The midnight oil has been burning most evenings for the past several months in Canadian Food Inspection Agency (CFIA) offices across the land.
On May 17, 2013 the CFIA published Annex O, “Policy on the Control of E. coli O157:H7/NM Contamination in Raw Beef Products” in the Manual of Procedures for Meat and Poultry Products. Two weeks later the “Independent Review of XL Foods Inc. Beef Recall 2012” was released. This was followed days later by the Harper government’s announcement that it was going to invest “nearly $16 million over three years to establish Inspection Verification Teams (IVTs) to oversee the performance of Canada’s entire food inspection system.” Then on July 2 the agency released the long-awaited “Final Model of the Improved Food Inspection Model” with the headline, “Inspection Modernization – Optimizing Confidence in Food Safety.”
These reports are supplemented by a number of other less-official CFIA publications on the agency’s website. I recommend one entitled “Foundations of an Outcome-based Approach” written by Veronica McGuire. In it she describes the three inspection systems available to the CFIA and explains the agency’s bias to move to an outcome-based program, but only if it is practical and safe to do so. Many would agree with this approach.
After wading through all these documents one fine August evening, I began reflecting on whether the proposed regulatory initiatives addressed the recommendations made by the independent reviewers, and whether the proposed modernized food inspection program would have prevented the outbreak at XL Foods.
Independent Review Score Card
The independent reviewers made 30 recommendations of which about half, in my judgment, relate directly to improving food safety in a beef processing operation such as XL Foods. The other recommendations are important but concern other matters such as improving communication and research initiatives. Below I’ve rated the level of support the reviewers’ recommendations will receive from the proposed regulatory initiatives on a scale of one (little support) to five stars (good support).
- Establishing food safety cultures – I’m disappointed not to see more emphasis on this. I didn’t see any reference to this in the inspection audit guidelines. (***)
- CFIA inspector training – There are a lot of promises to train but few details. It would be good to learn how the CFIA will prioritize training. Will it be the degree of risk in the product or commodity, assessing food safety models, or trending analyses? What about meeting management training to help the inspectors work better with upper corporate management? I’m not sure if CFIA management understands that the success of the new inspection program will depend on the competence of front-line inspection staff to work with the new systems. (**)
- Assessing the agency’s activities related to the meat program – I applaud the CFIA’s willingness to engage in an assessment process and I hope that the union supports it. (*****)
- Enforcing plant oversight. (*****)
- Prerequisite programs concerning livestock. (*****)
- Risk assessment of mechanically tenderized beef. (*****)
- Benchmarking five per cent for E. coli O157:H7 in beef trim. (*****)
- Defining and reacting to high event periods (HEPs). (*****)
- Reacting to high shedding seasons. (*****)
- Trend analyses. (*****)
- Compliance verification – I found only one supporting statement for the compliance verification system (CVS), leaving me to wonder whether the IVT initiative will be replacing it. (**)
The final score is 49 out of 60 points, or 82 per cent, which isn’t bad and deserves recognition for a solid start. So could the Modernized Inspection Program have prevented the XL recall? In a word, no, but the severity and scale of the recall would, in my opinion, be significantly reduced.
The CFIA deserves industry’s ongoing support and co-operation in the launch of the new inspection system. On the flipside, the agency needs to work patiently with industry over the next three to five years to optimize the program to everyone’s benefit, and to address the unexpected concerns that are sure to come up as the full impact of the implementation is felt.
Dr. Ron Wasik, PhD, MBA, is president of RJW Consulting Canada Ltd. in Delta, B.C. Contact him at [email protected]