On October 15, I sent a letter to USDA's Under Secretary for Food Safety Elisabeth Hagen and the Administrator of USDA's Food Safety and Inspection Service requesting that I accompany the USDA food safety audit team that is scheduled to visit Canada starting next week as it reviews the Canadian food safety inspection system for meat, poultry and egg products destined for export to the U.S.
This is the first check USDA has conducted in over three years and it comes in the middle of the Canada's biggest meat recall in history, so this portends to be a big deal.
I have worked on food safety issues for over 12 years -- first as a lobbyist for the consumer advocacy organization Public Citizen and since November 2005 for the public interest group Food & Water Watch. Most of my work has been focused on meat and poultry inspection issues. I have taken a particular interest in the safety of imported food and the measures our food safety agencies in the U.S. take to ensure that those products are safety for U.S. consumers.
In the late 1990s, USDA established a fairly elaborate process to evaluate the food safety systems of countries that wish to export their meat and poultry products to the U.S. USDA must first determine whether the exporting country's food safety system is "equivalent" that of the U.S. That means that it does not have to be identical, but the exporting country's food safety system must provide the same level of protection to consumers as the U.S. system. It can take years for USDA approval before a country can begin exporting its meat and poultry products to the U.S. At the present time, there are 34 countries that have been deemed to have equivalent food safety systems and are eligible to export their meat and/or poultry and/or egg products to the U.S.
Once a country is permitted to export their products to America, the exporting country certifies meat and/or poultry plants that can meet USDA food safety requirements. According to USDA, those foreign plants must maintain the same standards that are applied to domestic plants. For example, the plants must receive continuous inspection by the government food safety authority; the plants must maintain standard sanitary operating procedures and food safety plans that they follow; the plants must test for generic E. coli; and the plants operate under sanitary conditions.
USDA conducts verification audits in the exporting country to determine whether it is still meeting USDA food safety requirements and visits a representative sample of plants that are exporting to the U.S. to determine whether the country's food safety authority is enforcing U.S. food safety standards. Up until recently, those audits were conducted on an annual basis. The fact that Canada has not had an audit visit in over three years immediately sent red flags up for me. It was another example of how Canada has received special treatment from USDA over the years that I believe can jeopardize the health and safety of U.S. consumers.
While I described above the elaborate review process set in place in the 1990s for countries wishing to export their meat or poultry products to the U.S., Canada was never subjected to that rigorous review because it was one of several countries that were "grandfathered" in under the new system since the U.S. had already had a long-standing meat and poultry trade relationship with those countries. USDA, however, has conducted verification audits of Canada and it has consistently found examples of the Canadian Food Inspection Authority not enforcing U.S. food safety standards. In fact, the independent USDA Office of Inspector General conducted a special study in 2005 of how USDA enforced the equivalency requirements for Canada and it reported the following:
"In July 2003, as part of an onsite review, FSIS identified serious concerns with the Canadian inspection system. These concerns included the insufficient implementation of sanitation controls and HACCP requirements by establishments and the lack of enforcement in these areas by Canadian inspection officials.
Based on these concerns, FSIS proposed an enforcement review in 2004. (Enforcement reviews can lead to a determination that a country's system is not equivalent to U.S. standards and, thus, not eligible to export to the United States). The proposed 2004 enforcement review was not conducted and FSIS officials did not reassess Canada's implementation and enforcement of sanitation controls and HAACP requirements until almost two years later. When FSIS officials finally returned to Canada in May 2005, they continued to find the same types of deficiencies they had found in 2003.
FSIS' analysis of the regulations governing the Canadian inspection system identified two areas, which may not be equivalent to the United States inspection system. FSIS found that Canadian policy allowed less than daily inspection coverage in processing establishments. By contrast, FSIS has a long established history of requiring the presence of an inspector in a U.S. processing establishment at least once per shift per day. FSIS also identified differences in the testing performed for Listeria monocytogenes. Canadian inspection officials require establishments to perform risk-based environmental sampling, as opposed to the finished product sampling required by FSIS."
Have the issues been resolved? Not if one reads the findings of the 2009 USDA audit report of the Canadian food safety system. Here is what the USDA auditors found:
"The inability of inspection personnel to implement consistent sanitation and HACCP verification procedures, and more significantly, the lack/loss of consistent supervisory reviews to identify weaknesses in inspection personnel performance when it occurred. Many of the deficiencies encountered were repetitive, both from a historical perspective and within the context of the current audit."
With that as an historical backdrop and with the massive XL Foods recalls still on everyone's minds, what are the Canadian and U.S. governments proposing? Deregulation of the border inspection system. This is the same border inspection system that first caught the E. coli contamination problems at the XL plant. Food safety is not an area that should be deregulated. History dictates that we should strengthen and not weaken the food safety inspection system.
Maybe I am missing the logic of what the Canadian and U.S. governments are trying to accomplish. U.S. taxpayers are sending $16 million annually to USDA to ensure the safety of the imported meat and poultry we consume. Trade should not trump food safety. I want to go on that audit tour to make sure that is not what is happening.