The Canadian Food Inspection Agency might be trying hard to protect Canadian consumers from unsafe imported food. But, the simple fact is the agency is too broke to keep such products from store shelves.

Canada’s import food inspection is a patchwork that ignores some products, while others are examined, with little apparent logic to explain why. For Canadians watching daily reports about Germans falling ill and dying from food contaminated with a new variation of the E. coli bacteria, this knowledge will be cold comfort.

Proactive testing and inspection, other than trend monitoring or project work, is beyond the scope of CFIA’s current front line inspection resources. In fact, the inspection of food imports in Canada is one of the weakest components of the CFIA’s work.

There are only a handful of inspectors assigned to imports for food safety purposes. CFIA can afford to only temporarily assign inspectors to monitor imported food products. While one-off projects such as the Food Import Surveillance Team (FIST) are welcome, FIST has a small complement of inspectors and funding is temporary – for one year only.

The only inspectors dedicated to food imports 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. But inspectors have no latitude when it comes to export products. Where certification is required, a CFIA certificate for food exports is 100-percent mandatory.

When it comes to inspection of food imports, however, the CFIA has wide discretion to allow items 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 a situation in which 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 two per cent of food imported into Canada is inspected. And the vast majority of import inspections are conducted to protect plant and animal health, not to protect human health.

Inspections of products intended for human consumption are conducted primarily to monitor trends and not to prevent dangerous goods 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 of 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 such as 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. Since 2007, for example, CFIA has not been able to conduct an audit to ensure that food safety systems in China measure up to Canadian standards. To our knowledge, the only foreign country equivalency assessments conducted in 2010 took place in the United States.

But, it’s not just food imports where the CFIA is not able to meet its mandate to safeguard Canadians. 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.

Against this backdrop, the government plans to invest with one hand and cut with the other.

In the next two years, the federal government plans to invest an additional $18 million in food safety inspection. At the same time, the controversial program spending review that Ottawa is conducting could end up cutting more than $70 million from the CFIA’s budget.

The CFIA plans to regulate food imports. This is a good idea in principle, but who will enforce the regulations?

So, regulating and licensing food importers may improve appearances only. Meanwhile, our food safety regulator will continue to lack the resources to inspect imported foods, leaving Canadian consumers exposed to potentially dangerous products.

Bob Kingston is president of the Agriculture Union-PSAC which represents federal food inspectors.

© The Ottawa Citizen

Well, maybe not.

According to sources within the CFIA, a secret deal to win mention in the March 2011 budget that will be re-tabled next week may actually result in a cut to the Canadian Food Inspection Agency budget.

The CFIA is said to have made a commitment, no one has publicly disclosed, to cut its own spending by $35 million in exchange for the boost to its food inspection allocation contained in the pre-election budget. 

The problem for food safety is that Flaherty’s plan has only $18 million flowing to the CFIA in the first two years, leaving the Agency in a financial hole in the short term, with the balance apparently coming in 2013 and beyond.

Official spokespeople for CFIA have refused comment on this story citing budget confidentiality.

“If this is true, Finance Minister Flaherty has misrepresented a food inspection budget increase as something much bigger.  And, the CFIA has agreed to a $35 million budget cut in exchange for $18 million and an IOU that may never be honoured given the government’s intention to slash spending,” said Bob Kingston, President of Agriculture Union – PSAC, which represents federal food inspectors.

The upcoming operating and strategic review will require departments and agencies to cut spending by 10% or more which represents $72 million to the CFIA’s budget.  In addition, the CFIA has already had to absorb salary increases from existing budgets which has reduced the Agency’s food safety capacity.

According to the Budget tabled in Parliament on March 22^nd the $100 million investment over five years was to “enable the Government to complete its response to all of the recommendations of the Weatherill Report through targeted investments in inspector training, additional science capacity, and electronic tools to support the work of front-line inspectors”.

“The bad news for consumers is that Ottawa has not come close to fixing the food safety and inspection problems that Sheila Weatherill found at the root of the Maple Leaf deaths.  And, if this behind the scenes deal is true, the CFIA will not be able to.  I hope Minister Flaherty comes clean on June 6^th and comes up with the resources our food safety system so desperately needs,” Kingston said.

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OTTAWA – The federal government has suspended inspection activities indefinitely that were meant to make sure food companies and restaurants don’t mislead consumers with underweight products or exaggerated nutrition claims, Postmedia News has learned.  [More...]

CFIA abandons key consumer protections

Ottawa (28 April 2011) The Canadian Food Inspection Agency has abruptly and without explanation cancelled or deferred inspection activity in important areas designed to protect consumers from unsafe food products and fraudulent practices.

According to CFIA documents released this morning by the food inspectors’ union, the CFIA has indefinitely deferred inspection activities related to ensuring that consumer products available in retail outlets are not fraudulently under weight.  In addition, sources have revealed that the CFIA has cancelled outright its restaurant menu verification program.

