The risk is categorised as Class I (an immediate and acute risk to human health), Class II (moderate risk) or Class III (low and no risk).
“We have to demonstrate why we are doing it because we do recognise that although we are there to protect the consumer we also are dealing with the livelihood of businesses,” said Dr Aline Dimitri, the deputy chief food safety officer of Canada.
“So we can’t just frivolously go out and say ‘I don’t have all appropriate levels of evidence, I am still going to do a recall’.
“In some cases we may choose to do that because the epidemiological data, particularly when we have massive outbreaks, we may decide to take more risk around the amount of evidence we need for the first step but that decision is not taken lightly.”
Regulation change to help track importers
Dr Dimitri said the real change has been the complexity of information in the pathways of product transfer.
“Being able to understand where the importers are, our current legislation makes it challenging for us to track all the importers, so we are moving to new legislation where we are going to be licensing importers and that will help us in our investigation,” she said.
“We find that in the import/export space there is a lot of small businesses that come in and out of business and it becomes challenging to track. We’re working more closely with competent authorities from other countries to exchange information as they recognise that it is not because a product is produced in Canada that it is to stay in Canada.”
Dr Dimitri advised industry to maintain good record-keeping to make it easier to track and trace, keep testing up to date to make sure results can be shared and be part of investigations and validations.
The CFIA has a team dedicated to food recalls and statisticians to support them in designing sampling and testing to give confidence in the approach.
“We have different layers of the balancing act. One is how many products do we look at and usually it depends on the epidemiology,” said Dr Dimitri.
“What does the epidemiology tell us, once we have that we go and collect samples and if we find there is an issue we make sure we have enough samples and a proper design of the sampling and testing that can support evidence.
“Once we have that evidence we hand it over to Health Canada and their job is to ascertain the direct risk to human health. Based on [the risk] we have different communication processes around the intensity of the communication.”
The process can be complex: highlighted by a recent E. coli O121 outbreak which involved more than 15 recalls of different flour products.
“For the last almost two decades I have been in this organisation we constantly have the conversation around how do we simplify these multiple recalls from one product and the reality is because it poses a health risk, because people are getting sick, we feel that we have to communicate even if it is multiple times,” said Dr Dimitri.
“The challenge with E. coli in flour was the surprise that the general Canadian had with the fact that flour is a raw product. It was really symptomatic of how consumers are not well versed in the food safety system.
“The challenge is that people never conceived of flour as a raw product, it is not cooked or baked and there might be bacteria in it. A lot of our recalls weren’t for products that were intended to be baked.
“At the core of it, it was because people were eating cookie dough potentially raw or people will take off their cake and put it on top of a layer of flour so it doesn’t stick on anything or putting flour in play-doh for children.”
Using technology and using third parties
Dr Dimitri said whole genome sequencing is taking on a bigger space over time.
“Internationally it is becoming an important tool and Canada is looking at how better to use that tool and to better integrate decisions based on the data we extract,” she said.
“Whole genome sequencing is an intensive process, not so much in reading the genomic piece but in doing the analysis of the data and making decisions based on that.
“We are regulatory agencies so when we make decisions we have to ensure the evidence we have is out of technologies that have been validated. We are going through the process of integrating WGS in our laboratory processes but also our decision making process in terms of what data comes out of it.”
Dr Dimitri said the concept of using third parties to do certain activities is not a novel concept.
“It is something that is part of the toolbox that exists in any regulatory organisation. When we ask a third party to do something, in the context of food safety we use third party labs to do our testing, we still require them to have a certain quality of the work that they do and we monitor that quality and we take action should something happen so the ultimate authority remains with us.
“Using what we call alternate service delivery models is not something that is off the table completely but it is something we consider as options as appropriate and in the right context.”
Dr Dimitri said the public health agency maintains numbers of illnesses in an outbreak.
“As illnesses are often triggered several days after the consumption of a product it allows us to be able to provide the public with information without time limiting it or making it sound like it is over. It is the public health agency that declares a cluster of illness is over.
“We do have surveillance programs for things like Cyclospora because we too have seen the pattern over the years so we keep an eye on it. From the CFIA perspective we are there to monitor whether it is present or not and if it is present we take the appropriate action. We have been monitoring it year over year as part of our normal program of surveillance of foods.”
- Miss part one of the interview? Follow this link to read it in full.