• Opinion
  • March 22, 2019
  • 10 minutes
  • 0

Consult, collaborate, innovate: How we reformed food safety in Canada

Opinion: The SFCR are the largest regulatory reform initiative in Canada’s history

This piece was written by France Pégeot, Executive Vice-President, Canadian Food Inspection Agency. For more like this, see our public health newsfeed.


Today’s food is a mirror of our increasingly global world. A frozen pizza typically includes 35 ingredients from 60 countries on five continents, while a box of chicken fried rice often contains 28 raw ingredients from 35 suppliers in five countries.

The food we eat today comes from practically everywhere you can think of and contains ingredients you never imagined. Amid this ever-changing reality, governments are faced with new challenges to ensure food is safe while supporting the complex system that feeds people.

In Canada, we have one of the strongest food safety systems in the world. Yet we know that we need to keep evolving it to reduce risks while supporting the farms and businesses that Canadians and non-Canadians alike rely on every day for safe, healthy food.

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This is one of the key reasons why the Canadian Food Inspection Agency (CFIA) recently undertook a multi-year effort, on behalf of the Government of Canada, to draft, finalise and implement new food safety regulations.

On January 15, 2019, the Safe Food for Canadians Regulations (SFCR) came into force. Replacing 14 existing commodity-based food regulations, the SFCR represent the largest regulatory reform initiative in Canada’s history and a truly innovative approach to developing food safety regulations.

Unlike most countries which tend to update existing regulations, Canada started the SFCR from scratch, ensuring a modern, up-to-date and forward-thinking food safety framework.

This meant the project was more involved and time-consuming, but it was worth it. The new regulations make our food safety system even safer by focusing on prevention and allowing for faster removal of unsafe food from the marketplace.

They also provide a strong, respected domestic food safety system that helps to maintain and grow market access for Canada’s agri-food and agricultural sector by aligning our regulations with those of key trading partners.

As public servants, we can learn much from our respective experiences, and I would like to share with you our story about the SFCR. I will focus on the three pillars on which we built the new regulations: consultation, collaboration and innovation.

Consultation

Regulations are best built in an inclusive, open and transparent environment where all parties concerned have a voice at the table. In Canada, there are many stakeholders in the food sector — from farms, food processers and industry associations to importers, exporters, provincial-territorial governments and of course consumers.

In 2013, the CFIA began consulting extensively to help shape the proposed regulations, and all stakeholders were encouraged to get involved. Two national food safety forums were held in 2013 and 2014 to gather input, and participation was high, with hundreds of stakeholders taking part.

In 2015, a third national consultation was held for micro and small businesses, to better understand their unique needs and to explore options for reducing costs that would be imposed by the proposed regulations.

Altogether, the CFIA participated in more than 300 external stakeholder events and reached thousands of individuals through face-to-face sessions.

But there was more to come. In January 2017, the proposed regulations were pre-published in Canada Gazette for a 90-day public comment period.

Our engagement activities also included a cross-country series of open forums that yielded an unprecedented amount of participation and input. We met with more than 2,000 stakeholders through roundtables, webinars, technical sessions, industry conferences and international events.

More than 1,700 written submissions were received from consumers, small and large businesses, offshore companies, trade associations, producers and growers, academia and five foreign governments.

All submissions were reviewed and taken into consideration by the CFIA.

Collaboration

Like most public projects, the success of the SFCR hinged in part on the CFIA’s ability to build partnerships and foster collaboration among key players — in Canada, outside Canada and within the CFIA itself.

Long before the SFCR came into force, the CFIA began working with industry associations and provincial and territorial governments across Canada to communicate with a multitude of groups in the food sector.

We met regularly with industry groups and did a lot of listening as they shared invaluable hands-on insight into food safety practices. Our meetings provided a forum for productive two-way conversations that led to important refinements in the regulations.

Leveraging these partnerships enabled us to help food businesses understand how the new regulations would affect industry and how to prepare for them using tools and resources provided.

Beyond Canada’s borders, the CFIA interacted with trading partners to learn about their regulatory models and inform them of the proposed regulations and what they would mean for food imported into and exported from Canada.

These collaborations allowed the CFIA to ensure the regulations are consistent with the Codex Alimentarius, the international food safety standards developed by the World Health Organisation and the Food and Agriculture Organisation of the United Nations.

Within the CFIA, development and implementation involved collaboration across branches, in key areas such as policy development, enforcement, communications, digital support, international trade and licensing fees.

Innovation

If you want to build a modern regulatory framework, you had better be prepared to go down new roads to do it.

The SFCR introduce several innovations that reflect a modern approach to regulating food safety:

  • Outcome-based regulations: specify the result that a regulation is intended to achieve, rather than prescribing exactly what food businesses must do to produce that result. This enables industry to innovate, and make the food system even safer by allowing businesses to respond to emerging threats and leverage new technologies and scientific advancements.
  • Incorporation by reference (IBR): allows the SFCR to respond faster to public needs, modern science and new innovations. For example, an IBR list of food grades or standards can be revised by following set-out principles for maintaining the documents, without going through the lengthy process of amending the regulations themselves.
  • Online library of more than 300 interpretive guidance documents: helps industry to interpret the meaning of the regulations in everyday situations and transition successfully to the SFCR.

The final regulations

Feedback from the consultation process led to important refinements in the final regulations that include providing more flexibility for small businesses, developing additional guidance and adding more time for coming into force.

The CFIA also committed to the continuous improvement of the SFCR by reviewing the regulations and making changes every five years. Continuous improvement will also be achieved through the IBR documents.

Every day, public servants around the world draft regulations that are vital to society. The work we do affects many different stakeholders and requires rigour, dedication and know-how.

In drafting the SFCR, our three pillars played a key role in minimising risks and issues. Through consultation and collaboration, the CFIA was able to build a regulatory framework that strengthens food safety while gaining the support of stakeholder groups — highlighted by the fact that several of them issued public statements in support the SFCR.

When it comes to developing regulations, success depends on many factors but one thing we’ve learned at the CFIA is certain: success is much harder to achieve without openness, transparency and a commitment to innovation.

These will continue to be important pillars for us as we work to ensure food is safe, whether it’s eggs from a local farm or a frozen pizza with ingredients from 60 countries. Bon appétit! – France Pégeot

(Picture credit: Unsplash)

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