Widespread fraudulent activities related to deliberate mislabeling of products in grocery stores has recently come to light as a result of media investigations, work that should be done by the CFIA.   And, new studies have just been published demonstrating that consumers can be fooled by inaccurate and misleading labels into buying products they would not otherwise purchase.

“What would our political leaders say if they became aware that the CFIA is ramping down its consumer protection activities, at the very time when industry practices show clearly consumers need protection?” asked Bob Kingston, President of the Agriculture Union – PSAC, which represents federal food inspectors.

CFIA has gradually been reducing its regulatory oversight activities in the area of consumer protection.  According to the documents released this morning, routine CFIA surveillance of the declared weight of products has been “deferred”.  This means that any producer or retailer is now free to fraudulently claim that their product weigh s more than it does in fact. 

“Just like everywhere else, there are bad apples in the food industry that have demonstrated time and again they cannot be trusted.  When the CFIA withdraws from its regulatory oversight responsibilities – as they are now doing — food manufacturers and retailers take advantage, to the detriment of consumers”, said Bob Kingston

In addition, the CFIA has indefinitely cancelled inspection activities related to ensuring that restaurants menus are accurate and not fraudulent descriptions of their offerings.  This means that restaurants are now free to make whatever claims they want about the nature of the foods on their menus. 

“Claims that menu items are organic, or free of trans fats, or locally produced, can now be made by restaurants safe in the knowledge that no inspector from the CFIA will be checking, unless someone complains,” Kingston said.

“CFIA does not have the resources to fulfill its mandate.  As a result, it is dropping activities it considers to be ‘low risk’, all the while hoping that nothing bad happens as a consequence,” Kingston said.

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 For information: Jim Thompson 613-9592

Imported & Manufactured Food Program (IMFP)

Annual Memo to Inspectors 2011/2012

Purpose

The purpose of this memo is to highlight to CFIA Inspectors responsible for delivering IMFP work specifications, important changes made to existing work activities and to introduce new activities planned for the 2011/2012 fiscal year. 

1.  General Updates

This year marks the introduction of a program-wide initiative to promote a distinct and unified IMFP identity through the implementation of standardized work activity documents which utilize common nomenclature, document appearance and organization. All IMFP WSs outlining written work activities will now formally be referred to as Work Specifications (WSs). They will include a new and simplified coding system to facilitate easier identification of each WS. These IMFP WSs fall into one of four categories:

1) Joint WSs, 2) Manufactured Food (MF), 3) Retail Food (RF), 4) Food Safety (FS)

Table 1:  2011/2012 IMFP Work Specifications

Note: For all 2011/2012 Work Specifications and until further notice:            

i) Net quantity verification activities are deferred, and  

ii) Samples will only be taken to support inspection observations where non-compliance is suspected.

1.1 Contact Information

Please note that a new format has been developed for the list of contacts which are normally provided at the end of each WS. The “Contacts” section of each WS will now contain hyperlinks to two contact lists a Specialist Contact List and a Laboratory Contact List, each will bring users to a master document containing all of the required contact information for each individual WS and each FEN0/FS code lab contact, respectively. Storing this information in one central document will facilitate prompt and accurate updates when there is a change.

1.2 References Section

Most of the information which has historically been found within the “References” or “Appendices” sections of each IMFP WS’s, has been collected into one central RDIMS document; now only the link will be provided in each respective WS. This will enable efficient information management of the supplementary information that is provided to inspectors.

1.3 Sampling

For the fiscal year 2011-2012, FEN0 samples will be taken during inspection.

1.3.1 Inspection FEN0 Samples

This year both the WS code (e.g. WS_JUIC) and the SPRINT inspection number should be entered into the comments section of the LSTS form when samples are sent to the CFIA labs for analysis. This will improve our data and reporting capabilities and will enable us to link each LSTS form with a corresponding WS.

All unsatisfactory lab results for samples taken during inspection must now be entered into IMS to enable better tracking of the follow up related to unsatisfactory LSTS results.

2.  Joint Work Specifications

2.1 General Notes

To the extent possible, it is recommended that both the MF (labelling) and FS inspections be conducted in each establishment, for each WS. However, it should be noted that a full inspection doesn’t necessarily need to include both an FS and MF components. For example, if an allergen concern is identified for a particular establishment, inspection for allergen and applicable labelling controls should be conducted. However, inspection/sampling for micro would be based on operational priorities.

The coordination of MF and FS inspections will be the responsibility of each inspection office/region as they see fit.

WS inspections will not be conducted in registered facilities by IMFP inspectors.

2.2 Joint WS Details

Juice (WS_JUIC): 

This WS is new for 2011/2012 and will involve MF, FS and RF groups. The WS will continue to examine both apple juice and non-alcoholic cider products, but will now be expanded to include other non-federally registered (NFR) juice products, including those made at retail.

It is important to note that this WS will not include frozen novelties, semi-solid products (such as fruit gushers) and candies that contain juice.

