Who tests our food supply?

Zoomer | January 1st, 2006

It’s an annual ritual. Each year, from coast to coast, government auditors stand before the media to deliver highlights of their annual reports.

Federal overspending, provincial mismanagement-there’s always some alarming disclosure that’s guaranteed to be front-page news the following day.

This past November, Ontario’s Provincial Auditor Erik Peters did not disappoint. As he spoke, the latest newsmaker quickly became apparent: Serious deficiencies in the way Ontario’s Agriculture Ministry safeguards meat, milk and produce destined for the province’s supermarkets and dinner tables.

Report finds faults
Among Peters’ findings:

The details left opposition party politicians fuming and journalists scurrying to file their stories.

And, after hearing those reports, millions of Ontario residents – with the Walkerton tainted water tragedy still fresh in their minds – undoubtedly found themselves asking: just how safe is the food we eat?

E.coli in food
It’s a question that won’t go away – not just in Ontario, but right across Canada.

Residents of Saskatchewan and New Brunswick confronted the same question just weeks after Peters’ report was released – when outbreaks of suspected food-borne E. coli O157 bacteria in those two provinces killed at least one person and sickened dozens more.

What’s more, by Health Canada’s own estimates, there are 2.2 million incidents of foodborne illness in Canada every year – with some observers, such as Doug Powell, scientific director of the Food Safety Network at the University of Guelph, suggesting the actual number is probably three or four times as high.

Education best recourse
What Peters’ report did, however, was focus attention directly on the inspection and testing systems we count on to safeguard our food supply. Although both he and Ontario’s Agriculture Minister Brian Coburn would soon declare that most of the cited problems had been fixed, their words only reinforced a key point:

  • For the average consumer, caught between alarmist headlines and calming official assurances, the best recourse is education.

This is an introduction to who inspects and tests our food supply, how and why it’s done, where it fails and how it could be better.

Armed with such knowledge, you’ll be better equipped to make informed decisions about what you eat-and about what questions to ask when politicians come looking for your vote in the next election.

Next page: The players

The players:

  • The Canadian Food Inspection Agency (CFIA) in Ottawa oversees the inspection and testing of all federally regulated food and food products.

Any food animal or food product that crosses a provincial or national boundary during production or sale is the CFIA’s responsibility. That jurisdiction amounts to more than 50 per cent of our entire food supply, including all imported foods and approximately 90 per cent of all domestic meat and poultry production.

The CFIA, which operates under the Ministry of Agriculture and Agri-Food, is a fairly new agency. It came into being in 1997, providing centralized accountability and control for work that had been previously spread across four federal departments (fisheries, agriculture, health, industry).

Areas of responsibility:
Besides food safety, its 4,800 employees are also responsible for the related areas of animal health and plant protection.

  • While CFIA administers and enforces food safety policy and standards, it does not set them- that’s Health Canada’s responsibility.

  • Provinces and territories oversee the balance of food inspection and testing.

Every province has its own formula, involving different rules, regulations and ministries, often depending on that province’s dominant commodities (beef, produce, fish, dairy, etc.).

If there is a trend at work, it’s toward greater integration and harmonization of food safety standards. Since the early 1990s, the provinces and Ottawa have had steering committees and other groups working toward a common Canadian Food Inspection System.

“This issue is top of mind,” says Gwen Zellen, director of the Food Safety Policy Branch of the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA).

Checks and balances
Ultimately, everyone has a role to play – producers, processors, retailers, restaurants and consumers alike. With the exception of the last group – you and me – all are also legally bound to do their work according to federal, provincial and occasionally municipal statutes.

In fact, virtually all of the inspection and testing processes carried out by government are checks that ensure these producers, processors and handlers are doing their jobs.

If they’re found wanting, government inspectors can order changes, suspend production, shut down facilities, even press criminal charges.

Stages of inspection:
At latest count, approximately 40 per cent of the CFIA’s 4,800 employees are inspectors.

They’re located throughout the country, carrying out inspections at thousands of federally licensed facilities.

In all, the CFIA has 18 regional offices, 185 field offices (including border crossings) and more than 400 offices in processing facilities and other nongovernmental establishments.

A large slaughterhouse or processing plant may have several dozen inspectors permanently on site. At many locations, the CFIA also has staff veterinarians to check out any animal that requires closer examination.

“Before slaughter, there are actually up to three stages of inspection,” says Richard Arsenault, the CFIA’s acting chief of meat processing and inspection facilities.

“First, there’s the company employees, who usually look at the animals before they get to the inspector. Then the CFIA inspector does a check. Following that, CFIA vets will have a look at any suspicious animals that are screened out.”

Inspectors use senses
After slaughter, all carcasses and animal parts are inspected once again.

The CFIA’s primary meat inspections are “sensory” – with inspectors using sight, smell and touch to look for sick or diseased animals. In larger critters, they also make incisions in lymph nodes and glands to better detect disease.

