Download - Alan Grant- Food and Beverage Ontario- Member Feedback on the Safe Food for Canadian Act

Member Feedback onSafe Food For Canadians Act

Who We Are

• Not for profit industry association• Represents food and beverage processors

GOAL:To promote and support a competitive Ontario industry locally and within the global marketplace

Common Member Key Issues

• Regulations• Branding Ontario product• Funding opportunities• Labour• Education• Quality & food safety

Board Members

Safe Food For Canadians Act Major changes to the proposed regs

Major changes in the proposed regulations:• Licensing requirement• Preventative Control Plans (PCP’s)• Risk analysis• Traceability

Safe Food For Canada Act FBO Member Feedback

Member concerns:• Licensing• Cost to business• Import harmonization• Written PCP exemptions• Implementation timeline• Compliance promotion• Inspection activities


Licensing:• How will the process work• What events will require updates to a license• A large but unknown number of businesses will now

require federal inspection & license


2. Cost to business• Actual business cost is unknown variable• Every business evaluation will be unique • Where to go for funding assistance• Could the cost to business be tax deductible

Safe Food For Canadians Act FBO Member Feedback

3. Import harmonization• Importers will require a license & written PCP• Consideration for 3rd party verification of int’l

manufacturers


4. Written PCP exemptions• Consider raising the exemption ceiling higher than the

current proposal of $30K• Eg consider harmonizing with USA on exemptions for

equivalent standards for similar sized businesses• Eg not only annual sales but employees numbers


5. Implementation timeline• Timeline based on 3 groups:

1. Current federal plants2. Fruits & veg3. Current non-federal plants

• Propose to allow more time and consideration for #3 to comply to all facets of the regs (2017 +)

• Break #3 into subgroups to extend timeline


6. Compliance promotion:• Improvements to website• On-line tools could be more interactive• Transparency in sharing rationale on decisions • Industry access to COE and other expertise• Consideration for new website hosted by CFIA & Health Canada

dedicated to industry needs• Aggregating data on decisions to assist industry in improving gener • Track –share-leverage outcomes for educational uses• Timely communications on precedent-setting decisions• Guidance documents in plain language


7. Inspection activities:• Consistency & transparency• Interactive mechanisms in place for consulting on CFIA

decision making (eg industry access to COE)• Practices & challenges associated with inspector

training on various processes• Office of Complaints & Appeals – how will this work?• Recalls: more communication on decision making and

lessons learned, post recall assessments