Report Card

d minus

Federal government fails on food safety inspection & enforcement

On July 21, 2009, Sheila Weatherill made public the results of her investigation into the Maple Leaf Foods listeriosis outbreak which left 22 dead and dozens more seriously ill.

Almost half of Ms. Weatherill’s recommendations (23 of 57) to prevent another outbreak were directed toward the underfunded Canadian Food Inspection Agency. With its mandate to inspect sanitation practices and enforce food safety requirements, the CFIA was widely seen as failing to protect Canadian consumers. Ms. Weatherill established these important findings of facts in her report.

FACT The Canadian Food Inspection Agency (CFIA) failed to do mandatory safety audits of the Maple Leaf Foods plant which produced the tainted cold cuts for years prior to the outbreak.
FACT A new inspection system (the Compliance Verification System or CVS) implemented just before the outbreak was flawed and in need of “critical improvements related to its design, planning and implementation”.
FACT The CVS was “implemented without a detailed assessment of the resources available to take

on these new (CVS) tasks”.

FACT A shortage of food safety inspectors was in play before the outbreak. “In the lead up to the outbreak the number, capacity and training of inspectors assigned to Bartor Road (the tainted Maple Leaf plant) appear to have been stressed due to their responsibilities at other plants, the complexity of Bartor Road including its size and hours of operation, and necessary adjustments required by the implementation of the CVS.”

In short, Ms. Weatherill found that there are too few inspectors covering too much territory, hobbled by a new inspection system that never worked properly.

Six months after the Weatherill report and almost 18 months after the outbreak, little visible progress has been achieved. Little has been done to fix and properly staff the inspection system to ensure the food we eat is safe because of an absence of political will and commitment on the part of the federal government. The food inspector shortage remains and it’s only a matter of time before the next outbreak.

The federal government has earned a failing grade
on food safety inspection and enforcement. D-

Food Safety Inspection and Enforcement

Theme Recommendation Status Grade
Resources 7. To accurately determine the demand on its inspection resources and the number of required inspectors, the Canadian Food Inspection Agency should retain third-party experts to conduct a resources audit. The experts should also recommend required changes and implementation strategies. The audit should include analysis as to how many plants an inspector should be responsible for and the appropriateness of rotation of inspectors. An independent resource audit has not begun; inspectors continue with the same impossible workload. F
Resources 8. The Canadian Food Inspection Agency should ensure that inspectors receive timely education and training specific to each function which they perform. This should be based on an assessment of the additional training required to address gaps in the knowledge and abilities of inspection staff. Inspectors should regularly receive a mandatory program on current trends in science and technology in the processing of food, including compliance and verification processes. No new training initiatives have been launched since the Weatherill report. F
Resources 9. The Canadian Food Inspection Agency should equip its inspectors with modern technology (e.g. e-note pad) to increase their efficiency. Technology available to inspectors has not changed. Most inspectors rely on communications technology from the last century; there are inspectors who do not have cell phones or computers; many do not have access to high speed Internet. F
Resources 10. The Canadian Food Inspection Agency should amend its meat inspection system (CVS) to ensure:

a. the appropriate human resources are available to respond to workload requirements;

b. comprehensive training based on required competencies and skills; timely delivery of on-going training;

c. supervision of inspection staff structured to encourage enterprise and accountability.

The Compliance Verification System remains unevaluated and under resourced. F
Resources 51. The Canadian Food Inspection Agency should ensure that the Office of Food Safety and Recall has dedicated resources to undertake all the CFIA activities concerning recalls. The Office of Food Safety and Recall should be identified as the CFIA’s primary point of contact with Health Canada during a national foodborne emergency. The Office of Food
Safety and Recall already has dedicated resources but they are insufficient.
F
Inspection Process 15. The Canadian Food Inspection Agency, in conjunction with and in conformity to the proposed revisions to Health Canada’s Listeria Policy, should strengthen its February 2009 Listeria controls found in the Meat Hygiene Manual of Procedures to focus on control measures for Listeria in ready-to-eat meat products, in addition to the current environmental and product testing:

a. to ensure that any required testing is a verification step to confirm the effectiveness of the company’s Listeria control program and not
a control program in itself;

b. by differentiating the testing requirements to reflect the risk associated with each product (i.e. more testing for high risk products and less for low risk ones);

c. by requiring the testing of non-food contact

surfaces in the processing environment;

d. by establishing ‘hold and test’ product control requirements following positive test results for Listeria on food contact surfaces as follows:

i. several tests for Listeria on food contact surfaces should be conducted immediately on and around the area where positive results were found to determine:

  • if there is persistent contamination, or
  • if the previous positives have already been dealt with using standard sanitation procedures;

ii. if the follow-up tests are positive, then testing for Listeria monocytogenes must occur in products from the production line of concern During this testing phase, all products produced on that line and day (i.e. between two complete sanitation shifts) should be withheld from the marketplace until the results are known;

e. by further defining expectations of trend analysis to identify weaknesses in the company’s control programs (including its HACCP plan) by determining if a pattern of contamination is emerging.