Of course, inspectors don’t just look at the animals themselves. They are also required to examine facilities for cleanliness and repair, for proper handling methods, temperature controls and a host of other measures.

Passing the tests:
Where inspection leaves off, testing begins.

“There’s a whole bunch of stuff that you won’t see in a visual inspection that you’ll want to test,” explains Arsenault.

He’s referring to microbial contamination (including E. coli, salmonella, listeria and campylobacter) as well as chemical residues (pesticides, arsenic, hormones, antibiotics and the like).

Unlike inspection, testing is not exhaustive. Instead, tests are done on statistically significant samples of products, based on historical knowledge of each commodity’s contamination risk.

Next page: Shelfish, produce testing

Shellfish testing:
Take domestic shellfish, for example: Harvested species infected with certain illnesses can contain biotoxins that are potentially deadly to humans. Outbreaks of these diseases can occur in very locally defined harvesting areas, so many tests are needed to sample enough potential sources.

In 2000, the CFIA conducted 9,300 tests for paralytic shellfish poisoning and a further 6,800 tests for amnesic shellfish poisoning.

As a result of these and other tests, the CFIA made 165 biotoxin closure recommendations to the Department of Fisheries and Oceans.

Produce testing:
Fresh fruit and vegetables are also subject to extensive chemical and microbial testing. In 2000, the CFIA inspected more than 13,000 samples of domestic and imported fresh fruit and vegetables for agricultural chemical residues.

Among domestic samples, 98.9 per cent were judged compliant with limits set out in the Food and Drugs Act. Compliance for imported samples was even higher, at 99.7 per cent.

Such high scores for imported fresh fruit and vegetables may not mesh with the public perception that such imports aren’t as safe as our domestic products, but Doug Powell of the Food Safety Network says it’s perfectly valid.

“Countries exporting fresh produce to Canada and the United States know where they get their U.S. dollars from. The stuff is often produced in pristine conditions. What they sell locally is somewhat different.”

Testing labs:
At present, the CFIA has eight testing labs across the country, staffed with microbiologists, chemists, research scientists and lab technicians. It also does testing right in processing plants.

However, in other cases a lot of the work is also contracted to private labs. In the case of chemical residue testing in meat, Arsenault says as much as 85 per cent of testing is contracted out.

In some cases, it saves the government money, he says. It also enables them to do more testing than they could if they were using just their own facilities.

Some critics of Canada’s system argue that for testing to be effective and reliable, it must be done by government staff. Is Arsenault concerned about the calibre of the private labs work?

“Not at all. It’s not like it’s somebody in a garage doing this work,” he explains.

No facility gets the job unless it meets standards set by the Canadian Standards Association, which bases its criteria on International Standards Organization requirements. In addition, he says, private labs must also participate in CFIA proficiency testing programs.

Control is critical
Given the importance attached to inspection, it might sound like heresy to learn that the CFIA is working toward a system where traditional inspection activities will play an ever-decreasing role. Yet that’s exactly the case. What’s taking its place? Auditing.

The change begins and ends with a long buzzword: Hazard Analysis Critical Control Point, or HACCP (pronounced “HA-sip”) for short.

Rather than relying on inspectors to come in and look for trouble, HACCP programs are intended to prevent problems before they occur-or, in a worse case, catch them before they get out of hand.

An internationally accepted system, the HACCP approach requires operators of farms, slaughterhouses, processing plants-any link in the system, essentially-to assess their operations and, using science-based methodology, identify critical points at which disease or contamination are most likely to intrude.

Minimize risk
The next step is to adopt practices that either eliminate or minimize the risk of error at these critical points. All of this is then recorded and documented and – once a program is formally “recognized” and approved by the CFIA – it then falls to CFIA inspectors to audit a facility’s compliance with its own HACCP program.

“Instead of us inspecting food and operations against procedures that we have written, we’re auditing against their programs,” explains Tom Graham, the CFIA’s national HACCP coordinator.

Mandatory for fish, poultry
Graham’s mandate includes all federally licensed facilities that handle meat, poultry, dairy, eggs, maple syrup and honey – approximately 2,000 operations in all.

Of those, approximately 350 operations have recognized HACCP operations in place. Meat and poultry operators are leading the way, says Graham, adding that he expects HACCP programs to become mandatory for all meat and poultry facilities before the end of 2002.

The formal name of Graham’s HACCP plan is the Food Safety Enhancement Program (FSEP). In a separate initiative, all 970 federally registered Canadian fish processing plants have developed and implemented a HACCP-based program called a Quality Management Program (QMP).

The QMP has reached the point where CFIA personnel conducted more than 1,000 audits of industry’s controls in fish plants in 2000. The compliance rate was better than 99 per cent.

