Food Inspection in Canada gets a “Modernization” Makeover

As I let you all know here, in June of this year, the Federal Government tabled a new Bill that will overhaul the Canadian food safety system: the Safe Food for Canadians Act.  More recently, on August 9^th, the Government released a draft of an “improved” food inspection model.

These two developments illustrate the Canadian Government’s efforts to modernize regulation of the Canadian food industry.

As I have before, I applaud the Government for this lofty goal.  Modernization is key if Canada wants to stay a leader in food-related innovation, and I think you’ll all agree with me that we definitely do!

According to this, the changes are aimed at providing Canadians with a stronger and more robust food inspection system that allows for innovation (in both science and practices) and more transparent access to information about food so consumers can make informed decisions and healthy choices.   Hooray!  These initiatives were foreshadowed by the commitment made by the Government in the 2011 Budget to modernize food safety inspection in Canada.

So what does the Proposed Draft say about this improved food inspection model? One of the key components of the proposal is that the Canadian Food Inspection Agency (CFIA) will apply a single and consistent approach to inspection for all foods (i.e. to ensure compliance with legislation and regulations), regardless of whether the food is imported or produced in Canada.

Beyond that, the Proposed Draft can be broken down to the following key components:

Licensing / registration.  Companies that import or export food, or manufacture it in Canada for interprovincial trade will have to be licensed / registered. According to the Proposed Draft, the license application will require:

•  the development, documenting and maintenance of a “preventative control plan”, which addresses eight identified elements relating to food safety and basically allows for a check on how successfully the importer / manufacturer is producing safe food;
•  demonstration that key personnel within the business have been trained in, or have experience in, safe food handling practices; and
•  a commitment to notify the CFIA of confirmed food safety non-compliance in the market.

Note that the right to issue licenses and registrations in this way is provided for in the Safe Food for Canadians Act.

The Proposed Draft does not provide any exceptions to licensing, however notes that the CFIA may consider exceptions for regulated parties inspected by a recognized, competent authority.  I suspect companies subjected to FDA inspection could fall within this exemption.

Varying level of CIFA oversight depending on the risk remaining after the importer / manufacturer’s effective controls and compliance, and (in the case of imported foods) the CFIA’s level of confidence in the exporting country’s food safety systems.

A systems approach to inspection to verify the controls put into place by the importer / manufacturer.  This will require CFIA to globally assess evidence gathered during inspections to determine trends and potential impacts on food safety and compliance.

Compliance and enforcement will be evaluated on a case-by-case basis, having regard to a range of factors.

Evaluation of system performance will be undertaken to validate the food inspection program for continuous improvement.

The CFIA is seeking comments on the Proposed Draft from consumers and industry stakeholders – comments are due October 31, 2012.

It is recommended that industry take stock of their policies and procedures to make sure they’re ready for implementation of the new regime – it could come on fast and furious following the end of the comment period.