CANADA: Progress on food safety

26.jun.11
CFIA

A collaborative report prepared by:

Agriculture and Agri-Food Canada
Canadian Food Inspection Agency
Health Canada
Public Health Agency of Canada


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Introduction
In the summer of 2008, an outbreak of foodborne illness caused by the presence of Listeria monocytogenes in ready-to-eat meat resulted in the deaths of 23 Canadians. The Government of Canada immediately took a number of preventive actions to reduce the risk posed by the possibility of similar outbreaks in the future.

The Canadian Food Inspection Agency (CFIA) tightened food safety controls in federally registered plants that produce ready-to-eat meat products. The Agency also strengthened its directives regarding the control of Listeria, based on Health Canada’s policy on Listeria monocytogenes in ready-to-eat foods. These directives include the requirement that processors of ready-to-eat meat conduct environmental testing in all plants and immediately report any positive findings to CFIA.

Each of the federal organizations with responsibility for food safety and foodborne illness events—CFIA, Health Canada and the Public Health Agency of Canada (PHAC)—examined its operations and the actions it had taken during the outbreak. Each organization carried out a “lessons learned” exercise and implemented an action plan to strengthen its response to outbreaks of foodborne illness.

Because of the serious nature of the listeriosis outbreak, the Government of Canada also asked Ms. Sheila Weatherill to lead an independent investigation into the circumstances of the outbreak and to make recommendations to strengthen the food safety system.

In July 2009, the Report of the Independent Investigator into the 2008 Listeriosis Outbreak (the Weatherill Report) was submitted to the Government and publicly released. The Report outlines the events that led to the outbreak, describes the Canadian food safety system and the responsibilities of industry and government, examines what went wrong, and proposes 57 recommendations to help prevent future outbreaks and strengthen the food safety system. In September 2009, the Government committed to act on all of the recommendations of the Weatherill Report and to report back to Canadians within two years.

Since September 2009, the Government has made solid progress in responding to the Weatherill Report recommendations. This third interim report describes that progress with specific reference to three priority areas—reducing food safety risks, enhancing surveillance, and improving emergency response. Canadians can be assured that the Government has responded vigorously to the Independent Investigator’s recommendations, and is continuing to improve the food safety system in Canada.

Reducing Food Safety Risks
In the complex and increasingly integrated global economy, with food sources and food production-and-distribution methods in a state of continual change, greater vigilance is required, both of regulators and industry, to ensure prevention and the effective management of new and emerging risks to food safety. The Government of Canada continues to review and adjust its food safety standards, policies and operational procedures to ensure that its oversight of food safety remains effective.

Health Canada Listeria Policy Revision
The Weatherill Report noted that while the publication in 2004 of Health Canada's Listeria policy on Listeria monocytogenes in ready-to-eat foods placed Canada at the forefront of food safety policy, by 2008 that document was no longer groundbreaking, due to rapid advances in scientific knowledge and technology. The Report recommended that Health Canada’s policy be modified in order to provide more up-to-date guidance to food-processing firms.

In response, Health Canada released a new policy on Listeria monocytogenes in ready-to-eat foods on April 1, 2011, following consultations with consumers, industry and other stakeholders. The 2011 policy has developed new end-product compliance criteria that are similar to the International Codex Alimentarius Commission standards; categories of ready-to-eat foods according to risk; a more detailed compliance action decision tree; advice on including an environmental monitoring program in all plants; and encouragement to use treatments that inhibit or eliminate the growth of Listeria monocytogenes.

There is also an increased focus on outreach with the federal/provincial/territorial (F/P/T) community to increase awareness of the risks of foodborne listeriosis and to provide guidance on how to reduce the risks of acquiring listeriosis to personnel in institutions where high-risk people may be exposed. CFIA will continue to work with stakeholders to oversee the full implementation of the 2011 policy.

Faster Approvals
Health Canada is also responsible for the approval of food-safety interventions with proven health benefits such as the use of food additives that reduce the growth of pathogens like Listeria. The Weatherill Report urged that the approval process be reviewed so that such additives can be evaluated more quickly.

In response, Health Canada has provided guidance and a set of criteria to help industry seeking pre-market approval to identify food-safety interventions that offer proven health benefits. These guidelines were posted on Health Canada’s website in January 2011. Specific eligibility criteria have been developed in order to identify those applications that merit priority handling.

In addition, Health Canada is assessing other regulatory strategies that would help shorten approval timelines for safe additives, as well as for other food-safety interventions. For example, Health Canada has initiated a streamlined approach to publishing its intent to amend regulations to allow the use of certain food additives. The approach is to post web consultations of intended amendments and notify trading partners (instead of publishing such intents in Canada Gazette, Part I) while the drafting of the regulations is under way. Other areas for regulatory modernization are being explored as well.

Improved Processes
Weight-of-evidence Guidelines
The Independent Investigator found that agreement among government partners was needed regarding the weight of scientific evidence required to trigger both public advisories and food-recall decisions. In response, Health Canada finalized a guidance document in collaboration with PHAC and CFIA regarding the weight of evidence required to support appropriate and timely actions to protect consumers during foodborne illness outbreak investigations. Evidence to be considered includes the microbiological information gathered through food-sample testing and human illness reports, the epidemiological information collected from human cases, and the information collected from subsequent investigations at food-processing plants. F/P/T and selected international partners were consulted during the drafting process. The guidance document will be posted on the Health Canada website in 2011.

