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Requirements Regarding Food
Safety and Traceability

Canadian Dairy Outlook Seminar
John Lynch
Executive Director
Food Safety & Consumer Protection Directorate
Canadian Food Inspection Agency (CFIA)

March 22, 2011, Montreal
2007 Her Majesty the Queen in right of Canada
(Canadian Food Inspection Agency), all rights reserved. Use without permission is prohibited.

Legislative Modernization & Simplification Multiple key trading partners have either recently enacted new food safety legislation (e.g. USA, China) or are in the process of doing so In the March 3, 2010 Speech from the Throne, the Government committed to re-introduce legislation to protect Canadian families from unsafe food, Globalization and the pace of business change requires a new legislative Recognizes the global nature of the food system and aligns effectively
and efficiently with that of our major trading partners
Provides consistent treatment across all food commodities in a single
Facilitates development of flexible, non-prescriptive, outcome-based
regulations and supports modern inspection approaches
Ad hoc, responsive regulatory updates do not provide an acceptably consistent, risk-based and logically prioritized approach to meet CFIA has adopted a new regulatory prioritization process and matrix Regulatory frameworks are being developed for each of the CFIA business lines (Food, Animal, Plant) to chronologically sequence planned revisions A modern regulatory approach would consider: - mandated periodic review
- consistent treatment of all commodities
- single requirement for licensing or registration
- incorporation of standards by reference
- various enforcement options (e.g. licence suspension, AMPs, etc.)
• In response to public concern around imported products, the Government of Canada announced the five-year Food and Consumer Safety Action Plan to be developed and administered by CFIA, Health Canada (HC) and the Public Health Agency of Canada (PHAC) • A major focus of this project was the development and implementation of a regulation to address imported foods in the Non-Federally Registered Sector through a licensing requirement • The regulation will fall under the Canadian Agricultural Products Act Part I: General Provisions including recall plans, record keeping and Part II: Licensing Provision requiring development and maintenance Enhanced Food Allergen Labelling Regulations • The Minister of Health announced strengthened regulations on labelling of the priority allergens, gluten and sulphites on February 14, 2011 to assist consumers with allergies or sensitivities to make healthful food choices.
• Labelling changes must be implemented by August 4th, 2012.
• The regulations require clearer wording and declaration of what were previously hidden sources of allergens, as in terms such as“flavourings”.
• The CFIA will be enhancing its oversight of products for compliance with the regulation as of the coming into force date.
• A variety of communications and information sessions will be provided through both HC and CFIA to assist stakeholders.
The Food and Drug Regulations (FDR) allow for the production of cheese made from unpasteurized milk if they are stored for 60 days before sale at The FDR’s current microbiological criteria for cheese made from unpasteurized milk are outdated and do not reflect the risk posed by pathogens such as L. monocytogenes or E.coli O157:H7.
Health Canada is reviewing a variety of options to permit the national sale of soft and semi-soft cheese made from unpasteurized milk under Broad stakeholder consultations are underway Publication of policy intent expected in fall 2011 Implementation of the Revised Listeria Policy The updated HC Policy on Listeria monocytogenes in Ready-to-Eat Foods (2010) comes into effect on April 1, 2011 The current policy differs from the 2004 document in the following: - New end-product compliance criteria have been developed.
- The definitions of RTE foods in which growth of L. monocytogenes can or
cannot occur have been modified and/or developed. (e.g. Category 1 – soft
cheese; Category 2B – ice cream, hard cheese) The compliance action
decision tree has been modified to include more details related to sampling.
- It now states that an environmental monitoring program should be included
in all plants used in the production of RTE foods, as defined in this policy.
- It encourages the use of post-lethality treatments and/or L. monocytogenes
growth inhibitors.
- There is an increased focus on outreach
CFIA is issuing communications to industry on implementation plans • The CFSO for Canada has stated that our long-term vision is to have traceability throughout the food continuum • The current priority area for implementation is at the animal level • For food, the major concern is adequate record keeping to ensure • New recall requirements for the Non-Federally Registered Sector will be included under the Imported Food Sector Product Regulations Third-party Certification of Safety Systems • In response to retailer concerns around several high profile food safety issues, the global food industry has initiated the development of various food safety “schemes”, many of which align with the Global Food Safety Initiative (GFSI), to meet their needs • The CFIA is facilitating the development and recognition of both “on-farm” and “post-farm” food safety recognition programs, with support provided through APF/GF1 financial support • There is growing interest on the part of industry to leverage the investment in such systems to satisfy regulatory requirements and potentially reduce the regulatory inspection compliance burden • The CFIA is studying these schemes and systems to determine where this may be feasible, although certification through such schemes will not replace conventional inspection processes Concerns in China regarding any chemical additives in milk; Benzoyl peroxide use not Large-scale quarantines of farms, following contamination of feed Recent Asian media attention as follow-up to previous findings Antibiotics and antimicrobial resistance in agriculture – Canada and others Subject of a recent Codex Alimentarius workshop and two recent meetings of the Parliamentary Standing Committee on Health

Source: http://dairyinfo.gc.ca/pdf/FIL-IDF2011-Requirements_on_Food_Safety_and_Traceability-John_Lynch_eng.pdf

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