This recommendation was implemented prior
to Ms. Weatherill’s report.
But with no additional
resources, other aspects of food inspection have suffered.
B for

CFIA

F for gov’t

Inspection Process 16. The Canadian Food Inspection Agency should revise its monitoring programs (M-200 and M-205 plans), by tailoring the sampling frequencies to each plant based on risk factors including compliance history, product risks and target market (i.e. higher sampling frequency in some plants, lower in others.) Monitoring remains one size fits all; no change since report. F
Inspection Process 17. The Canadian Food Inspection Agency should review and update existing food safety programs, regulations and directives to best reflect current food safety practices. Programs, regulations and directives remain unchanged since report. F
Inspection Process 18. The Canadian Food Inspection Agency should update its Food Safety Enhancement Program Manual to require food processors to include all standard operating procedures and good manufacturing practices in their food safety plan. No action since report; no production facilities have had to re-submit HACCP plans. F
Inspection Process 19. The Canadian Food Inspection Agency should ensure that the Meat Hygiene Manual of Procedures is updated whenever there is a significant change to the practices imposed on industry. Meat Hygiene Manual of Procedures is under review. C-
Inspection Process 48. To ensure timely and consistent enforcement practices across the country, the Canadian Food Inspection Agency should review the interpretation and application of its rules and enabling legislation. No visible action. F
Communi-

cations

20. The Canadian Food Inspection Agency should formally communicate its expectation that registered meat processors will bring all information with potential consequences for food safety to the attention of their assigned inspector in a timely manner. A memo was sent to industry. C
Communi-

cations

26. Where human deaths or serious illnesses have occurred, the Canadian Food Inspection Agency should promptly disclose the results of its investigation of the implicated plant and the corrective actions taken, to the public and food safety partners. N/A (thank goodness).
Communi-

cations

31. The Canadian Food Inspection Agency should establish a formal protocol to ensure that timely and consistent information is provided to staff of the provincial/territorial or local public health organizations who are asked by the Agency to help it complete post-recall verification activities. No changes since report. F
Inspection Process 32. In providing information related to a given product recall to the distribution industry, including grocers, the Canadian Food Inspection Agency should use a standardized form (as suggested by the Canadian Council of Grocery Distributors). No change. F
Inspection Process 38. The Canadian Food Inspection Agency and the Public Health Agency of Canada should enhance their public profile to increase awareness of their mandates. No new public relations

initiatives since the Weatherill report.

F
Inspection Process 47. As a regulatory agency, the Canadian Food Inspection Agency should create a formal and transparent consultation strategy which will define its required engagement with stakeholders. There is nor formal and transparent consultation process; currently, consultations take place behind closed doors that shut out public engagement. F
Governance 44. As soon as possible, the Canadian Food Inspection Agency, supported by independent experts, should initiate a comprehensive review of

a. its organizational structure;

b. the current delegation of responsibility and lines of accountability within the Agency; and

c. its decision-making processes

This task has been assigned to the Deputy Minister of Agriculture whose independence has been questioned. C-
Governance 49. The three main lines of business of the Canadian Food Inspection Agency, food safety, animal health, and plant health should be assisted by permanent expert advisory committees to guide their evolution. This change may require amendment of the Canadian Food Inspection Agency Act. No amendments have been introduced into Parliament. F
Governance 50. The Office of Food Safety and Recall should report directly to the office of the President of the Canadian Food Inspection Agency. Even though there have been changes to the reporting structure, the Office of Food Safety and Recall currently does not report to the CFIA President. D
Recalls 29. Health Canada, the Canadian Food Inspection Agency and the Public Health Agency of Canada should review, update and publish the criteria for proceeding with a food recall to ensure that the weight of evidence takes into account epidemiological information, including suspected illnesses and deaths, geographic distribution, and food sample test results whether packages are opened or unopened. CFIA completed an evaluation of the Food Recall and Emergency Response System prior to the release of the Weatherill report, a process that began almost five years ago. Since then, no additional review has been undertaken. D
Recalls 30. The Canadian Food Inspection Agency should encourage federally regulated meat processors to move beyond the minimum existing requirement for accessibility of distribution records to include electronic access in non-proprietary and unlocked formats to assist in potential product recalls. No action. F