Presented by Bob Kingston, Oct 2, 2012
Mr. Chair, Honourable Senators, it is a pleasure to be here this evening to discuss Bill S-11.
By way of introduction, the Agriculture Union represents all federal employees working in the federal agriculture portfolio. I am a full time officer, on leave from the CFIA where I have 25 years experience as an inspector including 15 years as an inspection supervisor.
Without a commitment on the part of the government to ensure adequate resources are available Canadians cannot expect improvements in food safety outcomes from this Bill alone.
Too often budget has been the main determining factor in the design and/or delivery of CFIA’s inspection and food safety program, exposing Canadians to higher risk than should be the case.
If we are not careful, the successful enactment of Bill S-11, as well as CFIA’s new Inspection Modernization initiative could fall victim to these pressures as did the Compliance Verification System, or CVS, before them.
Cast your memories back to the summer of 2008, just months before the Maple Leaf Foods outbreak.
The CFIA had just launched CVS.
Without a serious pilot phase and before any lessons learned in development could be implemented, the Agency had no idea how many inspectors were needed to do the job under CVS or what skills and training they might require.
At the same time, more direct inspection oversight was retired deliberately or because inspectors, overwhelmed by the paper work demands of the new system, could not keep up with their more traditional duties.
Then the perfect storm of the Maple Leaf Foods outbreak occurred. We all know what happened.
It’s worth re-visiting some of the observations Sheila Weatherill included in her report.
She found that the Compliance Verification System was flawed and in need – and I quote – of “critical improvements related to its design, planning and implementation”.
She also found that the CVS was – and I quote again – “implemented without a detailed assessment of the resources available to take on these new (CVS) tasks.”
In the aftermath of the 2008 disaster, it was discovered that Maple Leaf was under no obligation to report to the CFIA test results showing contamination in the plant.
In a system which increasingly relies on companies to police themselves, this shortcoming was addressed.
Now all companies have a mandatory duty to test and report positive results to the CFIA.
Fast forward to today.
XL Foods, one of the biggest meat processors in the country, has just thumbed their noses at this requirement, and the CFIA did not have the resources in place to fully understand what was going on in that plant.
How could this be, you might wonder. After all, Minister Ritz has assured everyone that there are more inspectors working at that plant than ever.
You will be interested to know that at the XL plant only a small portion of inspectors are fully trained in CVS.
More than four years after CVS was introduced, most inspectors there have not been trained in how to use it.
There’s a simple answer.
CFIA cannot afford to deliver the training any faster and does not have enough inspectors to relieve those away being trained. As well, resources are often diverted to address crises which further derails training.
Because of the pace of production and other factors, those with CVS knowhow at the XL plant did not always share the results of CFIA conducted CVS tasks and tests so other inspectors would have no idea if there was a problem that required heightened vigilance.
This situation is not isolated to XL.
This is yet another example of industry self-policing gone wrong because the CFIA is not adequately resourced to verify compliance.
Returning to the matter before this committee…
Many say that S-11 will make imported food safer because importers will be required to obtain a license from the CFIA.
This could be more illusory than real with the cuts at the Agency this year.
Who will oversee the 10,000 new licencees the CFIA estimates will be covered by this new requirement to ensure they are in compliance with safety requirements?
As a result of downsizing in the federal public service, approximately 170 administrative staff positions at the CFIA have been eliminated.
These are the people who would initiate, evaluate, approve and monitor the performance of these new licencees. With 100 fewer inspectors on the job – again as a result of downsizing in the public service – you can see that this new licensing regime could potentially be little more than a paper exercise.
Back to Weatherill for a moment.
She recommended an independent resources audit to – and I quote again – “accurately determine the demand on its inspection resources and the number of required inspectors”.
While CFIA did not conduct such an audit, it did review the situation in the processed meat program. The result was that the Agency almost doubled its complement of processed meat inspectors.
I hazard to guess that if the CFIA did a similar review of its other inspections programs like fish and meat hygiene slaughter, they would find that a similar upward adjustment is required to adequately deliver those programs.
I urge the committee to amend this bill to make such a review mandatory.
I note that an amendment has been put forward by the government, but it does not require an resource audit of CFIA until five years after this bill becomes law. That’s like crossing your fingers and hoping nothing bad happens for five years. We already know CFIA has a problem. Don’t wait for another outbreak before addressing it.
The government’s amendment does not require the results of the audit to be made public. This shortcoming must be fixed as well.
One final point.
I mentioned that the CFIA is currently revising its inspection program which is likely to involve a reallocation of resources. I am concerned that executives at the CFIA will see Meat Hygiene Slaughter as resource rich.
In something akin to moving deck chairs on the Titanic, CFIA may think they can rob the program that let us down at XL Foods and reallocate resources to other areas which need to be shored up.
In closing, if Canada’s food safety system is to be a true partnership between government and industry, self-policing on the part of food companies must be reigned in.
To paraphrase the words of Ronald Regan: don’s simply trust; verify.
With a cop in the rearview mirror, people obey the traffic laws. The same holds true in the food industry.