Health Risk Assessments
The Weatherill Report also noted some limitations in the capacity of Health Canada to carry out human health risk assessments in a timely way. The Department is hiring additional specialized experts, and is continuing to train additional health-risk-assessment staff in order to provide 24/7 coverage and to meet a surge in demand in the case of a national foodborne illness event. As well, the Department is enhancing components of the health-risk-assessment process being used to support CFIA during its food safety investigations, including establishing service standard times for health risk assessment responses. The quality of risk assessments is also being enhanced through improved methodologies in line with recent scientific developments.

Engagement and Consultation with Stakeholders
Agriculture and Agri-Food Canada (AAFC), in collaboration with industry, established the Agri-Subcommittee on Food Safety (ASFS) in 2010. The purpose of the Subcommittee, which includes members from CFIA, Health Canada, and PHAC, is to strengthen relationships among all federal food safety partners and the food industry, to ensure a common understanding of the roles and responsibilities of all partners, and to contribute to the continuous improvement of food safety policies and standards. The Subcommittee, which met four times in 2010-2011, is developing an industry-government work plan that takes into account key recommendations from the Weatherill Report.

The Independent Investigator recommended that CFIA create a formal and transparent consultation strategy that defines its required engagement with stakeholders. In response, CFIA has developed an agency-wide consultation framework that provides an integrated, coordinated and consistent approach to consultation, and facilitates increased transparency and informed decision-making. The draft CFIA Consultation Policy and Framework document was posted on the CFIA website and the “Consulting with Canadians” website on May 18, 2011 for a 30-day consultation. The consultation closed on June 18, 2011. Comments submitted are currently being considered and the document will be amended accordingly.

As a partner in food safety, CFIA has worked to bring the Investigator’s recommendations to the attention of all federally registered meat-processing establishments. These establishments received a letter dated March 5, 2010 outlining the industry-specific recommendations in the Weatherill report, reminding them of their food safety responsibilities, and underlining the obligation of industry to report food safety threats as required under the Meat Inspection Act and its regulations.

CFIA also engages regularly with industry and consumers to discuss the Weatherill report recommendations and food safety issues. For example, the first two Consumer Association Roundtable meetings were held in December 2010 and June 2011. The goals of the Roundtable are to strengthen partnerships with key stakeholders and enhance consumer engagement in awareness, communication and policy development.

Inspectors and their Tasks
Each federally registered meat-processing plant must have a food safety plan. The Government’s Compliance Verification System (CVS) sets out the procedures to be used by inspectors to verify the design and implementation of such plans. The Weatherill Report noted that CVS is well regarded and broadly supported in the field, but that improvements to its design, planning and implementation need to be made.

In response, the Government of Canada conducted a comprehensive review of the compliance verification system. The report can be accessed from the Government's Food Safety Portal website.

Review of the Compliance Verification System (CVS)
An Expert Panel reviewed the technical requirements of CVS, including the details of CVS tasks, the frequency of task assignment, and the amount of time allocated to each task. The Panel concluded that CVS provides an excellent system overall for documenting the inspector’s verification activities, and that CVS tasks are well-aligned with CFIA’s food safety regulations. More flexibility in conducting task verifications was recommended to improve the efficiency and effectiveness of the inspector’s reaction to non-routine and emergency situations.

CFIA worked with a component of the Public Service Alliance of Canada’s Agriculture Union (the union representing meat inspectors) to conduct a front-line assessment of the way CVS is implemented at the field level. The assessment indicated that front-line inspection staff recognized the improvement that CVS represents over past inspection approaches: it increases consistency, and provides the level of detail required by inspectors to conduct their verification activities. Areas identified for examination and improvement include inspector training, information management and technology, and the management of heavy workloads. The recommendations made by the Expert Panel and the front-line assessment report are now being applied to CVS.

In fall 2008, an internal audit of CVS was conducted to provide assurance that CFIA's meat inspection activities are compliant with the Meat Hygiene Manual of Procedures. The audit report has been posted on the CFIA website.

A third-party review of CFIA’s calculation of the resources required by the Agency to deliver CVS in federally registered meat establishments was concluded in October 2010. The Government made funds available to hire 170 full-time food-safety inspectors, and as of January 2011, CFIA had hired all 170 inspectors. This investment fulfills the requirement for additional inspection resources in federally registered meat establishments, including the delivery of CVS tasks.

As recommended in the Weatherill Report, CFIA has explored opportunities to encourage inspector enterprise and increase accountability. CVS provides the flexibility for inspectors to pursue any food safety situation they might encounter during the inspection process. CVS procedures have been strengthened to ensure that the inspector is aware of current conditions and any areas of concern that may have an impact on food safety.

In addition, streamlined human resource processes and a national recruitment strategy have been implemented to support inspection managers and supervisors. These developments will allow inspection managers and supervisors more time to oversee inspection staff.

Training Plan
CFIA has completed an assessment of training needs and has developed a new national training plan for meat-processing-plant inspectors. The plan includes a new course curriculum that incorporates instruction in the required skills and facilitates continual training for both new and incumbent inspectors.

