Agenda Item 4.1 a) GF/CRD Canada-1   

FAO/WHO Global Forum of Food Safety Regulators
Marrakesh, Morocco, 28 - 30 January 2002

Canada's regulatory framework and food safety program

COUNTRY PAPER PROPOSED BY CANADA



SUMMARY

Canada's food safety system operates in a multi-jurisdictional setting involving federal, provincial, territorial and municipal authorities. Because of this shared jurisdiction, a comprehensive agreement entitled Food-borne Illness Outbreak Response Protocol outlines the roles and responsibilities of all governments that are involved in the investigation of a food safety emergency. It clarifies the roles of all participants in the investigation and details an integrated approach in response to national and regional food-borne illness outbreaks. For transboundary situations, Canada endorses and follows the Codex Guidelines for the Exchange of Information in Food Control Emergency Situations. As for domestic products, the Protocol serves as the guidance document to address a national food safety emergency involving an imported product.

New initiatives to improve food safety emergency procedures involve projects to enhance early detection and investigation of a food-borne illness. Health Canada has developed a program entitled "Skills Enhancement for Health Surveillance" which is an internet-based training initiative for local and regional public health departments across Canada to increase skills in epidemiology, surveillance and information management. A national reporting system is also being developed entitled "Outbreak Investigation" to improve notification of all food-borne illness outbreaks in Canada.

With these procedures in place, Canada is well prepared to deal with national and transboundary food safety emergencies.

CANADA'S REGULATORY FRAMEWORK AND FOOD SAFETY PROGRAM

The investigation and control of national and transboundary food safety emergencies in Canada operates in a multi-jurisdictional setting involving federal, provincial, territorial and municipal authorities. The primary mandate of all regulatory authorities is to protect the health of the consumer with policy decisions which are based on sound science and fully integrated to ensure effective communication and cooperation between jurisdictions.

At the federal level, the responsibility for food safety is shared by Health Canada and the Canadian Food Inspection Agency (CFIA). Health Canada sets standards and policies for food safety and nutrition and performs research, risk assessment and pre-market review for foods sold in Canada. Health Canada is also responsible for surveillance of food-borne, water-borne and enteric human illnesses and provides comprehensive expertise and support for epidemiological investigations.

The CFIA is responsible for enforcing all food safety standards set by Health Canada and all federally mandated food inspection, compliance and quarantine services. CFIA designs, develops and manages inspection, enforcement, compliance and control programs and service standards.

At the local level, provinces and territories also have a public health mandate, including food safety surveillance, investigations and compliance. Often, they are the first to be notified of potential food-borne illnesses, and thus play an integral role in the food safety system. Provinces and territories enact legislation complementary to federal statutes governing foods produced and sold within their own jurisdictions. Because legislative power may not be delegated from one level of government to another, governments collaborate in areas of shared jurisdiction, such as food inspection, to ensure effective and efficient program delivery.

Coping with National Food Safety Emergencies

Since food safety is a shared federal responsibility between Health Canada and the CFIA, a Memorandum of Understanding has been established that outlines the respective roles and responsibilities and establishes principles and mechanisms for an effective working relationship between the two organizations. A number of formal working agreements have been developed including one entitled Food Safety Emergency Response. This agreement broadly defines a food safety emergency as any situation involving or potentially involving food (as defined in the Canadian Food and Drugs Act) which may pose a high risk to human health. The document outlines guiding principles and responsibilities for food safety emergencies with human illness and those with no known human illness. The primary responsibility of Health Canada during the food safety emergency is to conduct the health risk assessment and to conduct and coordinate the epidemiological investigation. The primary responsibility of the CFIA is to coordinate the food safety emergency response such as the food investigation, the trace back and required food recalls, and related public communications. In addition, the CFIA has an Office of Food Safety and Recall which is a decision-making centre for managing food emergencies and examines emergency response processes and procedures with the view to continuously improve emergency responses in a timely, appropriate and consistent manner.

Food-borne Illness Outbreak Response Protocol

Because of the shared jurisdiction in Canada, a comprehensive document entitled Food-borne Illness Outbreak Response Protocol was developed outlining the roles and responsibilities of the federal, provincial, territorial and municipal governments that might be involved in the investigation of a food safety emergency. This document serves as the formal arrangement that clarifies the roles of all participants in order to guide the response and investigation of a food safety emergency.

