Safe Food for Canadians Act – Challenges & Opportunities

Royal Assent on November 22, 2012 resulted in Safe Food for Canadian Act. Entire Act must come into force on one day with supporting regulations, expect two years for full implementation.


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The Act consolidates the following:

  • Meat Inspection Act and Regulations,
  • Fish Inspection Act and Regulations,
  • Canada Agricultural Products Act (CAPA) and Regulations, and
  • Food provisions of Consumer Packaging and Labeling Act and Regulations



Canada’s food safety system among world’s best but vision when Canadian Food Inspection Agency created was for more integration across regulations, programs and inspection. With profound impacts for industry, consumers, and governments,  Canada’s food environment has changed during Agency’s 15 years, in terms of:

  • advances in science and technology
  • globalization and business consolidation
  • ageing population and increasing consumer safety expectations
  • product and process innovation, rising demand for ready to eat products
  • increasing use of modern food safety tools – preventive controls, traceability
  • increased knowledge of risk and systems-based approaches to food safety risk management

It also led to successful investments over last 5 years in Food and Consumer Safety Action Plan, new inspection model and new legal framework.

One Horizontal Food Safety Regulation, with the following elements: –

  • Preventive controls programs, special process controls
  • Licensing
  • Exemptions
  • Import, export and interprovincial trade
  • Certification
  • Disclosure of information
  • Record keeping

With Commodity Specific Provisions, which address:

  • Fair markets
  • Grade names
  • Certification
  • Packing and Marking
  • Labeling requirements
  • Commodity requirements
  • Compositional standards



Enormous challenges addressed by the Canadian Food Inspection Agency, few of them has been listed below:

  • Scope to further strengthen Canada’s world-class food safety system.
  • Industry principally responsible for safe food and consumer protection.
  • Food safety system must be capable of continuous improvement based on science, global trends and best practices and be:
  • Enabled to deliver better protection from food safety risks for Canadians;
  • Focused on science-based and risk-based prevention and control of potential hazards as well as robust and responsive;
  • Transparent so consumers can play their role and so industry understands obligations;
  • Internationally consistent and harmonized wherever possible;
  • Best available skills tools and technology to efficiently provide regulatory services to industry; and
  • Outcome-based and assessed regularly to verify that outcomes are achieved and that systems are functioning well.
  • A passage of Safe Food For Canadians Act sets stage for important improvements to achieve these outcomes


Beyond the Border

Beyond the Border action plan includes a more integrated border process whereby:

  • Canada and the US achieve an increased measure of data harmonization for imports into both countries.
  • Traders are provided with a single window in each country through which they can electronically submit all information to comply with Customs and other government import regulations.
  • Departments and Agencies will have the required electronic data to support admissibility recommendations by their respective programs.
  • Data requirements are converted to electronic form using Customs import data collection mechanisms, minimizing the requirement for paper forms in the import process.
  • Improved trade facilitation and increased efficiency are achieved through the use of electronic data interchange.
  • There is an increase in the number of departments and agencies conducting business electronically at the border.


The Benefits of this action plan include

  • Convert border process to electronic data requirements.
  • Better quality, more accurate and more timely information collected.
  • Processes and requirements are consistent with international trading partners.
  • Modernized electronic – commercial process.
  • Eliminate manual paper processes.
  • Designed in collaboration with the trade community.
  • Streamlined border processes
  • Elimination of duplicate requirements.
  • Align with eManifest, where possible


Project Plan

Project plan includes announcement of Regulatory Framework

  • New Food Regulation Framework released Spring 2013:

    • Anticipated elements of new food regulations, with public policy objectives clearly identified

    • Launch consultation plan and feedback mechanism

  • Address regulations to come under the CFIA Act, including:

    • Recall processes for all food

    • Appeals and redress mechanism

  • Imported Food Sector Regulations under Food and Consumer Safety Action Plan go to Canada Gazette Part I Spring 2013 (licensing and preventive controls for imports under existing CAPA authorities).

Project Plan concludes with formal Regulatory Process

  • Formal Notice of Intent of new Food Regulations – Spring 2014

    • Draft content of food regulations released

    • Supported by draft suite of guidance documents, including:

      • New food policies that provide consistency and direction

      • New compliance promotion documents for industry

      • New manuals for CFIA inspection staff

    • Will permit expedited coming into force after Canada Gazette process

  • Regulatory Requirements completed with TBS assistance – 2014

    • Cost Benefit Analysis and Small Business Lens

    • Regulatory Analysis and Impact Statement (RIAS)

    • Blue Stamped Regulations from DOJ

  • CG1 – by September 2014 and CG2– by December 2014

 Leading to New Food Program


New Food Regulations

Few important points from the newly developed project plan have been mentioned below that needs the special attention of enterprises, it includes:

Principles for Crafting Regulations:

  • universal licensing
  • HACCP-equivalent approaches to food safety
  • targeted, limited exemptions
  • more robust approach to imports
  • use of incorporation by reference for technical requirements (eg grade standards and standards of identity)
  • Requirements will be outcome-based and generic across food where ever possible
  • Program design to produce better output guidance to industry and inspectors


Importer licensing under Food Safety Action Plan

  • using existing authorities initially
  • Targets importers of products not currently regulated under CFIA statutes
  • License and preventive controls to be required


Changes to Meat Manual

  • New requirements for testing/procedures related to E.coli in meat plants


Food Traceability

  • Mandatory for meat establishments to track and provide electronic copies of traceability/distribution records & production records
  • immediately upon a CFIA request; and
  • in an unencrypted format that can be read and analyzed using standard commercial database software.


More Effective Inspection

  • Industry responsibility affirmed
  • Better verification and protection for Canadians
  • Risk-based decisions to better manage risk
  • Systems-based approaches
  • Transparency
  • System assessed regularly
  • More consistent regulatory interpretation
  • Regulated parties understand obligations


New Inspection Model Developed…



Summarizing Opportunities

  • Those who import, export or prepare food for inter-provincial trade will be identified and required to have preventive controls in place
  • Oversight will be risk based – better application of intelligence to determine risk
  • Inspection approach will be consistent across food
  • Single strategy for compliance and enforcement to provide consistent and appropriate resonse across food
  • Systematic assessment of performance embedded in approach to ensure continuous improvement
  • No food safety system can guarantee a risk-free environment. But planned initiatives focus on prevention and include series of integrated actions to deliver highest possible level of food safety for Canadians.
  • Will mean new requirements for licensing and preventive controls for many.
  • Government commits to working to tailor approaches to SMEs and provide time to transition.
  • Canadians are proud of and confident in their food safety system.
  • The system must evolve; Approach designed to maintain legacy of safe food in Canada

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