The Food Emergency Response System of the Canadian Food Inspection Agency

57 Documentation of the details of recall classification and rationale, effectiveness checks, disposal or correction of recalled products and the termination of recalls for the recalls that we reviewed was inconsistent. This information can be used to effectively monitor each emergency and conduct a meaningful post-emergency review. The emergency management checklists (see paragraph 53) could form the basis for these reviews.

Recommended Actions: The Canadian Food Inspection Agency should conduct and document comprehensive post-emergency reviews on a more regular basis especially for complex emergencies.

The Agency should, at all stages of the emergency response process, document decisions, rationale, and results of actions taken.

Agency's response: The Agency currently is conducting post-emergency reviews and documenting post-emergency reviews which include a review of roles and responsibilities. The Agency sees post-emergency reviews as an excellent means to continually improve the recall system.

The Agency is currently documenting the decisions, rationale and results of actions taken at all stages of the emergency response process. The Issues Management System will capture a large amount of the required documentation electronically.

Agency's Monitoring of the Food Emergency Response System

58 The Canadian Food Inspection Agency has a statutory responsibility to monitor and report on its performance which includes the food emergency response system. For that purpose, the Agency has developed a performance measurement framework which includes, as one activity, product recall and emergency response. For this activity it sets as the outcome "product deviations are effectively and efficiently managed by partners" and includes as possible measures speed of response and qualitative assessments. This is a very positive step.

59 On their own, these general objectives and measures are too broad to provide an adequate basis against which to measure and report on performance. There is a need to make these operational and to clarify what the Agency specifically expects to accomplish and how they are going to know that they have accomplished it. For example, one measure identified was speed of response. There is a need to define it further and specify targets or standards.

60 Clearly defining objectives and related performance measures for the Food Emergency Response System would also allow the Agency to give clear direction to its staff and facilitate the conduct of post-emergency reviews. The performance measures could be included in the checklist of information gathered on each recall (see paragraph 53). This would be an easy and efficient way to gather the relevant information necessary for monitoring and reporting on performance.

Recommended Action: The Canadian Food Inspection Agency should refine the objectives and performance measures for its Food Emergency Response System and use these measures to report on its performance.

Agency's response: The Agency reports on the performance of its food emergency response in its annual report to Parliament and will continue to improve its performance reporting in this area.

CONCLUSION

61 The following points summarize our conclusions with respect to the criteria used for the assessment. We recognize that the Food Emergency Response System adopted by the Canadian Food Inspection Agency operates in essentially the same manner as food emergency systems which had been in place previously in Health Canada and Agriculture and Agri-Food Canada. These were and remain consistent with practices for other inspection programs charged with responding to emergency situations. However, the assessment team believes that improvements can be made which will provide a greater level of assurance that consumers are protected from hazardous food products in emergency situations.

Roles and responsibilities: The roles and responsibilities for handling recalls were mainly clear and well understood within the Canadian Food Inspection Agency. 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. The Food Emergency Response Manual does not provide specific procedures for these types of food safety emergencies, or reference to other emergency plans and the role and responsibility of all other stakeholders that may play a role in a food emergency response.

Identification of food safety emergencies: Recalls were, for the most part, identified promptly and investigated sufficiently to reach a conclusion. Current Agency inspection, sampling and complaint investigation programs are a valuable source of information.

Risk assessment: The estimation of risk in a potential emergency situation 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.