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
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