To: Members of the Standing Committee on Agriculture and Agri-food
The inspection of food imports in Canada is one of the weakest components of the CFIA’s work. Consider:
There are no inspectors dedicated to imports for food safety purposes
CFIA cannot afford to dedicate full time inspectors to ensure the safety of imported food products. The only inspectors dedicated to food imports (in the Destination Inspection Service) are wholly funded by industry and their purpose is purely commercial — to determine the quality and grade of imported products, and therefore their market value — not to identify threats to public health and safety.
CFIA inspectors are responsible for the inspection of both import and export food products
For CFIA, certifying food exports is 100% mandatory. When it comes to inspection of food imports, however, the CFIA has wide discretion to allow them onto grocery store shelves uninspected. This creates an impossible balancing act for inspectors and the CFIA who are subject to heavy pressure from the Canadian food industry to certify their shipments for export. Everyone knows the unofficial priority is export certification. In the present resource-starved circumstances, CFIA and its inspectors are too often faced with an impossible balancing act where the inspection of imported products always takes a back seat to export certifications.
Stopping unsafe food from reaching grocery shelves is not the purpose of import inspection and less than 2% of food imported into Canada is inspected
The vast majority of import inspections are conducted to protect plant and animal health, not human health. Inspections of products intended for human consumption are conducted primarily to monitor trends and not to prevent dangerous good from reaching store shelves. For example, in the unlikely event that the CFIA inspects a shipment of fresh produce that is observed to be contaminated by an insecticide or fungicide (because it is covered with a coat white powder, for example), results from laboratory tests would not be available until long after that product had reached the dining room table.
Inspectors and consumers have no way of knowing what treatments have been applied to imported raw products like fruits and veggies
Importers of raw fruits and vegetables must declare only those treatments required by Canadian import regulations; any other chemical treatments not required to gain access to Canadian consumers do not have to be declared. Knowing this, CFIA inspectors take appropriate precautions, such as wearing protective clothing and/or breathing apparatus, when inspecting these kinds of imports because they have no way of knowing what poisonous or dangerous chemicals have been applied to the products they are handling. Unfortunately, downstream food handlers and consumers are unaware that such precautions may be necessary.
CFIA is not able to ensure equivalency with Canadian standards in the food safety systems of countries that export food to Canada
To our knowledge, CFIA has not conducted any periodic foreign country equivalency assessments in 2010 with the exception of the United States (a report on this audit was posted on CFIA’s website on November 15th). Unless it’s a special situation they just don’t go to foreign countries. This is in spite of the fact that the CFIA’s internal audit of the Management of Imported Food Safety released in July 2010 included this troubling finding:
“According to the Import Control Policy, greater emphasis was to be placed on foreign country equivalency assessments and audits to reduce dependence on downstream controls (e.g. for border point of entry or destination controls). While initial foreign country equivalency assessments were conducted with some countries (e.g. United States), periodic foreign country equivalency audits are only partially delivered and no foreign country equivalency controls are in place for food commodity programs other than meat, fish and seafood, and egg. Imports of other food commodities rely almost exclusively on destination inspections and projects.”
79% of food imports come from ten countries – US, Mexico, China, France, Italy, Brazil, Chile, Thailand, Australia and the UK. Apart from the US, were any periodic equivalency audits done in 2010?
The Management of Imported Food Safety Audit also found:
- “Consistent, comprehensive training was not evident in all programs particularly where higher work pressures exist.”
- “Staff resources have not been re-allocated to address changing import priorities, leading to difficulty in providing sufficient staff resources where significant increases in import related workloads have occurred. Workload increases were particularly evident in Toronto region.”
- “Sampling plans in some programs are partially under-delivered making it difficult to assess to what extent compliance is achieved. Systems to track current compliance and verification activities are not available for all programs.”
CFIA needs additional resources for import food inspection and has asked Treasury Board for more
In its response to the July 2010 Audit of the Management of Imported Food Safety, CFIA declare that it is awaiting a response to its Treasury Board submission for additional resources. Details of CFIA’S request are unknown. In the meantime, every CFIA program apart from processed meat inspection is under tremendous resource pressure. For example, vacant positions in all programs except meat hygiene are not being filled.
CFIA faces funding cut
Against this backdrop, CFIA faces a significant cut to its budget of $1.8 million due to the salary freeze announced in the 2010 Budget, according to the Supplementary Estimates (B). The CFIA’s plan to eliminate clerical positions will shift a significant administrative burden to frontline inspectors who will have less time to do their jobs to safeguard Canadian consumers.
CFIA’s plans to regulate food imports are a good idea in principle, but who will enforce the regulations?
CFIA simply does not have the inspection and enforcement resources to adequately discharge its mandate when it comes to domestic food production. So, regulating and licensing food importers will improve appearances only.
For information: Jim Thompson 613-447-9592