The meat recall now underway, the largest in Canadian history, has put not only E. coli bacteria under the microscope but the meat inspection system as well.
So far, there are 11 confirmed cases linked to tainted meat that came from the XL Foods plant in Brooks, Alta., and many Canadians wonder whether the system is broken and, if so, how to fix it.
It's a complicated system. XL Foods has recalled meat that was produced on five different days – Aug. 24, 27, 28, 29 and Sept. 5 – due to E. coli O157:H7.
If those were average days on the cutting floor, the recalled meat would have come from about 20,000 cattle. The meat was immediately sent to stores across Canada and a significant proportion was exported to more than 20 countries, including Japan, Hong Kong and the U.S.
In fact, it was the U.S. Food Safety Inspection Service that first confirmed a positive for O157:H7 in boneless beef trim on Sept. 3, after routine testing, and alerted the Canadian Food Inspection Agency.
The CFIA says it was notified on Sept. 4, the same day their own testing confirmed a positive in beef trim from XL Foods.
While some of the tainted beef was stopped at the border, the U.S. inspection service now estimates that about 1.134 million kilograms of potentially tainted beef was received by U.S. firms.
The positive tests led to more testing and investigation but it wasn't until Sept. 16 that XL Foods issued its first recall. More positive tests, and more illnesses linked to the meat would follow, and on Sept. 27, the CFIA temporarily suspended XL's licence to operate the Brooks plant.
"The number one responsibility for food safety is with the producer," not the government, University of Calgary veterinary medicine professor Bonnie Buntain told CBC News.
As she explains, at a meat plant there are really two systems of food safety: the plant's own system and the government's, which inspects what the plant is doing.
Buntain was previously the chief public health veterinarian at the U.S. Food Safety Inspection Service and she says that in both the American and Canadian inspection systems, both government and industry veterinarians look at animals before slaughter for signs of disease. That is the top priority to ensure healthy meat.
After slaughter, both company and government inspectors will look at the carcass and parts, including lymph nodes and internal organs for any other signs of disease as well as for quality issues.
The removal of the hide and the evisceration of the animal are critical points for E. coli infection. If something goes wrong during the cutting process, like the innards getting sliced, contaminating the carcass, that meat should be pulled from the line.
The second line of defence
A big part of meat inspection, however, is not just monitoring the line but the testing and data analysis, a second line of defence.
Since it takes days to get test results – the XL plant would typically take about 300 samples per day – a good record tracking system is critical. That is the company's responsibility, not the government's, Buntain said.
If a problem is detected in the testing, for example, the plant is supposed to pull or recall the lot that was on the line before and after the problem, along with the lot that had a positive test. In the business, that's known as bracketing.
CFIA officials have now said that this area is one where the XL Foods plant had shortcomings.
"Sampling protocols were not always followed by plant staff, which could have resulted in some inaccurate test results," and "trend analysis of the data collected was not being properly conducted," according to the CFIA's timeline of their investigation.
After its review, the CFIA also said that, because of the plant's faulty trend analysis, XL was not taking "the corrective measures that you normally would expect" when it found a higher than normal number of positive test results for E. coli O157:H7.
Week-long closing 'troubling'
Alex Stanoprud worked as a government meat inspector even before the CFIA was created in 1997, amalgamating the inspection services of three federal ministries, and he told CBC News that the week-long closing of XL Foods is a very serious matter.
He was a senior inspection manager in Quebec when he retired in 2006 but is still involved with the meat industry in a consulting role.
"All the bells and whistles have been put in place" to ensure food safety, he told CBC News.
But he still finds it "troubling" that the XL Foods plant has been closed for so long and with so many deficiencies identified. "What was wrong with inspection before, were they sleeping?" he asks.
Still, Stanoprud is more concerned about meat plants that come under provincial inspection. (Unlike the CFIA, which is only responsible for the plants that ship food interprovincially or for export.)
Federally inspected plants can guarantee their product for 90 days, something the chain stores demand. Meat product from local, provincially inspected operations can get onto the plate or into the freezer quickly. But if it had to last 90 days, he says, "it would walk away on its own."
