Earlier this year, I posted an article on upcoming food safety legislation stemming from the Food Safety Modernization Act (FSMA) and Safe Food for Canadians Act (SFCA).
As part of the Healthy and Safe Food Regulatory Forum, the Canadian Food Inspection Agency has now released an overview of the proposed Safe Food for Canadians regulations. More details are emerging on the proposed timelines for implementation of the new facility licensing and HACCP-based Preventive Control Plan (PCP) requirements for businesses that import food and/or prepare food for inter-provincial and international trade. Final regulations are expected to be published in the Canada Gazette, Part II in June 2015. Apart from a few exemptions, regulations will apply to the food sector at large subjecting all importers and manufacturers to a higher food safety standard. The new federal legislation will come into force in three phases starting with high-risk foods. This product category is manufactured by food establishments that are already federally-registered. These businesses are expected to comply by June 2015. The legislation will then apply to the fresh fruit and vegetable industry with licensing coming into force in June 2015 and PCP a year later. As for the currently non-registered food sector, it will be given until June 2016 to comply with licensing requirements and until June 2017 for all risk-based food safety controls to be put in place.
The Canadian Food Inspection Agency states that the SFCA “will be an important step in aligning Canada’s food safety system with our trading partners’.” The US, Canada’s largest trading partner, is no stranger to food facility registration requirements since the passing of the 2002 Bioterrorism Act. American food producers, manufacturers and distributors are now awaiting the publication of their own food safety rules under FSMA.
According to experts, some industry standards such as the Global Food Safety Initiative (GFSI) benchmarked standards approximate or even exceed the regulatory requirements of FSMA. In 2013, the SQF Institute contracted the services of Leavitt Partners Global Food Safety to compare the elements of the SQF Level 2 to the FSMA requirements — specifically the Preventive Controls Rule — and concluded that a SQF level 2 certification was “a very strong start to being in compliance with the new requirements of the proposed Preventive Controls rule.” A year earlier, Dr. Susan Moyers published an article in Food Quality and Safety encouraging food companies to consider the standards or “schemes” of the Global Food Safety Initiative (GFSI) while awaiting the FSMA rules. GSFI, a non-profit and business-driven organisation, was originally created in 2000 under Belgian law and is currently administered by the Consumer Goods Forum headquartered in Paris, France. Its mission is to “provide continuous improvement in food safety management systems to ensure confidence in the delivery of safe food to consumers worldwide.” Moyers states that GFSI food safety standards are higher than regulatory requirements in developed countries. In an attempt to gauge the preliminary impact of GFSI on food safety and to provide a “baseline for future analysis of trends,” Moyers researched food recalls in the US over a one-year period (2011-2012) and reported that less than one quarter of food businesses who had experienced a food safety recall were GFSI-certified. While the impact of GFSI implementation has yet to be further examined, she argues that the recall statistic should go down if strict auditing standards are maintained and more food companies achieve GFSI certification.
Regulatory requirements pertaining to food safety are becoming more stringent, but the industry has shown itself ready for change. The advantages of an SQFI certification are well understood by the food industry, regardless of business size. According to an article by Tom Boyd (Food Processing, January 2014), mid-sized private label manufacturers implement GFSI to remain competitive and become attractive to retailers. Their sophisticated food safety and quality management systems are on par with those of large organisations, he argues. I have to agree with this observation. Back in the late nineties, I started my career working for a private label bakery in Western Canada. At the time, the family business didn’t have documented pre-requisite programs or GMP. Fifteen years later, the bakery has expanded and is certified to British Retail Consortium (BRC) standards.
Governments in Canada and the US are aligning their food safety legislation with current industry standards. In Canada, the low-risk food sector involved in inter-provincial and international trade has over two and a half years to comply with the new requirements. GFSI standards and certification are proof that the food industry and its partners will continue to rise to the challenge in order to provide safe quality food and retain consumer confidence.