Regulatory Organization Pending Changes Federal Legislation New Listeria regulations Prospects for improved food safety

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2 Recent Government Action Modernizing and strengthening Consumer Product Safety Act Regulatory Organization Pending Changes Federal Legislation New Listeria regulations Prospects for improved food safety

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5 Improving predictability, effectiveness, efficiency, and transparency in Health Canada's food regulatory system, i.e. food additive clearances; Promoting regulatory responsiveness to food innovation and promoting consumer access to foods with assessed health benefits (discretionary fortification); Modernizing the regulatory toolkit to address "food contributors" to chronic disease such as the development of strategies to reduce the presence of trans fatty acids in Canadian diets to the lowest possible levels;

6 Improving Health Canada's responsiveness to acute food safety health risks - food allergens, risk communications for food safety and nutrition risks, consumer-level education, and retail-level food labelling for improved public health and consumer protection; and Promoting a sustainable and integrated system for food safety and nutrition in Canada - collaboration between HC, CFIA, PHAC, and the food safety authorities in the provinces and territories.

7 $113 million over 2 years Proposes: Active prevention - better safety information to consumers/ guidance to industry to prevent problems in the first place Targeted oversight - focus on products that represent the greatest risk Rapid response - enable government to respond faster to protect public by recall power to Health Canada and doubling inspection staff over 5 years

8 Action Plan- Food and Consumer Safety Newest measure: provides a general safety net Bill C-6 (CCPSA), Jan. 29, 2009 (was Bill C-52) Prohibits manufacture/ import unsafe products Mandatory reporting of adverse incidents Can require test/ study results Document retention- traceability Health Canada can order corrective action, recall Increased fines/ penalties- incremental, criminal Does not cover foods, natural health products, drugs, fertilizer, feed, plants, animals.

9 Regulatory modernization for Food & Nutrition - Risk-based decisions will guide food regulation development - Health claims (product specific) - Discretionary fortification of food - Food for chronic diseases - Food safety Reality - Health Canada Strategic Plan $5M reduction Food & Nutrition budget, and 10/700 people - No visibility food safety effort, resource limits evident - Priority= natural health products or safe food?

10 Allergen labelling possibly Canada Gazette I 2009 (Food Labelling and Allergen Act?) International effort; segregation; assay costs; gluten-free = USD $650 million Bottled water regulations? spring, mineral water Processed products (re-write) positive-listing additives GRAS (SURE) Jurisdiction e.g. juices/drinks

11 Canada Food Safety and Inspection Act, Unified food inspection act Bill C-80, died no apparent parliamentary interest now

12 Canada organic food industry worth $1 billion with growth 20% per year. Mandatory regulations in place 2008 Organic food logo. Certification is required for interprovincial trade

13 Regulatory Food Safety Agencies Canada Canadian Food Inspection Agency (Agriculture) Health Protection and Food Branch (Health Canada) Public Health Agency (Health Canada) Inspection Trade standards Food labels Food safety Foods, drugs, Natural health prods Health standards FDAR changes Food safety Infectious diseases Illness surveillance Water and Food safety

14 Prohibits sale of foods containing substances likely to be injurious to human health or food improperly processed or handled. Prohibits improperly labelled foods from sale. Prohibits importation or interprovincial shipment of foods not meeting standards Prohibits making health claims for food.

15 FOOD and DRUGS ACT Covers all food imported or sold in Canada Fish Inspection Act Covers fish and fish products marketed in Import, export and interprovincial trade. Meat Inspection Act Covers meat and meat products marketed in import, export and interprovincial trade. Canada Agricultural Products Act Covers most dairy, egg, fruit, vegetable, maple and honey products marketed in import, export and interprovincial trade

16 Dairy, shell & processed eggs, fresh fruits, veggies honey, maple syrup, beef, pork, poultry, fish All other foods Percentage of grocery dollars spent by consumers on these commodities Applicable criminal legislation i.e. Food & Drug Act Applicable trade & commerce legislation, i.e. Canadian Agricultural Products Act, Meat Inspection Act, Fish Inspection Act Federal registration required or enhanced import control Federal registration NOT required FOOD 4500 FOOD SAFETY AND REGULATIONS

17 Performance: In top 50% of 36 countries (illness frequencies) : EU, Norway, Australia, New Zealand, Japan, S. Africa, U.S. Deficiencies: No national foodborne enteric disease surveillance system A two- tiered inspection system, poorly co-ordinated by three levels of government (gaps, overlaps, inconsistent regulations). Affects import standards. Inspection not risk- based Food legislation: scattered in different Acts at federal provincial/ territorial levels (legislation renewal?). Planning handicap: We don t know what foods or pathogens cause most illnesses Single Food Safety Agency? Probably not needed.

