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Americas: Building food safety harmony in Canada

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The US is not the only country in North America that pushing forward with major food safety regulations.

Canada, its northern neighbor, has been upping its game to help ensure food quality both within the country, the continent and across the globe.

In May 2016 for example, the Canadian Food Inspection Agency (CFIA) at the Department of Health Canada signed a Food Safety Systems Recognition Agreement with the US Food and Drug Administration (FDA).

The FDA, CFIA and Health Canada started assessing one another’s food safety systems in 2015, and they determined that the US and Canada’s food safety systems provide public health protection comparable to each other.

This not only strengthens the already strong partnership between the food industries of the two countries, but bridges each nation’s food safety programs in ways that will only help increase safety for consumers.

Food safety measures

A major force is the FDA’s Food Safety Modernization Act (FSMA), which creates new food safety regulations for both food facilities and US importers.

The food facilities in Canada that manufacture, process, pack or hold food for consumption in the US follow many, must-have food safety plans, including a hazard analysis, preventive controls, a supply chain program and other components that are compliant with FDA regulations.

Also, FSMA’s Foreign Supplier Verification Program (FSVP) rule creates new requirements for US importers including monitoring, approving, and creating an FSVP for each foreign supplier, a large role in Canada’s food industry.

Meanwhile, two Canadian think tanks, the Canadian Agri-Food Policy Institute (CAPI) and the Canada Institute of the Wilson Center, released a proposal on September 2016 advocating a cross-border cooperative food protection system between the US and Canada.

The view of the proposal is that “a well-functioning food safety regime helps to increase global demand for safe and wholesome North American food products”.

Citing the collective history of Canada and the US to work together to ensure the integrity of the countries’ shared ecosystems, resources and infrastructure, CAPI and the Wilson Center believe this is the moment to jointly move to protect the shared food supply of the two countries.

While Canada and the US are already coordinating on food safety, the proposal calls out that technologies or protocols may be available on one side of the border but not the other, an issue that could be resolved through more regulatory collaboration.

The paper cites an example involving 3M Food Safety and its molecular detection assays for E. coli, Listeria and Salmonella.

All original molecular detection assays are approved for use in Canada and the US, but although all the second-generation assays for each pathogen are approved in the US, only version two for Listeria has been approved for use in Canada.

Even if a method is validated by AOAC in the US, Health Canada requires its approval process that requires additional testing and could take at least 12 months.

A harmonization of these method validation processes as part of a cooperative food protection system will go beyond consumer protection to enhance the competitiveness of the Canada-US food supply chain and increase global demand for North American food products.

Canada is embracing the demand for stricter food safety programs, with the country working to put itself at the forefront of food quality and health.

Adopting food safety regulations

Since 2007, the Canadian government has committed to making food as safe as possible for consumers and developing a world-class, modern food safety system, beginning with the announcement of the Food and Consumer Safety Action Plan.

A commissioned government report from an independent investigator on Canada’s Listeriosis outbreak in 2008 (which stemmed from the consumption of contaminated deli meats) recommended Canada’s government “modernize and simplify federal legislation and regulations that significantly affect food safety”.

This led to the Safe Food for Canadians Act in 2012, which consolidated government agencies previously established to regulate sectors of the food industry with the goal of instituting a more consistent and widespread inspection regime, implementing tougher penalties, providing better control over imports and exports and strengthening food traceability.

This year marks the six-year-anniversary for the Safe Food for Canadians Act, and since its enactment, the government has put practices in place to:
• Improve food safety oversight to better protect consumers through new prohibitions, strengthened food traceability and improved import controls.
• Streamline and strengthen legislative authorities by modernizing and simplifying food safety legislation as well as aligning inspection and enforcement powers.
• Enhance international market opportunities by giving passing legislation allowing the CFIA to treat exported food commodities consistently and creating a cost-effective review mechanism providing an avenue of recourse for regulated parties.

Last year, Canada’s government proposed its Safe Food for Canadians Regulations (SFCR) to serve as an extension of the Safe Food for Canadians Act and, like the US FSMA law, would “require food businesses to have preventive controls in place to identify and manage food safety risks before products are sold to consumers”.

These preventative food safety controls include training staff in food handling and safety; wearing appropriate protective clothing and practicing good hygiene; keeping a facility sanitary and free of pests; properly receiving, storing and loading food; and following procedures for handling complaints and recalling unsafe food, and are based on international food safety best practices characterized by preventative rather than corrective measures after an issue is uncovered.

CFIA not only describes attention to preventative controls as “a key element” of its proposed regulations but encourages all food businesses to begin to put into practice what has been outlined in the SFCR.

By developing and following a preventative controls plan, food safety issues can be identified and corrected early in a company’s process.

Also taking its cue from FSMA, when sharing the SFCR, the Canadian government pointed out that the regulations were drafted to be in line with what key trading partners were instituting to instill confidence in Canada’s food safety system.