He also said that in the few huge plants like XL "the speed of slaughter is a problem." It takes workers only about 40 minutes to perform all the steps before the carcass goes into the chiller.
Stanoprud says you cannot test your way to safe food so for him the critical component is a system called HACPP, which stands for Hazard Analysis Critical Control Points.
The system originated with the NASA space program in the 1960s, which had hired Pillsbury to prepare food for astronauts to take into space, and it is now mandatory for the meat industry in Canada and the U.S.
HACCP is essentially a food safety plan that identifies the hazardous steps in food processing, how to deal with them and how to take corrective action. The company is then responsible for performing everything in the plan and following all the regulatory requirements.
"The program is fantastic but someone has to audit this" and make sure companies follow the procedures on a regular basis, Stanoprud says.
When it comes to the audit, Stanoprud thinks it should be done by a totally independent group of inspectors, out of concern that the company and its regular inspectors "become a close-knit group."
He favours a team from outside the region going in for one to two weeks to do an audit to "get a portrait of what is going on and how to improve."
Are more inspectors needed?
Neither Stanoprud nor Buntain think the solution is simply hiring more inspectors.
"You cannot inspect or test your way to food safety. More inspectors do not equal safer food, period," Buntain says, adding that a HACCP system that's based on prevention will make a bigger difference.
She wants industry doing the bulk of the inspection on the line, freeing up government inspectors to monitor the data HAACP generates.
"Canada doesn't realize how much they're paying to make these companies rich," Buntain says.
"Right now, Canada and the U.S. spend more time doing things that industry should be doing and less time analyzing the whole system and making sure they are constantly in a control situation so that they're preventing problems, instead of reacting."
That is beginning to change, in both countries, she says, pointing to the Safe Food bill before Parliament as well as the CFIA's inspection modernization program currently underway.
A carrot-and-stick approach
Buntain argues that the current system should have more flexibility, rather than the current cookie-cutter approach in which the same regulations apply to both large and small plants.
Buntain is on the expert advisory committee for the CFIA. The agency sent her to Australia, New Zealand and home to the U.S. to look at their inspection modernization practices.
She favors more of a classic carrot-and-stick approach, like what she saw in Australia and New Zealand, in which there are three levels of oversight. Plants with a history of problems or food safety issues receive enhanced inspection.
The next level is normal inspection and then reduced inspection in plants that "don't have a history of regulatory violations, do constant testing, trend analysis, can show records, have tracking that can show where everything goes and are able to recall product immediately, should there be a presumptive problem," Buntain says.
In that system, the industry, not the government, pays for government inspection and all test results go into a government database.
The enhanced system is obviously more expensive, so there's strong motivation for a company to avoid that level of extra cost.
Along with the reduced inspection levels, the regulations give companies more flexibility in how they carry out their safety plans, another carrot.
XL Foods an extraordinary case
Food safety expert Sylvain Charlebois, the acting dean at the University of Guelph's college of management and economics, also says that Canada does a good job when it comes to food safety, which makes the XL Foods situation unusual.
He told CBC News this is the first time he has seen a federal agency responsible for food safety "openly criticize, to a certain degree, a private company."
"I cannot think of another situation where the CFIA was actually saying to the media, a company didn't do its job all that well, it didn't respond to their requests thoroughly," he said.
Charlebois prepares a detailed world ranking on food safety performance, with editions published in 2008 and 2010.
In the 2010 edition, Canada and the U.S. were tied for 4th, following Denmark, Australia and the U.K. New Zealand was not one of the 17 countries ranked.
Where Denmark stood out, especially in relation to Canada, was in its ability to track food products. "You cannot make the proper decision unless you have access to the information in real time," or close to it, Charlebois says.
Charlebois also points to what he considers a shortcoming of the current system, one that won't be rectified under the proposed legislation. He said the CFIA should no longer report to the minister of agriculture, arguing that puts the minister "in an awkward position.
"He has to protect industry and at same time think about safety of consumers and it's difficult to do both," Charlebois argues.
He would like to see the CFIA and Agriculture Canada decoupled, noting that the equivalent agency in the U.K. reports directly to parliament.