of the current application for each jurisdiction. There is also the cost to taxpayers, which would be significantly reduced if the duplication of effort in each jurisdiction were eliminated, freeing up public health resources to attend to their core responsibilities. The cost to business, in terms of lost revenues while programs await approval, would be significantly reduced.
Relative to the alignment of interprovincial, territorial and international standards, there are criteria for practices required for food safety. These are all based on accepted science. It means that what is taught can be consistent between jurisdictions, because those jurisdictions rely on the accepted scientific evidence.
Since we already have national guidelines for food safety training programs, and these are generally acceptable to all jurisdictions, the variations in criteria between jurisdictions are nearly always very minor in nature. Having all jurisdictions agree to one set of criteria, without variation, would permit alignment nationally. It's would also be good to look at further alignment of our national standards with other countries, because that would open the doors to international export of training programs from Canada.
The food service and hospitality industry requires workers to move through various jurisdictions, and students of culinary programs travel across the country to get work. Provinces and territories benefit from the alignment of standards, in order to attract these much needed human resources.
I have some suggested improvements to the pathway to market. We should harmonize requirements for food safety between provinces and territories to create one set of national criteria without interprovincial or territorial variations. We should review international standards to align Canada's criteria with them, since they're all based in science. We should create a national body that can independently review and accredit programs meeting those national standards. This body would not be in the business of delivering or promoting food safety training programs, so it would remain objective in its program review. Finally, we should establish a streamlined review process that reduces the time to market for programs that meet the required standards.
Thank you for listening to my comments.