The first five weeks of classroom training has been delivered to inspectors and will continue as new inspectors are hired. Delivery of the next two weeks of classroom training has begun and development of the final two weeks is under way.

The new curriculum includes such topics as: food allergens and foodborne diseases; regulatory requirements for equipment and registered premises; sanitation; and control measures for Listeria in ready-to-eat meat products.

Better Equipment
The Independent Investigator suggested that inspectors could be more efficient if they were equipped with modern tools and technologies. As an initial step, CFIA has increased the use of laptops, cell phones and faster network connectivity. In addition, a pilot project completed on April 1, 2010 assessed whether inspectors—particularly those in remote locations—could benefit from wireless technology, which would allow them secure access to the CFIA computer network and applications.

The pilot project resulted in the development of a plan for the first phase of a new system to improve connectivity. The system will increase the ability to connect program specialists and inspectors across the country, and allow inspectors better access to information to support decision-making and improve communication. Implementation of the plan will depend upon Agency priorities within the broader information-technology investment strategy.

Compliance and Enforcement
CFIA has revised its Compliance and Enforcement Operational Policy to promote consistency in enforcement practices across the country. The updated policy was posted on the Agency’s website on February 9, 2011.

On March 16, 2011, CFIA began posting on its website quarterly information about the Agency’s enforcement activities. The information includes the names of food imports that have been refused entry into Canada and of federally registered food establishments whose licenses have been suspended, cancelled or reinstated. It also includes notices of violations with warnings and/or penalties, including identifying repeat offenders of animal transport regulations.

The posting of CFIA’s enforcement activities is part of the Agency’s ongoing commitment to transparency and will continue to be expanded.

Compliance and enforcement actions are being incorporated into the Agency’s Quality Management System. This is an agency-wide program for improving the consistency and quality of delivery of inspection programs through supervisory oversight.

Updated CFIA Manuals and Policies
CFIA reviews and updates its regulations, directives, and food safety programs on an ongoing basis. For example, imported-food-surveillance activities have been reviewed and are being updated under the Government’s Food and Consumer Safety Action Plan. The Food and Consumer Safety Action Plan is a series of initiatives to modernize and strengthen Canada’s safety system for food, health and consumer products, and to better support the collective responsibilities that government, industry and consumers have for product safety.

The introduction of streamlined business processes is of great importance to the Agency. In April 2011, CFIA began developing a framework as well as business processes that will facilitate the routine updating of manuals. These manuals provide information on program requirements to CFIA staff, including guidance on the interpretation of legislation, regulations and related policies, and what is required to achieve compliance.

Meat Hygiene Manual of Procedures
CFIA has completed an update of the Meat Hygiene Manual of Procedures and has distributed the updated manual and posted it on the CFIA website. The Agency has also reviewed its process to ensure that updates are made on a regular and continual basis as part of ongoing business. To keep the food industry apprised of significant changes to the manual, an email subscription service is available on the CFIA website that alerts subscribers whenever changes are made.

New Environmental Monitoring Requirements
In February 2009, CFIA published an amendment to the Listeria directive that requires environmental monitoring of food-contact surfaces to detect the presence of Listeria. Sampling plans for ready-to-eat meats and food-contact surfaces were revised and implemented in April 2009 and were clarified in November 2009 to allow for reduced sampling frequencies for frozen foods, because of the lower risk of contamination by Listeria monocytogenes in those products.

For 2011-2012, these sampling plans will be revised again in order to link the frequency of testing at a specific establishment to the risk profile for the establishment and the products made there. Under the revised plans, CFIA will increase the level of sampling required of establishments that produce high-risk products.

CFIA is also in the process of building its capacity for trend analysis, including the development of a prototype system to monitor Listeria monocytogenes test results, both from industry and from CFIA testing programs and inspections. CFIA will collect and analyze data and test results from processing plants in order to better identify trends and areas of concern in establishments where risks are highest.

Food Safety Enhancement Program (FSEP) Manual
The CFIA Food Safety Enhancement Program (FSEP) Manual has been clarified and updated to specify the records-maintenance standards that food processors must meet. In the event of a recall, regulated parties must provide the distribution records of the recalled products to CFIA in a format that is readily accessible and legible.

The revised FSEP Manual also clearly designates to senior management of food-processing establishments the responsibility for ensuring compliance with applicable regulatory and CFIA program requirements, and for verifying that the establishment’s Hazard Analysis Critical Control Points (HACCP) system meets all requirements of the FSEP manual. Food processors are required to include all standard operating procedures in their HACCP systems. Under the HACCP plan, food processors agree to bring all information with potential consequences for food safety to the attention of the assigned inspector in a timely manner.

Industry awareness sessions on the changes made to the FSEP Manual have been completed.

Food Investigation and Response Manual (FIRM)
The CFIA is developing the Food Investigation and Response Manual (FIRM) to provide guidance to CFIA staff regarding the conducting of food-safety investigations and delivery of response processes, including recall processes.

The FIRM consists of procedures and templates to guide inspectors, including, for example, a template to share information with provinces and territories during post-recall verification activities. It also includes a revised Checklist for Gathering Implementation Information and Verifying the Firm’s Recall Plan.