This WS will be delivered in three distinct phases: a retail survey, which will be conducted by MF inspectors in Q1of 2011/2012, survey result analysis and associated policy development/clarification in Q2 and the inspection phase will commence in mid-Q2.

Data collected in Q1/Q2 will be shared with the RF and FS groups prior to commencement of their inspection activities in late Q2/Q3.

 Table 2: Juice WS Delivery

 Confectionery (WS_CONF):

This WS is new for 2011/2012 and will involve MF, FS and RF groups. 

 This WS will be delivered in three distinct phases: a retail survey, which will be conducted by MF inspectors in Q1of 2011/2012, survey result analysis and associated policy development/clarification in Q2 and the inspection phase will commence in Q3.

Data collected in Q1/Q2 will be shared with RF and FS prior to commencement of their inspection activities in late Q2/Q3.

This WS is also new for 2011/2012, will have Retail section involvement and will also be delivered in phases:  a retail survey will be conducted by MF inspectors in Q1 of 2011/2012, Survey result analysis and associated policy development/clarification will be conducted by HQ/areas in Q2, and the inspection phase will commence in Q3.

 Table 3: Confectionery WS Delivery

Grain-Based Infant & Toddler Foods (WS_GRA):

The scope of this WS has been expanded to incorporate grain-based foods for young children up to 3 years of age and to examine additional hazards such as undeclared allergens.

It should also be noted that when sampling for mycotoxins, inspectors should limit the products selected to only breakfast-type cereals and infant foods, since snack foods which contain fat may significantly interfere with lab analysis. 

Spices (WS_SPIC):

The scope of last year’s WS included only those spices for which a standard existed (FDR Part B, Division 7). This year, the scope has been expanded to incorporate spice blends and seasoning mixes as it was recognized that both labelling and FS issues can exist in these products.

Border Blitz (WS_BLITZ):

This WS was formerly known as the BIPEIV (or WD004). In an attempt to simplify this former work description, the activities have now been split into 2 separate work specifications:

1) Border Inspection activities, which formerly made up the “BI” portion of the BIPEIV, will now be captured under the Border Blitz WS (WS_BLTZ).

2) Post Entry Import Verification activities, which formerly made up the “PEIV” portion of the former BIPEIV work description will now be captured in the Import Compliance WS (WS_IMPC).

Import Compliance (WS_IMPC):

This WS will be used to assess importer’s controls for food safety hazards and labelling and advertising compliance. This WS will serve as a “catch-all”, enabling inspectors to inspect importing establishments that are not captured in a commodity-specific WS.

 This WS will involve both MF and FS inspection staff and will incorporate activities from the former Post-Entry Import Verification (PEIV) work description, from MF project 0111, and from the former WD003 – Allergen Controls at Importers.

 All MF work conducted in conjunction with this WS should be coded in SPRINT under the 0111 code.  However, to enable the collection of inspection data, that is representative of each respective inspection activity, additional and  more accurate coding information will be required in SPRINT.  Inspectors will now be asked to include the following coding information under the “reason for visit” field:

o     “PV” – should be included to capture information for inspection activities that have occurred as a result of information obtained from the Canada Border Services Agency (CBSA) or an Area Import Centre (activities that would have formerly been done under PEIV) post-entry import verification activities.

o     “AL” – should be included to capture Allergen Inspection activities.

o     “M” – should be used to capture all other non-compliant inspection activities.

Domestic Manufacturing Compliance (WS_DOMC):

This WS will be used to assess domestic manufacturer’s controls for food safety hazards and labelling and advertising compliance. This WS will serve as the “catch-all”, enabling inspectors to inspect domestic establishments that are not captured in a commodity-specific WS.

 2.3 Clarification on coding of WS_DOM and WS_IMP Activities:

 Food Safety (FS) – Inspectors are reminded that activities related to food safety complaints, investigations and follow-ups should not be coded as WS’s. These activities should be coded under their appropriate complaint/investigation/follow-up code eg. FS300/301, FS500/501, FS700/701 (or F where applicable).

 Manufactured Food (MF) & Retail Food (RF) – Inspectors may code inspection activities related to complaint follow-up as falling under a specific work specification (WS) when a significant amount of the activities required by the WS have been completed in the process of following up on these complaints.

 3.  Dedicated Work Specifications

 3.1 Retail Food Work Specifications

 Establishment lists and random selection instructions have now been added to each retail WS, providing retail inspectors with a reference listing of retail establishments which also includes the date of last inspection.

 To ensure that information is accurately recorded in SPRINT, more detailed instructions have now been added to each RF WS regarding SPRINT data entry.

 In an effort to target high-risk retailers, the percentage of planned (surveillance) inspections has been increased by 25% for WS_RFC and WS_IFR.

 3.2 Food Safety Work Specifications

 The scope of WS_SYR (or FS410 Maple) has been expanded to include all tree syrup and tree syrup products. This will accommodate the inspection of additional establishments for which lead contamination is of concern. 

 RDIMS#: 2705766, v5

Document Name : IMFP Annual Memo for Inspectors 2011/2012

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