3.5 Canada

3.5.1 Imports

Canada is a significant importer of fish and fish products and, importantly for this study, it also collects and records detailed information on rejections and detentions at borders. It has also been, along with other countries, on the forefront for developing and implementing HACCP-based fish safety and quality approaches.

From 1999 to 2002, Canada imported over half a million tonnes of fish and fish products annually, including meal and oils (Table 41). In the region of half of the imports came from its neighbour, the United States. The next main exporters were Peru, Thailand, China, Norway and the Russian Federation, accounting for a further 35 percent of imports.

The total imports are also broken down by continent (Table 42), as this allows a later comparison with the border cases from these same regions. Not surprisingly North America dominates, with Asia and Central and South America as the next two most exporting regions. Worthy of note is that the only continent that has decreased in volume exported to Canada year on year over the four-year period is Europe. The shortfall from Europe has been more than made up from increased exports from the United States, the Americas and Asia.

TABLE 40
Border cases in Japan per unit volume of imports, 2000 - by continent

TABLE 41
Top ten exporters to Canada 1999-2002 (2002 basis)

Source: Fisheries and Oceans Canada
(http://www.dfo-mpo.gc.ca/communic/statistics/trade/canadian_trade/import_data/index_e.htm).

TABLE 42
Total Canadian imports by exporting continent 1999-2002

Source: Fisheries and Oceans Canada.

The following table^[12] (Table 43) breaks down the imports into species groups and into main product types, again for comparative reasons when examining the border case data. These data do not include fishmeal and oil. The data also only cover the period from 1999-2001, as the FAO statistics provide this breakdown, and 2002 data were not available at the time of this study. The table uses the same definitions for product types (prepared, processed, etc.) as was used for the discussions about the European Union - for comparative reasons.

TABLE 43
Total Canadian imports by product type and species group 1999-2001

Note that for some products several types e.g. prepared and frozen, are used to categorize the product. Source: FAO.

The main species group was fish, and within this group, the main species imported are tunas, salmon and cod in a mixture of forms (frozen, chilled, live, processed, etc).

3.5.2 Border cases

During the 4 year period studied (1999-2002), Canada recorded just under 600 border cases where imported fish and shellfish were detained for inspection. Peak years were 1999 (170 cases) and 2002 (174 cases). However, no trends are identifiable from this data set.

As mentioned earlier, the data set for the border cases in Canada is detailed and thus further examination of the border cases is possible. Table 44 details the border cases by year (1999-2002), by risk and by exporting region.

As can be seen from these data, the main exporting continents from which border cases in Canada arose were Asia, Europe (both European Union and non-EU) and Central and South America. Overall, some 36 percent of cases during the 1999-2002 period were from exports from Asia, 32 percent from Europe and 18 percent from Central and South America. What is interesting when examining the European data is that the European Union exporters had more border cases in Canada than non-EU European exporters.

However, these figures do not take into account the volume of imports into Canada from these respective regions and this is an important point. A later section in this chapter puts the border cases into perspective, comparing the border cases with the volume of exports from each region.

Border cases due to microbial problems were relatively low over the 1999-2002 period accounting for only 5 percent of all cases in the four-year period. Where problems occurred, it was due to Listeria spp. (13 cases), E.coli (10 cases) and Salmonella (4 cases) with these 3 bacteria accounting for 93 percent of cases. It is also interesting to note that Asia (with 14 cases) and the European Union (with 10 cases) accounted for over 80 percent of the microbial based cases.

As can be seen from the data however, the main causes of concern were chemical (22 percent) and "other causes" (73 percent). The relative frequency of border cases arising for chemical or other reasons was not consistent for exporting regions or annually. For instance, Asian exporters in 1999 and 2000 had most problems with other causes (five times more other causes than chemical), whilst in 2001 and then 2002 this relative frequency was shifting towards almost a 1:1 relationship.

TABLE 44
Border cases in Canada from 1999-2002 by cause and exporting region

Source: Canadian Food Inspection Agency.

It is worth breaking these two categories down further.

Table 45 shows the breakdown of border cases, from 1999-2002, where a chemical risk was identified as the reason for detention or rejection.

Two things become apparent when examining this table. First, there are three main chemical causes identified - mercury, sulphites and histamine - and these appear every year as a significant chemical contamination associated with imports. A second trend, or lack of one, is the fact that other chemical based risks appear in one year and then not again, or re-appear a second time in a later year. It will be important to understand the cause for this so that proper advice can be given to exporters, especially those in the developing world. Further discussions on this appear in Annex A.14.

By far and away the largest category of risks identified by Canadian authorities was that classified as "other causes". As a reminder, this category is applied for risks other than microbial and chemical risks. In the case of Canada, it is clear that these other causes predominate in border cases, though some risks in this category can be indirectly relevant to microbial risks, for instance, can integrity.

Table 46 details the breakdown of reasons for border cases classified as other causes from 1999-2002. The main problem is classified as "sensory evaluation", accounting for 47 percent of cases. Under Canadian procedures, sensory evaluation is used to determine quality attributes, though if decomposition is suspected, then samples are analysed for histamine.

TABLE 45
Border cases in Canada from 1999-2002 - chemical causes

Source: Canadian Food Inspection Agency.

TABLE 46
Border cases in Canada for 1999-2002 - "other causes"

Source: Canadian Food Inspection Agency.

Net weight problems are next in importance (28 percent). This problem, however, does not always imply a health hazard to consumers and is often an issue of economic fraud (whether intentional or not), except for canned low acid seafood where underweight can result in a safety hazard. However, the can integrity test (19 percent) is used to protect consumers from possible health hazards, specifically from the anaerobic bacteria, such as Clostridium botulinum. This test is performed at the border in Canada and can detect minor faults in cans and the seals. As the requirements for can integrity checks at the border are systematic in Canada but not in other countries, and the standards used, especially regarding wrinkle measurements, are more stringent, companies unaware of these differences do not set their seaming machines and double seam control to the Canadian requirements and their products can be penalized at the Canadian border.

