Measuring the success of the Safe Food for Canadians Regulations

Every business assesses its performance against well-defined business goals on a weekly, monthly or quarterly frequency to ensure that the company is on track to meeting those goals and ultimately achieving success. Although the comment period for Canada Gazette Part 1 (CG1) closed on April 21, it is not too late to have a discussion on how to measure the success of the Canadian Food Inspection Agency (CFIA) and the Safe Food for Canadians Regulations (SFCR). So what is to be expected?

Current success metrics

Under the title of “Performance measurement and evaluation,” which appears just prior to the details of the SFCR, CG1 states that it is expected that the regulations will “improve the ability of the CFIA and regulated parties” to achieve the following:

• Prevent and manage food safety risks.
• Better protect consumers.
• Maintain and expand market access for Canada.

The text goes on to say that “The CFIA is developing a food program performance framework to measure how well its activities, processes and services contribute to these outcomes…to monitor and assess whether the Regulations are achieving the goal of increasing food safety in Canada.” These are reasonable outcomes. The performance metrics for the CFIA, proposed in CG1, are stated as:

• Increase in number of CFIA-licensed food manufacturers that have a system in place to promote food safety.
• Increase in number of CFIA-licensed food importers that have a system in place to promote food safety.

In today’s competitive business environment, would any CEO accept such ambiguous performance objectives? The answer is not just “no!” but “hell no!”

Following are some goals that I think are better suited to reflect good performance. Let’s start with what CG1 says should be expected out of the SFCRs:

1. “Prevent and manage food safety risks.” These are “motherhood and apple pie” goals. They need to be quantified by setting benchmarks, such as reducing a wide array of significant food safety risks like recalls of all classifications, against the number of recalls in the previous year and against a five-year moving average.

2. “Better protect consumers.” The question is, better protecting consumers from what? Aside from food safety risks already addressed, this could include reducing the number of complaints arising from fraudulent claims of all types. The benchmark could be the claims in the previous year as well as a five-year moving average.

3. “Maintain and expand market access for Canada.” The question is what national trade metrics should be used to determine if Canada is exporting more goods abroad? Some might advocate using a total aggregate measure, while commodity sectors would prefer a commodity-based metric. I recommend a commodity approach as a single aggregate measure will mask problems. Again, year-over-year and five-year moving average benchmarks for each commodity are recommended to measure success.

Measuring performance

It’s difficult for me to clearly distinguish the differences between the “activities, processes and service performance” of the CFIA as stated in CG1. If the Agency is to be measured against these terms, then each term will need to be clearly defined in a way that will permit setting quantifiable goals that are consistent with the desired outcomes of the SFCR, consumers and industry. Getting agreement on the metrics will take at least two years. It will then take another three to five years to fine-tune the metrics. This assumes that the Agency has performance programs of some kind in place today which can adapt to whatever metrics are agreed upon.

I strongly encourage readers to submit CFIA performance criteria directly to the CFIA and through your trade association if you have one. If you can, suggest specific goals for the criteria you recommend. If you decide not to do so, be satisfied with whatever convenient metrics the CFIA decides to use. The choice is yours.

Dr. R.J. (Ron) Wasik, PhD, MBA, CFS, is president of RJW Consulting Canada Ltd. Contact him at rwasik@rjwconsultingcanada.com