Score card for regulatory modernization

Recently, I had the privilege to be on a conference call which had a senior Canadian Food Inspection Agency (CFIA) official talking about some of the food safety initiatives currently underway within both Health Canada (HC) and the CFIA. After the speaker finished, those on the call were invited to ask questions. I asked what benchmarks Health Canada (HC) and the CFIA were planning to use to monitor the effectiveness of the Safe Foods for Canadians Act and Regulations (SFCAR) and the CFIA Inspection Modernization Initiative. The answer I received was that neither HC nor the CFIA had given much thought to this as both were focused on implementing the SFCAR. However, the speaker invited those on the call to submit any suggestions.

Before getting into a discussion on performance metrics, I think that it is important to remember why the SFCAR was implemented. One objective was to improve the competitiveness of Canada’s agri-food industry. Another objective was to improve, simplify and update the agri-food regulatory framework. There was also an objective to improve health outcomes for Canadians by improving food safety. Any performance metrics should quantitatively measure what progress is being made on achieving these objectives. Here are my suggestions to industry, the CFIA and HC.

Health outcomes

Many factors affect a person’s health. Genetics, lifestyle, stress, diet, education, health care and the environment where the person lives, all come to mind. It is definitely not just diet. However, it is hard not to get the impression that HC holds our industry largely responsible for the health outcomes of Canadian consumers, especially when it comes to foodborne illnesses, obesity and vascular diseases. I believe that the health outcome most closely connected to our industry is a foodborne illness. We should study this over the next five years to see if the number of foodborne illnesses drops significantly.

Although the correlation between food recalls and foodborne illnesses is tenuous, there is data on the type and number of recalls. Recalls could also be part of what is trended over the next five years. Compliance to better regulations and enforcement should lead to fewer foodborne illnesses and recalls.

Improved agri-food regulatory framework

At the time the SFCA was being promoted, the CFIA and the Treasury Board both claimed that the new legislation would not add any incremental cost to the CFIA’s budget. Budget management should be a metric. I predict that the CFIA will spend more in the next five years (2019-24) than it did in the previous five years (2014-18). Given that inspection staff will have to be trained on the SFCAR, training costs and turnover could be other metrics. I predict that both training costs and turnover will increase dramatically over the next five years. HC and the CFIA also claim that the application of risk modelling, equipping inspectors with digital devices and establishing inspector-support centres will improve inspection efficiency. Presumably, this means that each inspector will be able to inspect more establishments in the ensuing years. Let’s see if that happens. Although HC and CFIA lead one to believe that our industry is solely responsible for recalls and foodborne illnesses, I believe that HC and the CFIA have a strong influence on these outcomes. How the number of food recalls and outbreaks trend should also be performance metrics for HC and the CFIA.

Industry competitiveness

The cost of compliance is a significant cost to our industry. The SFCAR was supposed to reduce industry’s compliance costs. Let’s see if that happens. Outcomes-based compliance was promoted as a means to provide industry with greater freedom to innovate, especially in the area of food safety. Although this would be a largely subjective exercise, we need to know whether or not outcomes-based compliance is promoting innovation.

Next steps

Our industry must insist that HC and the CFIA to establish programs to measure how effectively the SFCAR are meeting the three objectives mentioned in the introduction. However, before we get started, let’s agree on what to measure, what data can and should be collected, who will collect it and who will analyze the data impartially. Please remember that we in the agri-food industry also have significant contributions to make to this exercise.