This does not however imply that other importing countries do not control can integrity. To the contrary, the United States and the European Union rely more on the control (prevention) at the source to protect against can integrity problems rather than quality control at their borders only. Indeed, the United States has a specific regulation^[13] for low acid canned food and acidified food (LACF/AF) which requires the exporting establishment to be registered with FDA and to carry out can seaming operations under a Better Process Control School (BPCS) certified supervisor. The BPCS programme certifies supervisors of thermal processing systems, acidification, and container closure evaluation programmes for low-acid and acidified canned foods. Likewise, in the European Union, can integrity is part of the HACCP system and any testing is carried out by the Competent Authority of the exporting country.

TABLE 47
Border cases in Canada from exporting regions - "other causes" for period 1999-2002 combined

* Central and South.
Source: Canadian Food Inspection Agency.

TABLE 48
Border cases in Canada from 1999-2002 - by product types and species groups

* Note that for some products several types e.g. prepared and frozen, are used to categorize the product.
Source: Canadian Food Inspection Agency.

This may also reflect differences in the types of products exported from the different regions. For example, a region exporting mainly canned products, is likely to have higher border cases of can integrity. Unfortunately, the available data do not permit to refine the analysis further.

Table 47 breaks down the other causes by exporting region. The trend differs between the regions. Asia, Oceania and the Americas mirror the overall trend of sensory evaluation being the main cause of border cases, followed by net weight and can integrity problems. Europe (non-European Union) and Africa also have sensory evaluation issues as their main area of concern but net weight issues and can integrity issues are swapped. However, the European Union has most problems with net weight and can integrity issues, possibly because of the differences in standards evoked before (see Table 10).

This may also reflect differences in the types of products exported from the different regions. For example, a region exporting mainly canned products, is likely to have higher border cases of can integrity. Unfortunately, the available data do not permit to refine the analysis further.

Table 48 breaks down the border cases by product type and species group for the four-year period 1999-2002. The predominant forms of product causing border cases are frozen, prepared, processed and canned. It is interesting to note that fresh and cured fish accounts for only around 5 percent of border cases during the 4 year period and that caviar accounts for 2 percent.

TABLE 49
Combined border cases in Canada from 1999-2002 - by cause and product type/species

The main problem species group is "fish", with bivalves and shrimp coming in a distant second and third. Other groups (crab, lobster and cephalopods) account for only 8 percent of border cases. However, it will be interesting to note the relative frequency when trade volumes are considered in the next section.

Finally, the data set allows us to determine the causes for border cases according to the species or products imported (Table 49).

3.5.3 Border cases in Canada in the context of import volumes

As the data sets come from different sources, the periods studied are restricted to those where both border cases and import volumes are known. For Canada, we can compare the 1999-2002 period for the border cases arising from exporting regions. For border cases arising from problems associated with products or species, we are restricted to the years 1999-2001.

Table 50 breaks down the border cases per 100 000 tonnes from various exporting regions. The picture changes dramatically from earlier indications of absolute numbers of border cases. It becomes clear that in exports to Canada, Africa performs poorly relative to other continents, by some considerable margin. The European Union and then Oceania are the next two regions that most give rise to border cases.

As was noted for the European Union, it is interesting to note that the four regions that export the most product to Canada are also the best performing. As before, it is not possible to determine the exact reasons for this, but the same possibilities present themselves i.e. it is probable that those exporting countries that trade the largest volumes with Canada are likely to have larger consignments, thus the number of border cases per unit volume would be lower, but absolute volumes (in kg for instance) would be high as the problem consignment is larger. Also, these exporting regions are more likely to be familiar with the Canadian regulations thus reducing the likelihood of problem consignments.

In the Canadian system, once an exporter is found to be responsible for a problem shipment, then the exporter is checked systematically for four consecutive consignments. This increases the chances that future problems, if any, will be found. It also should provide incentive to get things right, though.

A useful figure to note is the total number of border cases per unit volume (100 000 tonnes) arising in Canada from all imports each year. This figure can be compared to other regions later in the analysis section. From 1999 to 2002, the figure ranges from 22 to 35 border cases/100 000 tonnes imports.

As regards products and species, a similar situation arises where the higher absolute numbers of border cases for a product category or species are no longer the main problem relative to the amount of trade in those species/products (Table 51).

TABLE 50
Border cases in Canada per unit volume of imports, 1999-2002 - by continent

* Central and South America. Source: CFIA and FAO.

TABLE 51
Border cases in Canada per unit volume of imports, 1999-2001 - by product types and species groups

Note that for some products several types e.g. prepared and frozen, are used to categorize the product. Source: FAO.

Frozen products now rank lower, with processed^[14] products predominating in the relative importance of border cases. The very high levels of caviar cases per unit volume of trade may not be relevant and some care must be taken with the relative figures due to the very low amounts traded - very high figures for 2000 and 2002, and zero for 2001. What is maybe interesting is that smoked products (classified under cured), which have hit headlines in recent years, prove to be low risk products. Maybe this is the result of the considerable exposure of Listeria spp. in smoked fish products having an effect on the processors and is indicative of greatly improved processing conditions for cured products in general.

Likewise for species trends, fish do no longer rank highest, with bivalves consistently predominating (for border cases). However, the most obvious reason for this does not hold true. It might be expected that microbial or chemical problems would predominate for bivalves, but in fact sensory evaluation, net weight and moisture problems cause the border cases. However, this is against a backdrop of a low level of microbial cases in Canada in border inspections.