The Protocol is a partnership among provincial and territorial governments, Health Canada and the CFIA that details an integrated approach in response to national food-borne illness outbreaks, and regional outbreaks causing high levels of severe morbidity or mortality. The Protocol ensures that all responsible agencies are notified promptly and work collaboratively to mitigate and contain risks. It lays out clear working relationships between the federal and provincial and territorial agencies to ensure all responsible agencies are involved as early as possible in the investigation and continue to work collaboratively as a group, with each member taking responsibility for their respective area of expertise. For each emergency situation, the Protocol calls for the establishment of an Outbreak Investigation Coordinating Committee (OICC) which is comprised of representatives from each body involved in the investigation and control of the food emergency. The OICC is a dynamic group that changes from outbreak to outbreak, and ceases to exists once the food emergency is over.

The OICC functions as a joint risk management team. Joint decision making is encouraged and all OICC members have access to all relevant information. Where appropriate, other bodies, including international counterparts, are invited to join the investigation particularly on transboundary food emergency outbreaks. For food related outbreaks involving two or more provinces the epidemiological investigation is conducted by Health Canada. For transboundary or international outbreak situations, Health Canada acts as the main liaison for information sharing.

Each agency has the responsibility for communication with the public within its jurisdiction. However, during a food emergency communication must be a co-ordinated effort. It is important to coordinate the timing and content of released messages to the public regarding the emergency to avoid confusion and mis-information. When appropriate, media relations representatives from Health Canada, CFIA and the provinces and territories attend meetings of the OICC.

The OICC is also responsible for coordinating the post outbreak reviews and providing recommendations to all agencies involved in the outbreak regarding lessons learned which could be addressed through regulatory or policy changes.

New initiatives to improve food safety emergency procedures

One of the key factors in the identification of food safety emergency is the early detection and investigation of a food-borne illness. In efforts to improve consistency in the early detection of these, Health Canada has developed a program entitled "Skills Enhancement for Health Surveillance." This program is an internet-based training initiative for health professionals in local public health departments and regional health authorities across Canada to increase skills in epidemiology, surveillance and information management.

The system includes the development of educational training manuals and other instructional materials. Included within the program is a Field Epidemiology Training Program (FETP) to strengthen public health practice in Canada through a training program which fosters excellence in the practice of applied epidemiology. The most visible aspect of the FETP comes from its support of field investigations for the control of diseases of local or national interest.

A system is also being developed by Health Canada to improve notification of all food-borne illness outbreaks. This involves an ongoing pilot project and development of a common incident reporting system entitled "Outbreak Investigation" that is under consideration for use as a national system for reporting food safety investigations.

Health Canada, the CFIA and a number of provincial public health laboratories are collaborating in a pilot project allowing the sharing/exchange of molecular typing images derived from isolates of food or water borne bacterial pathogens. This recent project using "pulse field gel electrophoresis" images is based on a similar program of the Centre for Disease Control in Atlanta titled "Pulsnet", and has already shown significant improvement in the investigation and detection of food-borne incidents.

Transboundary food safety emergencies

The importance of having in place a formal arrangement detailing roles and responsibilities to ensure a co-ordinated, early and rapid response and identification of food safety emergencies is especially necessary as the globalization of food trade increases. Globalization and the integration and consolidation of food industries means that large amount of food from a single source can be distributed over far greater distances leading to the possibility for wide spread disease outbreaks. Food safety emergencies can have enormous social and economic consequences on communities, the regulatory agencies and the health system in general.

Canada endorses the Codex Guidelines for the Exchange of Information in Food Control Emergency Situations1 and the Codex Guidelines for the Exchange of Information between Countries on rejections of Imported Food2 as they relate to both imported and exported foods. It is important that information exchange between countries relative to food safety emergencies is rapid to minimize the risks to human health and for the early identification and recall of the food from the market. While the guidelines offers a standard format for international information exchanges in food control emergency situations, the Food-borne Illness Outbreak Response Protocol is the guidance document used by Canada to address national food safety emergencies.

The CFIA has the responsibility for trace back of all products implicated in a food safety emergency. When product trace back involves other countries, the CFIA will take the lead and be responsible for communicating with the appropriate regulatory authorities and enlisting their support in the investigation.

Lessons learned

The goal of all food control authorities is to prevent the production, distribution and sale of any food which contains a hazard to human health. An important safeguard for the protection of human health is the development of a food safety system which is fully integrated between the different agencies involved in the regulation of food safety to allow for the early detection and reporting of any food-borne illness outbreak. This is especially true for countries such as Canada which operates in multi-jurisdictional context. The development of clear policies and documents identifying the roles and responsibilities of all parties in a food emergency situation is vital in preventing the wide spread distribution of a food-borne disease outbreak.

 


1 CAC/GL 19-1995

2 CAC/GL 25-1997