The SFCR consolidates 13 existing regulations and the food labeling provisions of the Consumer Packaging and Labeling Act to place all food subject of CFIA oversight (federally registered sectors and food that is destined for import, export or interprovincial trade) regulated under the Safe Food for Canadians Act and Food and Drugs Act.

What is covered by the SFCR runs the gamut from preventative controls and preventative control plans to licensing requirements for the import, export and interprovincial trade of food to regulations on grade requirements, labeling and container sizes and weights for certain food products.

One aspect of significance is that under SFCR, previously non-federally registered food sectors will be subject to Canada’s licensing rules and CFIA oversight.

This also is like actions by the US under FSMA, as importers without a place of business in Canada would still be eligible for a license provided it has a fixed place of business in a country with food safety policies equivalent to Canada’s.

After pre-publishing the proposed SFCR in January, there was a 90-day comment period for all Canadians on the proposed regulations, and now the government is reviewing and analyzing feedback with final publication of the regulations expected in spring 2018.

Conquering food challenges

Clearly, Canada wants to take a holistic approach to food safety, and labeling and complete supply chain transparency are large pieces of SFCR.

As with most initiatives, budget can provide an obstacle, and if the CFIA is unable to secure enough funding to handle instituting all proposed regulations as well as enforce these rules, it will be difficult to deliver on that holistic approach.

Training personnel to implement the SFCR also will be important, which requires time and dedication from leadership and educators.

Also, those in the food industry must set aside time to properly train workers so that new regulations are followed.

There are many food categories to cover, from produce to dairy to poultry, as well as process controls such as sanitation and allergen control, which may create a barrier to providing enough resources to cover the entire food safety system.

Canada averages about 350 food recalls a year, mainly due to undeclared allergens and Listeria contamination and often involving products that contain milk, eggs, peanuts or wheat.

  • Allergens

In particular, allergens are having a dramatic impact on food safety, and ensuring food and beverage products are free from potentially harmful allergens must be an important point of emphasis for the Canadian food industry.

After analyzing CFIA data, allergens were found to account for 52 percent of Canada’s food recalls in 2016 compared to 18% for Listeria and 10 percent for Salmonella, with E. coli only accounting for 4%.

To reverse these numbers and better serve the public, Canada is working to make science-based nutrition information easier to understand through changes in labeling on packaged foods, helping Canadians more easily identify ingredients.

Health Canada and the CFIA list 10 priority allergens (comparatively, the US cites eight), and the agencies have worked with the medical community, allergy associates and the food industry to foster discussion and enhance labelling requirements for priority allergens, gluten sources and sulphites in pre-packaged foods sold in Canada.

When it comes to labeling, Canadian regulations require that the most common food and food ingredients that can cause life-threatening or severe allergic reactions always be identified by their common names (“soybean vs. Glycine max”) so consumers can easily recognize them on labels.

From a scientific standpoint, Health Canada and CFIA have galvanized various food laboratories throughout the country into an Allergen Methods Committee (AMC) that is designed to direct and coordinate the development, delivery and advancement of allergen testing and allergen research programs, including inter-laboratory evaluation of both commercially available and in-house allergen detection methods.

  • Pathogens

Relating to pathogens, recalls due to Listeria have been seen from dozens of food companies, with everyday food products such as energy and granola bars, fruit and vegetables, salad toppings and trail mixes being pulled from shelves and putting many lives at risk in Canada as well as across North America.

Getting the threat of Listeria under control will continue to take time, but an ultimate objective of Canada’s food industry must be limiting Listeria to where consumers are no longer in fear of what might be hidden in their groceries.

Today, Listeria control is mandatory for high-risk food categories such as ready-to-eat deli meats and unpasteurized milk and dairy products, which is an important step in building trust between consumers and their every-day grocers.

Again, it is important to call out the role training and building awareness plays inside food producers; if workers at a food company understand how to identify and prevent Listeria, we become closer to eliminating this threat.

In addition, as part of its holistic approach, more research and examination seems to be placed on the impact that climate change may have on the emergence and spread of new pathogens to the area, or at least new strains of pathogens not typically seen in or near Canada, but that may be growing within seafood as ocean temperatures rise and change.

Research seems to show correlations between increased sea surface temperatures and the occurrence of disease associated with Vibrio.

Proactive food safety

Industry compliance with SFCR, including food industry organizations being willing to cooperate with CFIA, can prevent widespread food illness by improvements in processing, sanitation and other practices.

The CFIA states that with thousands of food items entering the marketplace, it focuses its inspection activities in areas where risks are highest while ensuring areas of lower risk continue to get the appropriate level of oversight, insisting both industry and the government can be more agile in protecting Canadians.

Food recalls and other health issues can no longer be swept under the rug as consumers, who demand transparency, are paying closer attention to what is on their shelves and what is in their foods.

It comes down to the Canadian food industry being proactive, and with the Canadian government leading by example, organizations need to invest in the tools and processes that aid consumers, employees and productivity.

Article by Ana Lozano, 3M Food Safety (Canada)