Food Safety Education and Information
Food safety education and information play an important role in preventing foodborne illness. The Weatherill Report makes several recommendations, and the Government has taken a number of steps to provide Canadians, including those at a higher risk, with information and tools they need to protect themselves against a potential foodborne illness.

Food Safety Portal
In February 2010, the Government of Canada launched an online Food Safety Portal (www.foodsafety.gc.ca) as a one-stop source for information about food safety and foodborne illness. The food-safety and foodborne-illness information initiatives developed by CFIA, PHAC and Health Canada (and described in this report) can now be found on the Portal, along with links to CFIA, PHAC and Health Canada websites.

To raise awareness of the Food Safety Portal, CFIA issued a social media news release that encouraged individuals to share information about the Portal online by using social media book-marking and tagging options. As well, the Agency participated in six food-related events and exhibits between May 2010 and March 2011 to promote the Food Safety Portal and raise awareness of safe food-handling practices and recall procedures.

CFIA Online Communication Strategies
The Consumer Centre section of the CFIA website was expanded in November 2009 in order to explain the roles that consumers, government and industry play in food safety, and to provide more information on important food safety issues.

Since October 2009, CFIA has used Twitter to reach a wider audience on food safety issues and recalls. The Agency has attracted more than 1900 followers, including representatives from the media, health organizations, consumer groups and bloggers.

In addition, CFIA has developed a recall widget to automate the distribution of notices. Food safety stakeholders can embed the CFIA widget into their websites, blogs, or social media pages, allowing them to receive live content from CFIA regarding food recalls.

In February 2011, CFIA began issuing email notification of all allergy alerts to email notification service subscribers. This service is part of the CFIA’s ongoing commitment to deliver timely recall information to Canadians so that they can make informed food choices. CFIA now has 47,500 subscribers to the recall-and-allergy-alert email notification service.

In March 2011, CFIA began posting data on the Agency’s enforcement actions for food safety, animal health, and plant protection. This information is now available on the Consumer Centre of the CFIA website.

When serious foodborne illnesses are traced back to an Agency-regulated food-production establishment, CFIA uses its website to ensure that Canadians continue to be informed once an investigation into the event has concluded. Investigation reports posted online include a summary of the event, a review of the affected establishment, the results of the investigation and a summary of the corrective actions taken by the establishment operators.

Health Canada: Safe Food Handling Practices
The Government recognizes the importance of informing Canadians—especially those who are at higher risk—about safe food handling practices that will help them avoid foodborne illness.

In March 2010, Health Canada launched the three-year social marketing campaign, Safe Food Handling, aimed at those populations that are at greater risk of complications from foodborne illness (older adults, pregnant women and those with weakened immune systems). The campaign includes targeted national radio, magazine and web advertising to each of the at-risk groups, and interactive web tools to advise consumers about food safety practices that can be used both at home and at the grocery store. Other strategies include the distribution of booklets to seniors—via an Old Age Security statement mailing—and to pregnant women at point-of-purchase in Thyme Maternity stores.

Health Canada continues to collaborate with PHAC and the Council of Chief Medical Officers of Health to develop communication messages and consistent guidance for at-risk populations and their caregivers on how to minimize the risk of developing foodborne illness. For example, the guidance document, Prevention of Listeriosis: Considerations for the Development of Public Health Messages, was made available to the provinces and territories in July 2010 to provide advice on creating communication messages within each jurisdiction. This document offers basic information on foodborne listeriosis, and provides common sense prevention advice for the general public, for vulnerable populations, and for food-service providers serving food to these populations.

Public Health Agency of Canada: Risk Communications Strategy
PHAC collaborates with Health Canada to ensure that PHAC’s information for Canadians during a national outbreak is consistent with the food safety information that Health Canada provides.

In order to ensure that at-risk and vulnerable populations can access food-safety messages explaining the protective measures they can take during a national foodborne illness outbreak, PHAC continues to work with partners in the provinces and territories. As part of these efforts, PHAC has developed a Risk Communications Strategy aimed at the general public and at medically and functionally vulnerable groups such as older adults, pregnant women, those with weakened immune systems and those living in isolated communities. Should a national outbreak occur, the major elements of the plan could be implemented immediately as part of the response.

The Strategy uses a variety of traditional and innovative formats, such as media events, web- and audio-casts, the Food Safety Portal, and stakeholder briefings.

Activities under the Strategy include: tailoring food safety messages for at-risk populations; preparing plain-language fact sheets; preparing and promoting group-specific sections on the PHAC website; working with stakeholders so that communications will reach targeted audiences in the most effective way; and utilizing social media tools (Facebook, Twitter, etc.). Plans are under way to develop videos and interactive activities for the web aimed at journalists and the general public to increase knowledge of PHAC’s role in a national foodborne illness outbreak.

Enhancing Surveillance and Early Detection
The Independent Investigator found a need for improvements in surveillance and detection, both of Listeria monocytogenes in food, and of subsequent cases of foodborne illness. In response, the Government is strengthening national surveillance and early detection of foodborne illness through improvements to operational, laboratory and disease-reporting networks. These measures are key to ensuring better preparedness in cases of foodborne illness outbreak in the future.

