Add to that, Dr. Godefroy says, Canada’s food safety legislation was subjected to recent updates, with an amendment to Canada’s Food and Drugs Act and the development of a new legislation under the name of Safe Food for Canadians Act.
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“This latter legislation constitutes a major overhaul of the Canadian food legislative landscape with a consolidation of the various federal acts under which food is managed,” Dr. Godefroy points out. “Regulatory provisions under this legislation are still to be developed.”
Like the U.S.’s FDA Food Safety Modernization Act (FSMA), the new Canadian legislation and subsequent regulatory provisions are to focus on preventive measures taken by industry to manage and mitigate food risks during production from farm to table, Dr. Godefroy explains.
“This overhaul will result in major enhancements and clarification of regulatory requirements associated with food production,” he says. “In parallel, Canada’s food inspection agency, the Canadian Food Inspection Agency, has embarked on a major food inspection modernization process aiming to create a more uniform approach to inspect and enforce food safety legislations and regulations. Until recently, the system was disproportionately putting emphasis on meat and poultry and was relying on a commodity-based approach.”
While these changes will likely result in major simplification, modernization, and improvements of the country’s food regulatory system, some challenges remain, Dr. Godefroy relates.
“Fragmentation of regulatory requirements, which make a distinction between foods crossing provincial boundaries versus those that are sold within one single province, continues to be an issue,” he says. “According to the new proposed rules, the enhanced regime would only apply to the former category of foods. Foods sold within the boundaries of a single province are only subject to general rules under the Food and Drugs Act and provincial requirements. They would therefore not be subject to the application of the ‘preventive measures’ paradigm. Similarly, it will be important that the application of preventive controls and the way this is verified be commensurate with the size and importance of the food establishment. Such details of the development and application of the regulatory provisions are therefore still to be worked out.”
Also, in an environment of scarce resources, there continues to be fragmentation and dispersion of efforts, between the various levels of governments and between agencies within a single level of government overseeing food, Dr. Godefroy adds.
“For example, the risk assessment and standard setting mandate is shared between Health Canada and the Canadian Food Inspection Agency, resulting in the need to rely on complex governance mechanisms and major efforts of coordination that add pressure on existing resources, all in a constrained environment,” he explains. “There are a number of opportunities for improvement in integrating efforts and maximizing the use of resources, such as the consideration of a single food standards authority. This would simplify the system for industry, for consumers, and for the agencies themselves.”
As far as thematic priorities are concerned, Dr. Godefroy says Canada’s food safety system is challenged by the same drivers of change as what are witnessed internationally. These include:
- Applying a preventive approach through the development of guidance to identify, prevent, and/or mitigate hazards and associated risks during all phases of food production.
- Identification and management of emerging pathogens (resulting from climate change or other drivers) and occurrence of known pathogens in new food sources/vehicles.
- Continued importance of managing risks associated with allergens in food processing, without the reliance on the propagation of allergen precautionary statements on food labels.
- Multiplication of food chemical risks from known and emerging sources (environmental contamination, natural contaminants such as mycotoxins and phycotoxins, process induced chemicals) and their management in a changing environment influenced by changes in climate and food production patterns globally.
- The emergence and propagation of antibiotic-resistant pathogens from food sources and potentially linked to the administration of such drugs to food-producing animals.
- Applying the relevant risk-based approach to the management and administration of chemicals used in conjunction with food production such as packaging materials, processing aids, and other indirect additives such as sanitizers used in food production.
- The emergence of novel food formulations, which include a broader range of bioactive ingredients either extracted from other foods or from synthetic sources and added to foods as a vehicle of administration or to respond to consumer demand related to the development of functional foods. These foods have a different risk profile and currently face a system varying from either a vacuum of oversight or a too rigid environment unfavorable to product innovation.
“Canada’s food and agri-food production sector is amongst the most developed and prolific globally with a high throughput, given the sheer size of agricultural land and the vitality of the livestock sector,” Dr. Godefroy says. “Yet, Canada’s food processing sector has been shrinking, impacted by amongst other challenges, global consolidation.”