Agriculture committee  Thank you very much for your question. Our clear preference is to amend the legislation rather than allow the regulations to address the concern. Not having seen the regulations, we don't know whether we can adequately address it through regulation. Again, one of the biggest challenges is going to be how we carve out the set of exemptions when we're looking at a broad cross-section, potentially, of Canadian food products that are exported to foreign countries.

Agriculture committee  Currently, many spices that are imported into Canada are not safe for human consumption either because of a high microbial load or because they may contain sticks and stones and other natural substances that have to be removed. What Canadian processors do in Canada is they treat them so they're microbially safe and they process them to remove the sticks and stones.

Agriculture committee  Spices are just one example. The challenge is going to be going through and identifying all of those specific exemptions and finding a way to incorporate them adequately in the regulation.

Agriculture committee  I think there's an opportunity for this bill to do a lot of very good things for the import community. First, one of the areas that we've had challenges with is the compartmentalization of the inspectorate. For instance, if a truck comes to a border crossing in Canada from the United States and there is a meat inspector there, that meat inspector cannot open that truck to inspect it if it has fresh fruits and vegetables or other commodities.

Agriculture committee  Thank you very much for your question. In Canada, Canadian companies produce product for export sale only. Because the requirements in Canada are different from what they are in certain other countries, we are allowed to use ingredients that are not permitted in Canada for the manufacture of those products, provided those products are for export sale only.

Agriculture committee  Right.

Agriculture committee  It's very much the same kind of thing, only it's the reverse. In this case we are required to include ingredients in our products under regulation that are not permitted in a foreign country. Because of that, our products will not be acceptable in a foreign country if they have to meet our requirements.

Agriculture committee  It's a legislative conundrum. It's an unintended consequence of how the legislation is written. If we did not have the export provision in the bill, the risk that I talked about regarding the loss of Canadian jobs, aside from the specific example that has to do with spices, would not exist.

Agriculture committee  We've had discussions with CFIA and we've had discussions about how that might happen. Again, as my colleague has raised, until we see those regulations we do not know whether or not the regulations will adequately address the concerns that we have. Also, one of the challenges we face with the regulatory process in our country is that once we have a regulation in place, it is very hard to change a regulation that does not meet the requirements of Canadians or industry.

Agriculture committee  In closing, while the food safety objectives of the bill are clear, there are provisions which, if not amended, will result in considerable loss of Canadian jobs and consumer choice. Our members are committed to consultation with officials to address these concerns. On behalf of I.E.Canada and its member companies, I would like to thank you for the opportunity to be here today on a matter that is vitally important to all Canadians.

Agriculture committee  Thank you, Mr. Chair and members of the committee. My name is Keith Mussar. I am with I.E.Canada, the Canadian Association of Importers and Exporters. It is a privilege to appear before the committee to testify with respect to Bill S-11, the safe foods for Canadians act. I.E.Canada, the Canadian Association of Importers and Exporters, is a national trade association that has been speaking on behalf of the Canadian trade community for more than 80 years.