Canadian Network for Public Health Intelligence
The Independent Investigator recommended that governments continue to use and support surveillance and monitoring systems such as the Canadian Network for Public Health Intelligence (CNPHI) – Public Health Alerts (formerly known as the Canadian Integrated Outbreak Surveillance Centre). The CNPHI is a secure web-based collective of applications designed to facilitate the nation-wide, integrated real-time collecting and processing of laboratory and epidemiological surveillance data, the dissemination of strategic intelligence, and the coordination of the public health response. F/P/T governments do in fact continue to use and support CNPHI, including via the PulseNet Canada outbreak response network (see below); furthermore, PHAC continues to maintain and support the Integrated Public Health Information System (iPHIS), a web-based case- and outbreak-management system that currently operates in select P/T jurisdictions across Canada.

At the Investigator’s suggestion, PHAC has begun to assess the Canada Health Infoway-funded Panorama system—a pan-Canadian health-surveillance software application—in order to determine its suitability for effectively managing multi-jurisdictional outbreaks of foodborne illnesses. The assessment is to include an investigation of the feasibility of integration with alerting systems such as CNPHI. In addition, PHAC is developing a strategy with respect to business intelligence tools and analytical capacity in order to take full advantage of current and future surveillance and monitoring systems.

National Enteric Surveillance Program (NESP)
PHAC has also made improvements to the national surveillance of listeriosis by adding Listeria monocytogenes to the National Enteric Surveillance Program (NESP), placing it among other enteric pathogens for which weekly surveillance is conducted. In addition, an Enhanced Listeriosis Surveillance Pilot Project has been established to collect timely case-based information on listeriosis cases. Under the Pilot Project, there is direct interaction between PHAC surveillance epidemiologists and the provincial epidemiologists to investigate all cases of invasive listeriosis. Also, Listeria strains are sent from provincial microbiology laboratories to the National Microbiology Laboratory for testing.

The resulting NESP data and case information from the pilot project can be integrated so as to aid in the detection of clusters of the Listeria pathogen, resulting in more timely public health responses to outbreaks of invasive human listeriosis.

PulseNet Canada
Progress has been made in the linking of public health laboratory networks through PulseNet Canada, an electronic laboratory network that serves as a primary data sharing and communications link for its partner-members—PHAC, CFIA, Health Canada and the provincial public health laboratories as represented by the Canadian Public Health Laboratory Network (CPHLN).

PulseNet Canada identifies clusters of foodborne pathogens, based on their DNA fingerprints, and allows fingerprints to be compared in real time so that outbreaks can be detected at the earliest possible stage, and so that foodborne illness from a common source can be identified. Laboratory information is now shared and jointly analyzed among all F/P/T partners on a daily basis, including information provided by the CFIA on contaminated food products that have already been distributed.

PHAC has led the standardization and ongoing certification of Listeria monocytogenes molecular subtyping (DNA fingerprinting) within PulseNet Canada. Since the 2008 listeriosis outbreak, the number of provincial and federal laboratories and laboratory staff that are certified by PulseNet Canada for work with Listeria monocytogenes has increased from nine staff in four laboratories, prior to the listeriosis outbreak, to twenty-seven staff in nine laboratories across Canada. CFIA, for example, has established a fully accredited and certified Pulsed-Field Gel Electrophoresis (PFGE) laboratory able to undertake DNA fingerprinting of foodborne pathogens such as Listeria. The CFIA activities include PFGE fingerprinting of pathogens recovered during the routine surveillance of food.

In order to further increase the number of PFGE-certified laboratories, PHAC is developing a training curriculum to teach the standardized DNA fingerprinting methodology, which will subsequently be delivered to federal and provincial laboratory staff. This initiative will include the distribution of materials, protocols and controls to PulseNet Canada member laboratories. The objective is to increase the number of locations and the numbers of staff trained and certified to use PulseNet Canada laboratory and informatics modules, and to increase information sharing with the CNPHI.

DNA fingerprinting techniques and access to epidemiological evidence have greatly improved Canada’s ability to detect contaminated food products and to identify in the laboratory a link between the consumption of such food products and cases of human disease. Participating clinical and food laboratories collect and share evidence (DNA fingerprints) of clusters of human disease linked to foodborne pathogens. PulseNet Canada now identifies and notifies health partners whenever two or more matching Listeria DNA fingerprints are detected within a period of 120 days.

In addition, work is being done by Health Canada, CFIA and PHAC to create an inventory of the capabilities of federal laboratories (for example, capacity, staffing levels, scientific expertise, available equipment/technologies) and to identify what partnerships have been established to increase the capacity for rapid detection of and response to potential foodborne illness outbreaks.

A Network of Networks
Further to the recommendation of the Independent Investigator, an Interdepartmental Federal Committee with members from CFIA, Health Canada, PHAC, Environment Canada, the Department of Fisheries and Oceans and Agriculture and Agri-Food Canada drafted a project plan that outlined the requirements to establish a national integrated laboratory network—a network of networks.

The formal process of establishment was launched at the inaugural workshop, held March 22-24, 2011 in Toronto. Prospective network members (representatives from various sectors of the federal, provincial, industry and academic laboratory communities across Canada) met with CFIA, PHAC and international experts to identify common interests, explore current laboratory capacity, and discuss how networking of food/animal health/public health laboratories can build capability for the future.