Next page: Lax enforcement, fines

Lax enforcement, fines
Having all these inspection, testing and auditing procedures is well and fine, but without proper enforcement, there will always be those players who fail to do their part.

To some critics, inadequate enforcement powers remain one persistent weakness in the system.

For example, paltry fines and lax enforcement were two of the problems cited in auditor Erik Peters’ report on Ontario’s food inspection system.

During the 2000-2001 fiscal year, he found that the average penalty for non-compliance with food safety legislation was $320.

“That’s not much of a deterrent,” says Peters.

For this reason, he’s encouraged by Ontario’s new Food Safety and Quality Act, passed in December, 2001. Under the old rules, first-time offenders faced a maximum $2,000 fine.

Today, individuals can be charged up to $25,000 for a first offence, with corporations liable for fines as high as $100,000.

Feds detain, test
At the federal level, CFIA personnel work under 26 different acts and regulations.

According to Susanne Frost, the CFIA’s director of enforcement and investigation services, inspectors’ responses to violations typically move in stages.

  • They can detain suspect items and send them for testing
  • They can hold back products until a producer or processor makes them compliant
  • They can order a production halt or lift a license until corrections are made.
  • The final stages see them referring cases to superiors where charges can be laid as either “regulatory” offences or referred in turn to the justice department for criminal charges.

Unlike with some provincial statutes, Frost says inadequate financial penalties are not a concern.

“Most offences carry maximum penalties of up to $250,000.”

Next page: Judges more aware

Judges more aware
Of greater concern has been the court’s unwillingness to levy fines anywhere near that limit. But lately, Frost says, this has been changing.

“It used to be that most fines levied under the Food and Drug Act [a key tool for CFIA staff] were in the hundreds or low thousands,” she says. “But today they’re much more often in the ten-, twenty- and thirty-thousands.”

Frost says a key force that’s pushing up those fines is increasing consumer concern.

“Judges are becoming increasingly aware of the potential impact of these infractions and violations.”

Are systems effective?
Ultimately, for most Canadians, the devil is not in the details listed above but in the food that’s in their fridges and on their plates-is it safe? Does the system do an effective job?

Certainly that was the message Erik Peters was affirming after his latest report made headlines.

“We didn’t go from a basis of saying we found it was unsafe,” he says. “Our conclusion is that the food was safe, but the risk could be reduced that we were consuming unsafe food. It’s a risk management area. You can never be 100 per cent sure.”

As you’d expect, CFIA and other federal officials are quick to declare Canada’s food safety system among the best in the world.

And while there’s no shortage of interest groups and third parties willing to throw in their two cents worth, the list of reasoned, informed, relatively independent observers is somewhat shorter.

The Food Safety Network’s Powell appears to fit that bill. To him, the mere fact that we continue to have outbreaks of food-borne illness is proof that the system could be better. A big supporter of HACCP-based programs, he says he is buoyed by some of the work he sees coming out of the CFIA.

“It depends,” he says. “They’ve got a huge responsibility. To say I’m generally supportive would be an overstatement.”

Measuring food safety
In particular, Powell says there are programs and policies in place elsewhere-especially the United States-that have the potential to do the job more effectively than our current system.

Recently, Powell published the following five points that he says should be the measure of a great food safety system:

  • Effective and rapid surveillance systems.
  • Effective communication about the nature of risk.
  • A credible, open and responsive regulatory system.
  • Demonstrable efforts to reduce levels of uncertainty and risk.
  • Evidence that actions match words.

Asked to assess our system against these criteria, he saves his highest praise for the latter components. On the first point, he’s extremely critical.

“Our surveillance sucks,” says Powell.

The problem, he says, is that we’re still largely dependent on a “passive” system for reporting, tracking and responding to food-borne illness outbreaks.

U.S. model systems
Powell advocates immediate adoption of two related systems that were put into place in the United States in the late 1990s-Foodnet and Pulsenet. Both are “active” surveillance systems that attempt to catch and detect problem outbreaks before their effects are severe.

  • Foodnet is a system where officials routinely sample human stool samples collected for other purposes, looking for well-known bugs.

This helps them detect the presence of bacteria like E. coli in the earliest stages of outbreaks.

  • Pulsenet steps in every time a person gets sick with a food-borne illness.

Stool samples are collected and officials take a “genetic imprint” of the bacteria that then goes into a database where it can be readily compared against other cases elsewhere.

Anytime there’s a match, it suggests a common bacterial source. Powell says Pulsenet already can be credited with preventing many serious outbreaks of food-borne illness.

Complaints good sign
For all of his harsh criticisms, however, Powell does offer a few reassuring last words for Canadians.

“I have to say our food is safer now than it ever has been,” he says. “We’re hearing about more problems, but what that really means is that the issue is getting more attention and more coverage. In the ‘good old days,’ we just didn’t know what it was when people got sick from food.”