18 Organism/ food Cases Deaths E. coli O157:H7 (ON) Salmonella cheese (QC) 87 1 Listeria proc meats (ON) Listeria cheese (QC)

19 For CFIA inspected meat processing plants Major mandatory changes in test requirements: Food contact surface testing for Listeria Reporting positive results Risk- based product testing for Listeria Trend analysis of data Non-food contact environmental testing encouraged. Recommendations from Industry Working Group on Best Practices for Listeria control expected fall 2009

20 Listeria sampling for registered plants Monitors effectiveness of sanitation + removal of Listeria by sampling processing environment (sampling plan M205). Random RTE meat and poultry product monitoring for domestic products, (plan M200). Sampling frequency (6x year 09-10). Risk- based verification sampling of RTE meat and poultry products. Implemented by operators, inspector supervised. Applies to product exposed to environment after lethal processing step. RTE product sampling imported product (plan M203), info distributed annually, Chapter 10 Meat Hygiene Manual

21 M205 applies to RTE meat and poultry products (except those requiring further heat treatment at preparation) Frankfurters and deli meats included Sampling frequency : 6x current year. Operational Centre CFIA supplies kit, instructions for inspector-in in-charge to sample Pre-moistened swabs for food contact surfaces (FCS) Composite samples tested for L. monocytogenes Product affected held- pending result Unsatisfactory result triggers a CAR under CVS, resampling 5d of same FCS and repeated twice more

22 M200 applies to all RTE meat and poultry regardless of treatment after heat processing Sampling frequency tied to production capacity Affected product should be held, pending ROA If positive, hold and test end product, take CFIA approved corrective action Risk- based verification sampling Sampling by operators Applies to products exposed to environment after production process complete Frequency det d by establishment alternative classifications

23 Demonstrate effectiveness of HACCP controls by sampling (Listeria or Lm) Mandated food contact surfaces (FCS) Risk- based verification sampling of products exposed to environment after processing (Lm), done under CFIA supervision, tracked Non-food contact surface sampling not mandated yet

24 Alternative Control measure Risk level Sampling frequency Alternative 3 Sanitation only Highest risk 12 samples per year (1 per month) Alternative 2B Antimicrobial agent or process (AMA/P) 2 log increase in Lm through shelf life Mediumhigh risk 6 samples per year (every other month) Alternative 2A Post-lethality treatment after the primary lethality process (PLT) achieves 1 log reduction L. monocytogenes Mediumlow risk 3 samples per year (1 per 4 months) Alternative 1 AMA/P and PLT are in place Lowest risk 1 sample per year

25 Establishment Category Alternative 3 Sanitation only Alternative 2 (AMA or P) allowing 2 log increase thru shelf life; (PLT after primary LT) achieves 1 log reduction L. monocytogenes Food Contact Surface Testing 2/year/line 4/year/line Alternative 1 AMA/P and PLT are in place Non-deli, non-hot dogs Deli, hot dogs 10 5 kg/yr 1/month/line 1/month/line Deli, hot dogs 10 5 to 2x10 6 kg/yr 2/month/line Deli, hot dogs Deli, hot dogs 2 to 6x10 6 kg/yr > 6x10 6 kg/yr 3/month/line 4/month/line

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29 Federal Government Shiela Weatherill report July, 2009 House of Commons Inquiry Canada Consumer Product Safety Act (Bill C-6) Health Canada Diacetate/ lactate approval cooked cured meats Consumer product safety/ inspections PHAC Notable by silence (C- EnterNet surveillance renewed, to expand to two sentinel sites this year). CFIA Listeria sampling rigour Food contact surfaces and product sampling Inspection rigour?

30 Prospects limited Concerns: Disenfranchising HACCP Foodborne llness surveillance passive Over-reliance on inspection to yield safety Inadequate inspection co-ordination, uniformity, risk-based? Recall immunity