The establishment of a fully integrated Canadian laboratory network is a complex enterprise that will require time and resources to complete. The March 2011 workshop marked the beginning of a process that will result in enhanced laboratory testing capacity, investigative support and surge capacity for faster emergency response in the future.

Novel Detection Technologies
Genomics
During the 2008 listeriosis outbreak, PHAC implemented novel laboratory technologies, notably whole-genome sequencing, to obtain definitive characterizations of the outbreak-associated Listeria strains. Genomics began as a research tool, but technological advances have made it feasible and suitable for use during public-health investigations of bacterial diseases. Evidence provided by whole-genome sequencing in determining the cause and scope of human illness is all but indisputable. PHAC is now able to perform whole-genome sequencing for outbreak-associated Listeria strains that have caused disease across Canada in the past two decades.

PHAC is acknowledged as an international innovator with respect to the use of genomics in the pursuit of public health applications, based on its activity during the 2008 listeriosis outbreak and during the 2010 – 2011 cholera outbreak in Haiti. PHAC continues to collaborate with provincial and federal partners to implement public-health-ready versions of this emerging laboratory technology.

PHAC and Health Canada are conducting joint studies that use the latest generation of nucleic-acid-based technologies and employ a diverse set of Listeria isolates associated with significant public health events in the past. The purpose of these studies is to investigate the distribution and characteristics of Listeria populations that have been associated with outbreaks of human disease. The studies will examine the ecology of the organism to better understand how it survives, why detection is challenging, and how monitoring can be improved.

Other methodologies
Health Canada continues to develop improved detection methods for Listeria monocytogenes and other hazards in food that reduce testing time and enable more rapid response during food safety investigations. An enhanced method for the isolation of Listeria has been developed that makes results available in 3 to 5 days instead of the former 7 to 10 days. It is currently being validated for different food commodities and categories by Health Canada and CFIA. Once the validated method is published in the Microbiological Methods Committee's Compendium of Analytical Methods, industry and other stakeholders will be notified.

In addition, Health Canada has updated its list of recommended Listeria testing methods. These methods were made available in the Compendium of Analytical Methods on Health Canada’s website in April 2011, at the same time that the revised Listeria policy came into effect.

Health Canada is also collaborating with the National Research Council (NRC) in a multi-year project to develop a microchip-based laboratory method for Listeria that would provide results within 48 hours.

Health Canada continues to operate the Listeriosis Reference Service for Canada, with objectives that include the examination of suspect foods and clinical specimens submitted for analysis, and the maintenance of reference cultures of Listeria monocytogenes. The Listeriosis Reference Service holds all strains and characterization data indefinitely, which facilitates the comparison of various strains. The Foodborne Illness Outbreak Response Protocol (FIORP (2010)) includes an appendix on the Listeriosis Reference Service that describes the purpose of the Service and the procedures to follow when foodborne listeriosis is suspected.

Improving Emergency Response
Surge Capacity
The Independent Investigator observed that most organizations involved in the response to the 2008 outbreak had limited pre-planned capacity for managing a surge in the demand for expertise and laboratory testing.

Federal surge capacity is being provided through training, laboratory certification and partnership among PHAC, Health Canada and CFIA. PHAC has also cross-trained staff among its program areas to provide surge capacity to PulseNet Canada technical staff when needed. While PHAC provides personnel and capital resources to provinces and territories, including the sharing of full-time staff and laboratory and informatics equipment as required, more resources are required in order to better prepare for and respond to the needs of some P/T jurisdictions for extra capacity during a foodborne illness outbreak.

Public Health Reserve (PHR)
To respond to these needs, PHAC is developing a pilot model for the establishment of a Public Health Reserve to bolster capacity during food-borne illness outbreaks and other public health events. A Secretariat office has been established to coordinate the project and processes and PHAC has identified a roster of internal human resources who could support response activities. An inventory of skill sets required for outbreak detection/response was developed and validated, and a gap analysis undertaken. The results informed the scoping of the PHR pilot concept, and the development of a training strategy. A framework has been established in consultation with internal and external public health experts, and internal partners engaged to support strategic development and implementation.

A potential administrative and training model for the PHR pilot will be tested over the next ten months through various training and exercise events. Recruitment of reservists representing a variety of employer/skill backgrounds is already under way. A web-based tool to support the reservists is being developed. The pilot will be assessed in 2012, and the data will be used to inform the development of the ongoing PHR framework.

Outbreak Coordination and Communication
At the time of the 2008 listeriosis outbreak, the Foodborne Illness Outbreak Response Protocol (FIORP) was in place to guide the response to outbreaks of foodborne illness. However, the Weatherill Report discovered that, though the protocol was seen as valuable, it was not well understood by signatories, and had not been recently revised. Following extensive PHAC-led consultations with F/P/T partners regarding public-communications operating procedures during a national outbreak, an improved version of the protocol, the FIORP (2010), was produced. It was subsequently endorsed by F/P/T Deputy Ministers of Health and Agriculture and finalized in June 2010.

Foodborne Illness Outbreak Response Protocol
According to the FIORP (2010), PHAC is charged with centrally coordinating the investigation of and response to any foodborne illness outbreak involving more than one province/territory or country, as well as multiple agencies at all levels of government. It also establishes PHAC as the usual first point of contact for partners wishing to notify the federal government of issues related to foodborne illness outbreaks, or requesting content expertise/support.

