The Food Emergency Response System of the Canadian Food Inspection Agency

EXECUTIVE SUMMARY

In April 1997 the Canadian Food Inspection Agency Act established the Canadian Food Inspection Agency, reporting to the Minister of Agriculture and Agri-Food. Health Canada is responsible for assessing the effectiveness of the Agency's activities related to food safety. The following are key findings from the first food safety assessment of the Canadian Food Inspection Agency's activities, namely, those related to the Food Emergency Response System.

Every year in Canada, emergencies involving the safety of food products occur. The Food Emergency Response System as adopted by the Canadian Food Inspection Agency operates in essentially the same manner as the food emergency system which had been in place previously in Health Canada. The system remains consistent with practices in other inspection programs charged with responding to emergency situations. The assessment team identified some areas where improvements can be made which will provide a greater level of assurance that consumers are protected from hazardous food products in emergency situations.

We conclude that the Agency was, overall, effective in identifying situations in which recalls were necessary, that it assessed the situation and initiated a response in a timely manner, and that it implemented management actions which were, for the most, in accordance with the level of risk. The Agency's role in overseeing and monitoring industry's recall actions can be improved with enhanced guidance in the Food Emergency Response Manual and better documentation of the decisions and actions taken.

Key Observations

Roles and Responsibilities

The roles and responsibilities for handling recalls were mainly clear and well understood within the Canadian Food Inspection Agency. These include relationships within the Agency and between the Agency and various stakeholders and partners, including the food industry and provincial officials. The role of the Food Emergency Response System in other food safety emergencies such as sabotage or tampering incidents, reported illnesses and man-made or natural disasters needs to be clarified.

Identifying Food Emergencies

The Agency, for the most part, identified potential food emergencies promptly and investigated them sufficiently to reach a conclusion. Current Agency inspection, sampling and complaint investigation programs are a valuable source of information.

Risk Assessment

The Memorandum of Understanding between Health Canada and the Canadian Food Inspection Agency concerning Food Safety Emergency Response describes the respective roles and responsibilities of Health Canada and the Canadian Food Inspection Agency in food safety emergencies. Health Canada and the Agency had different interpretations of when the Agency should request Health Canada to conduct a Health Hazard Evaluation. The Agency and Health Canada considered this a significant problem and it is now being addressed.

The estimation of risk in a potential emergency and the subsequent risk management actions taken were appropriate in the vast majority of situations and the process for determining the risk was carried out in a timely manner. Better documentation of the rationale for recall classification decisions is required.

Emergency Management

The Food Emergency Response Manual provides procedures to manage a food recall. Its guidance with respect to public announcements and monitoring the effectiveness of recalls could be improved. The root causes of food emergencies were investigated and the scope of investigation was broad enough to identify all contaminated products in almost all recalls reviewed. Documentation of the progress and subsequent termination of food recalls could be improved. The checklist that is part of the Food Emergency Response Manual and that is to be completed for each emergency could include the key information on the success of the recall in removing hazardous products from the marketplace. Overall, these improvements would contribute to assurance that appropriate action is taken to fully protect the public in each food emergency situation.

Performance of the Food Emergency Response System

Few post-emergency reviews were documented for the recalls examined. The Agency has developed a broad performance measurement framework which includes the Food Emergency Response System, a very positive step. It now needs to clarify it and define it further.

Key Recommendations

1. The Agency should continue to ensure that the relative responsibility of the Agency, stakeholders and partners remain current and clear. The area of food safety is constantly evolving and relationships with Health Canada, provincial and foreign governments and industry need on going consideration.
2. The Agency should define roles and responsibilities for the Food Emergency Response System in responding to emergency situations of disaster, reported illnesses, tampering and sabotage, and include procedures for carrying out those responsibilities or refer to other emergency plans or procedures in the Food Emergency Response Manual.
3. The Agency should implement procedures agreed-to with Health Canada for assessing the risk of all food safety emergencies for which appropriate standards, tolerances or guidelines do not exist.
4. The Agency should clearly specify in its Food Emergency Response Manual:
   • the circumstances in which a public warning is or is not necessary;
   • adequate guidance on the timeliness, adequacy and level of effectiveness checks;
   • information required to review how each food emergency has been managed by Headquarters and the regional offices and to determine its effectiveness.
5. The Agency should, at all stages of the emergency response process, document decisions, rationale, and results of actions taken.
6. The Agency should develop clear policies and procedures describing when and how to use the recall powers of the Canadian Food Inspection Agency Act.
7. The Canadian Food Inspection Agency should improve the overall coordination and oversight of food safety emergency activities which take place across both Headquarters and the Regions.
8. To ensure accountability, the Agency should refine the objectives and performance measures for the Food Emergency Response System and use these measures to report on its performance.