Dynamite comes in small boxes

After a prolonged silence on the status of Canadian Food Inspection Agency (CFIA) modernization and the Safe Foods for Canadians Act, my email inbox suddenly received a dozen emails from a variety of sources to announce that these initiatives were still alive. Among the emails were a couple from the CFIA asking for comments and suggestions on possible regulatory approaches for micro and small enterprises. Here are the highlights of my reply to this online questionnaire.

Should the proposed requirements for preventative control plan (PCP) record keeping requirements not apply to micro-scale business and to other enterprises? If extended, what measure(s) should be used to qualify such enterprises for an exemption?
It is in consumers’ interest that any enterprise selling food for human consumption intra or inter-provincially have a documented PCP, a HACCP program, a traceability program and be registered with the CFIA. However, if an exemption program is implemented, any criteria based on revenue, the number of employees and volume of product sold (i.e. self-reporting) is open to manipulation. I am not totally opposed to using self-reported qualifiers but I strongly recommend that a CFIA risk assessment be part of the qualification process.

It is also in the public interest for these micro and small enterprises to be inspected when operating. These inspections needn’t be done by the CFIA but could be done by municipal and/or provincial food establishment inspection personnel.

Should micro and small businesses have more time to comply?
Our American neighbours are giving their micro and small enterprises three years to comply with their regulations. It would be hard for Canadian regulators to require anything less. However, it would be a mistake to turn a blind eye to this sector until the day that the regulations come into force. As recommended earlier, I believe that registration with the CFIA should be mandatory for all food processors regardless of size. Once registered, micro and small firms should be required to develop a critical path delineating the dates they will achieve each compliance milestone and ending with full compliance by the time the sector regulations come into force.

What kinds of products and support services would be helpful to make compliance easier and less costly for micro and small businesses?
At no time in human history has it ever been easier and less expensive to share information and to communicate, thanks to web-based and cloud-based solutions.
Prior retiring in 2007, I had the opportunity to market food safety software and witness the implementation of this software in companies in Canada and the U.S. This type of software has become easier to use, more effective and less expensive since then.

As a service to micro and small enterprises, the CFIA should develop food safety portals loaded with food safety information and forms that these small firms can tailor to some degree for their own needs. Modern commercial food safety software allows the user to set critical limits which, if exceeded, alert the user to the problem. This and other features can be built into the CFIA-developed software. Today’s food safety software also escalates alarms up the chain of command. Records of these events are permanent and cannot be altered.

Such food safety software and training should be provided at no charge to micro and small enterprises, saving them anywhere from $5 to $15,000 upfront and much more over time. However, I believe that the CFIA should have some level of access to the user’s food safety data, including being alerted when out of compliance food safety alarms are not addressed on a timely basis.

The size of a food enterprise has no bearing on the extent of damage and devastation that can be caused from a failure to manage food safety. The precautions taken to handle one stick of dynamite are much the same for the entire box. In the consumer’s mind, food safety concerns are the same regardless of the size of the supplier. I am not advocating a one-size-fits-all approach, but at the very least all food enterprises should be registered.