While PHAC assumes the lead coordination role, responsibility for the outbreak investigation is spread across a number of separate agencies according to mandate. For example, within the Government of Canada, CFIA leads the food safety investigation, PHAC leads the epidemiological investigation, and Health Canada leads the health-risk assessment process that guides risk-management decisions. Each partner participating in an outbreak investigation retains its legal responsibilities for actions and activities consistent with its mandate.

PHAC conducted bilateral exercises of the FIORP (2010) with each province and territory from January to April 2011, in order to test the FIORP and to support related knowledge development. PHAC now plans to convene a national multi-lateral exercise in 2011. These exercises include testing for communication gaps, assisting with knowledge development, and strengthening networks among communication partners.

A key element of the FIORP (2010) is the inclusion of provisions for the sharing of information, including epidemiological data, as needed to identify the foodborne illness outbreak, taking into account privacy and confidentiality issues. As well, the communications section includes clearer language and guidance for improved coordination of public communications among F/P/T partners. There is also an appendix that discusses communicating with the public and with those at greater risk.

Post-outbreak Review
The FIORP (2010) also provides an enhanced description and a template for guidance of the post-outbreak review process. The process includes confirmation of the outbreak’s cause, proposed measures to prevent reoccurrence, assessment of the effectiveness of outbreak-control measures and evaluation of utilized processes and methods. The results of post-event reviews will be used to evaluate the FIORP and make required changes.

Three post-event reviews have been conducted using the process established in the FIORP since it was finalized in June 2010.

Food Safety Communications Protocol
Having recognized the need to establish guidelines for improving communication with Canadians during an outbreak of foodborne illness, PHAC worked with Health Canada and CFIA to produce the Food Safety Communications Protocol, which was finalized in January 2010. The protocol clarifies the roles and responsibilities for joint communications on food safety issues that involve the three federal departments and is based on risk communications principles that are consistent with the Health Canada/PHAC Health Portfolio Risk Communications Framework.

According to the protocol, PHAC assumes the lead (non-ministerial) role in communicating with the public during national foodborne illness emergencies. PHAC works with partners in the provinces and territories, outlining roles and responsibilities, and providing guidance on a range of communications activities that will ensure that food safety messages are communicated to at-risk populations during a national foodborne illness outbreak.

The Communications Protocol includes an appendix named “Foodborne Incident Federal Risk Management Scenarios”. This documentdescribes a range of scenarios that may arise during a food contamination event or a foodborne illness outbreak. In this context, it guides federal action among CFIA, Health Canada and PHAC, and provides guidance on communication to the public for each situation.

In November 2010 and February 2011, PHAC, Health Canada, and CFIA piloted a tabletop exercise and training program to test understanding of the Communications Protocol. These exercises were designed to raise awareness of the Protocol, discuss how to implement the protocol, and build communications surge capacity to respond effectively to food safety issues and emergencies within the three organizations.

Foodborne Illness Emergency Response Plan
Multi-jurisdictional foodborne illness outbreaks are guided by the FIORP (2010), as established in consultation with the provinces and territories. However, for the rare instances when a foodborne illness outbreak requires a response beyond the scope of the FIORP, PHAC, in collaboration with Health Canada, has led the development of a Foodborne Illness Emergency Response Plan (FI ERP), which is an appendix in support of the federal Health Portfolio Emergency Response Plan (HP ERP). The FI ERP designates PHAC as the lead responding agency at both the national and federal level and makes use of a common incident command structure.

The FI ERP was endorsed by the Health Portfolio Joint Emergency Preparedness Committee in June 2011. The HP ERP and its appendices support the Government of Canada's all-hazards Federal Emergency Response Plan. Exercises for testing and validation of the FI ERP will take place in 2011.

The FI ERP Incident Management System (IMS) structure is based on the current IMS of the Health Portfolio Emergency Operations Centre (HPEOC). It has been customized to show how Health Portfolio resources will be organized in the HPEOC to support the response to a foodborne illness emergency.

The IMS includes links to the FIORP Outbreak Investigation Coordinating Committee, which coordinates F/P/T activities directly related to outbreak response while describing how the Health Portfolio would support that response in an emergency. The IMS also includes a high-level link between a representative P/T group and the Health Portfolio Executive Group in order to facilitate high-level F/P/T decision-making during a foodborne illness emergency. IMS Liaison Officers will ensure appropriate communication with the regional offices, CFIA, and other government departments.

Governance
The Weatherill Report observed that management of the listeriosis outbreak represented a significant challenge to the multiple jurisdictions (federal, provincial and municipal) and the various sectors of the federal government that were involved.

The Government has taken steps to improve governance of foodborne emergency events by clarifying accountability and ensuring coordination of action among all responsible federal partners.

In July 2009, the Clerk of the Privy Council asked the AAFC Deputy Minister to chair a special committee of Deputy Heads from CFIA, Health Canada and PHAC that would recommend improvements in the ways their organizations work together to deliver their food safety mandates. This committee has been meeting regularly and is being supported by Assistant Deputy Minister (ADM)- and Director-General (DG)-level committees as well as a full-time secretariat at AAFC. A six-month report was provided to the Clerk in March 2010, and two interim reports detailing progress on food safety can be accessed from the Food Safety Portal.

