The Food Emergency Response System of the Canadian Food Inspection Agency

13 The Agency provided a list of 240 food recalls that occurred during the period covered by our assessment. Sixty were Class I recalls (actual food safety emergencies), 163 were Class II recalls (potential food safety emergencies) and 17 were Class III recalls (non-food safety emergencies -, i.e., incidents posing a low or no immediate health risk). Of the 223 Class I and II recalls, 29.6% were concerned with microbiological hazards; 56% involved allergens and 4% chemical contaminants other than allergens; 10% involved extraneous material; and three recalls
(0.4%) involved other concerns.

14 We reviewed and evaluated in detail 49 of the Class I and Class II food recalls. Of these, 21 were initiated in the period during which the Food Emergency Response System was under the direction of Agriculture and Agri-Food Canada and 28 were initiated after the creation of the Canadian Food Inspection Agency. We selected our sample to include Class I and Class II recalls, recalls involving different types of hazards, and recalls initiated from different Regions. We also selected some recalls which included Health Hazard Evaluations by Health Canada and others that did not. In addition, we examined 12 food safety-related incidents that did not result in food recalls. We also examined, in the context of the Food Emergency Response System, the ice storm that took place in January 1998. Finally, we interviewed officials and reviewed files at the Canadian Food Inspection Agency's Headquarters and in the Pacific, Ontario, Quebec and Atlantic Regions. For more information on this assessment, refer to the "About the Assessment" section at the end of the report.

OBSERVATIONS AND RECOMMENDATIONS

Roles and Responsibilities

15 We reviewed the Canadian Food Inspection Agency's documentation and its understanding of the roles and responsibilities of the Agency, of Health Canada and other external parties in potential and actual food safety emergencies. Our objective was to determine whether their roles and responsibilities were clearly defined and understood.

16 We found that the Canadian Food Inspection Agency personnel who play key roles in the Food Emergency Response System, and whom we interviewed, understood their roles and responsibilities in a food recall.

17 The Canadian Food Inspection Agency's Food Emergency Response Manual defines their roles and responsibilities and provides procedures to manage a food recall from the Headquarters level and down to the regional Chiefs of Food Inspection. We found that only two of the four Regions that we assessed have a documented regional emergency response plan, as required by the manual, which describes regional roles, responsibilities and procedures. The Agency relies on personnel in Headquarters and the Regions to carry out activities for effectively responding to food safety emergency situations. Completing the documentation of regional roles and responsibilities will contribute to a clearly defined and understood Food Emergency Response System that can be managed effectively at all levels of operations.

18 The Food Emergency Response Manual and the two existing regional emergency procedures manuals do not clearly define roles and responsibilities or refer to specific procedures for responding to other emergencies such as confirmed sabotage and threat incidents, complaints involving confirmed product-related illness and man-made or natural disasters which threaten the safety of the food supply. The Agency has four emergency plans and the Food Emergency Response Manual should identify the relationship of the Food Emergency Response System to other related emergency response plans, for example, the Agency's Regulatory Affairs Division and the Food and Agriculture Emergency Response System were involved in the response to the ice storm. The ice storm as a food safety emergency is discussed in paragraph 37.

Recommended Actions: The Canadian Food Inspection Agency should ensure that all Regions have fully documented regional emergency procedures, and that these are consistent with the Food Emergency Response Manual.

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.

Agency's response: The Agency agrees and has put in place a process to ensure each Area has documented emergency procedures consistent with the Food Emergency Response Manual.

The Agency has developed an Emergency Management Framework for natural disaster, sabotaging, tampering and reported illnesses. These procedures will be referenced in the Food Emergency Response Manual.

The Memorandum of Understanding between Health Canada and the Canadian Food Inspection Agency concerning Food Safety Emergency Response outlines their respective roles and responsibilities. We found, however, that both parties had different interpretations of when the Agency should request Health Canada to conduct a health hazard evaluation. Once this was brought to the attention of Health Canada and the Agency, both parties began and continue work to clarify the Memorandum of Understanding.