CFIA, Health Canada, and PHAC have established internal governance mechanisms to streamline information sharing and provide a more cohesive and forward-looking approach to food safety. The Government has also taken steps to heighten awareness of the legislative authority vested in the federal Minister of Health by Parliament to protect Canadians during a national foodborne emergency.

Appointment of new officers (PHAC and CFIA)
PHAC is working to increase its capacity for flexible and timely responses to public health threats. In order to support the Chief Public Health Officer in his role as the lead public health professional in Canada, an Executive Vice-President/Chief Operating Officer (Associate Deputy Minister) was appointed in September 2009. The responsibilities associated with the new position include: providing leadership on all matters related to central agencies; leading and assuring high quality PHAC planning, execution, reporting and accountability; and assuring that PHAC has robust emergency preparedness and response capability. The Chief Public Health Officer also announced the creation of a new Assistant Deputy Minister’s position with duties including managing the Centre for Emergency Preparedness and Response. The position was filled in May 2010.

CFIA has completed a review of its organizational structure and decision-making processes, and has made improvements to its governance structure. On May 25, 2010, the Prime Minister appointed a Chief Food Safety Officer for Canada and a new Executive Vice-President of CFIA.

Office of Food Safety and Recall (OFSR)
In June 2010, CFIA completed a review of governance with respect to the Office of Food Safety and Recall (OFSR), which is the primary point of contact with Health Canada during a food safety investigation. The report recommended measures to strengthen and clarify accountabilities with respect to the OFSR; these measures are currently being implemented. The Chief Food Safety Officer now chairs a senior-level recall committee to oversee critical food safety events. The Office of the President is fully engaged in emerging food safety issues through daily status briefings by the Vice-President of Operations, to whom the OFSR now reports directly.

During a national emergency, all necessary CFIA resources are dedicated to managing the emergency response. As specified by CFIA’s Incident Command Structure, during a national foodborne emergency, the Agency’s Incident Commander is the primary point of contact with CFIA’s federal partners, including Health Canada and PHAC, as well as its P/T partners.

A note on Incident Command Structure

Incident Command Structure (ICS) is an international model for the command, control, and coordination of emergency response. It combines facilities, equipment, personnel, procedures and communications operating within a common organizational structure.

Expert Advisory Committee
Further to the advice of the Independent Investigator, CFIA has established an expert advisory committee to provide the Agency with objective and technical advice on key issues related to the evolution of its three core business lines, which are food safety, animal health and plant health. The first meeting took place in June 2011.

Ministerial Advisory Board
The Minister of Agriculture and Agri-Food has established a Ministerial Advisory Board of seven highly-qualified advisors from the food, animal and plant-health sectors to advise the Minister on issues that are relevant to CFIA activities, as is consistent with the Minister’s responsibility for the Agency’s overall direction.

Federal/Provincial/Territorial Collaboration
F/P/T Health Ministers have agreed that food safety constitutes a priority area for the health sector, and that collaboration is needed with the agriculture sector in order to have a more integrated Canadian food-safety system. They have asked their officials to review and improve the current food-safety governance structure within the health ministries, to assist health officials to work together as well as with their agriculture counterparts, in order to enhance the food safety system.

F/P/T agriculture ministries have been working to advance three food safety ministerial priorities that will make important contributions to meeting the challenges faced by consumers and producers in Canada. These priorities include: the development of a national meat hygiene standard to facilitate inter-provincial trade; a systematic pathogen reduction strategy for meat and poultry; and better linkages among food safety and human health surveillance information sources to improve targeted interventions and manage foodborne illness outbreaks more effectively.

Conclusion
As this report demonstrates, the Government of Canada has made considerable progress in addressing the recommendations of the Independent Investigator. The commitment of $75 million announced by the Government in September of 2009 attests to an intention to move quickly on these recommendations. Budget 2010 committed to CFIA an additional $13 million annually for two years to fund increased inspection capacity for meat and poultry processing facilities. Budget 2011 provides the CFIA with $100 million over five years to invest in inspector training, tools and technology, and science capacity. These investments build on the Government’s 2008 commitment to invest $489.5 million over five years in the Food and Consumer Safety Action Plan.

In response to the Independent Investigator’s call to simplify and modernize federal food-safety-related legislation and regulations, the Government of Canada has affirmed its commitment to enhancing the legislative and regulatory basis for food safety. Legislative options to simplify and modernize federal food-safety-related legislation and regulations have been analyzed and developed jointly by Health Canada and CFIA.

It is expected that a final report on the implementation of Ms. Weatherill’s recommendations will be shared with Canadians in fall 2011, together with an assessment of its impact on improving Canada’s food inspection and food safety emergency response systems. Canadians can expect that much will have been achieved in meeting the recommendations of the Independent Investigator.

The Government recognizes, however, that there is always more work to be done. The food safety system is complex and requires collaboration among government partners, industry and consumers. Collective effort and sustained action are necessary to reduce the constantly changing risks that foodborne illnesses pose to Canadians. Strengthening the food safety system is a continuous process to which the Government of Canada is fundamentally committed.