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1988 Report of the Auditor General of Canada

Main Points

We were impressed by the dedication of the Food Production and Inspection Branch's management and inspection staff, and by the high regard in which the Branch is held internationally. This reputation is important for Canada's trade.

The Branch shares responsibility with industry and with provincial and other federal departments for the safety, health and wholesomeness of agricultural food products. It conducts a wide range of activities to protect the health and safety of Canadians and the viability of large sectors of Canada's food, plant and animal industries. Work remains to be done to fully determine which risks are most serious, so resources can be better concentrated where risk is greatest. (paragraph 8.2)

The Branch needs to strengthen several key inspection practices to provide reasonable assurance that human health and safety threats posed by chemical and bacterial hazards associated with food and agricultural products are prevented or removed. Although it does extensive sensory inspections, it needs to use additional laboratory testing, generally the only way of detecting these hazards. (8.26 to 8.40, 8.44 to 8.48)

Current procedures for registering and regulating pesticides need strengthening to provide reasonable assurance that all pesticide products used in Canada are effective and pose minimal or no risk to human health and the environment. (8.49 to 8.65)

There is a need to reduce shortcomings in import inspection standards and practices to reduce Canada's vulnerability to the introduction of foreign animal or plant disease. The Animal Health program has been internationally recognized for eradicating brucellosis and tuberculosis in cattle. But the Branch is not actively involved in controlling many of the plant diseases and - in recent years - animal diseases now established that may be of significance in Canada. (8.66 to 8.100)

The Branch also needs to strengthen certain export certification practices for agricultural and forestry products in accordance with requirements of the international convention (8.101 to 8.110). It also needs to improve support and training for inspectors and relations between line and supervisory staff (8.41 to 8.43, 8.58, 8.82 and 8.83).

Overview

8.1 This audit of the Food Production and Inspection Branch of the Department of Agriculture concentrated on the Branch's delivery of its program. The Branch is the government's primary regulatory and inspection arm, in plants registered by Agriculture, for ensuring the quality and safety of the domestic and imported foods Canadians eat (other than fish). Its activities are intended to protect the health and safety of Canadians and Canada's plant and animal resource base and to maintain and improve the marketability of agricultural and forest products. It has developed formal results statements concerning the achievement of these objectives. For example, one of these results statements is to:

prevent/remove human health and safety threats created through chemical and bacterial hazards associated with food and agricultural products.
8.2 While prevention or removal is the ultimate aim, the Branch can only provide reasonable assurance that it is achieving this intended result. We believe that, for each objective, it can provide such reasonable assurance only by:

    - determining which risks are greatest;
    - targeting its resources where risks are found to be greatest; and
    - setting specific performance targets, in relation to what the Branch is committed to accomplishing.
This theme, of the need to assess risks, allocate a major portion of the resources to the highest risk areas, and operationalize objectives, appears throughout this chapter.

8.3 The Branch's inspection activities have a direct and daily effect on Canadian consumers on the one hand and the agricultural industry on the other hand (see Exhibit 8.1). For example, Canadians on average consume some 95 kg of fresh fruit, 146 kg of fresh vegetables and 71 kg of red meat a year, all of which fall under the Branch's regulatory jurisdiction. In carrying out its mandate to protect human, animal and plant health and safety and to facilitate economic trade within Canada and internationally, the Branch must balance considerations that often conflict.

Exhibit not available

8.4 The Branch reports on its activities in relation to the three inspection programs described below. These represent seven directorates, of which two deliver the programs regionally and five develop policy at headquarters.

8.5 Food Safety and Inspection. This includes the Meat Hygiene sub-program for regulating and inspecting meat, and other sub-programs for poultry, fresh and processed fruit and vegetables, and dairy products.

8.6 Animal Health. This program has a mandate to regulate and inspect live animals, animal products and by-products such as embryos and animal feeds.

8.7 Plant Health. This program's mandate is to regulate and inspect plants, forest products, seeds, pesticides and fertilizers.

8.8 The three programs, and the Branch's management and administration component, require some 4,300 person-years and $240 million, as outlined in Exhibit 8.2. Eighty-five percent of the Branch's personnel are employed in the regions, where inspections at manufacturing plants, airports, and a wide range of other facilities are conducted (see photo).

Exhibit not available

8.9 The Branch's legislative authority derives from 10 significant Acts of Parliament and related regulations. It shares responsibility with industry and other provincial and federal departments, such as Health and Welfare and Consumer and Corporate Affairs, that have responsibilities for the safety, health and wholesomeness of agricultural food products.

Audit Scope

8.10 Our audit was limited to the Food Production and Inspection Branch in the Department of Agriculture and concentrated on its program delivery in Food Safety and Inspection, Animal Health and Plant Health - specifically plants, forest products and pesticides. We looked at these programs in relation to the Branch's following five statements of expected results, which it uses as objectives:

    - prevent/remove human health and safety threats created through chemical and bacterial hazards associated with food and agricultural products;
    - prevent the introduction into Canada of exotic diseases, insects, weeds and other dangerous entities of plant or animal origin;
    - control and eradication of exotic diseases, insects, weeds and other dangerous entities of plant or animal origin which gain entry;
    - prevent/control/eradicate domestic animal or plant diseases of economic or human health significance; and
    - provide the inspection and certification required for export.
8.11 We looked at how the Branch carried out its operations, how it translated the results it expects to achieve into specific targets, and operating procedures' consistency with legislation. In developing our audit findings, we relied on the Branch's internal audits and studies wherever possible.

8.12 The observations and recommendations that follow result from audit examination to March 1988. Departmental responses to our recommendations include corrective actions to August 1988.

Human and Environmental Health and Safety

Chemical and Bacterial Hazards in Food and Agricultural Products

8.13 Industry's goal of safe food is similar to that of the Food Safety and Inspection program. While industry is ultimately responsible for the health, safety and quality of products offered for sale, the Branch is required to inspect and regulate these products according to health standards specified under the Food and Drug Act. The Food Safety and Inspection program's mandate as stated in Part III is to "ensure that food and agricultural products are safe, wholesome, accurately graded (for economically significant factors), packaged and labelled to avoid fraud, thus enhancing their marketability and eliminating human health risks".

8.14 The Branch has an extensive program of inspections of slaughter operations for animals and poultry; monitoring of establishments involved in food production, storage and transportation; grading of livestock carcasses; and monitoring the movement of meats, poultry and dairy products, and fresh and processed fruits and vegetables, to ensure compliance with Canadian and foreign standards for safety, wholesomeness, packaging and labelling (see Exhibit 8.3).

Exhibit not available

8.15 The program's operations are not only diverse but very significant. In 1987, for example, according to Branch information, it inspected 2.7 million tons of domestic meats, audited and rated the safety of 570 Canadian meat slaughter and processing plants, inspected some 7,500 shipments of imported meats and monitored 1,700 federally licensed produce dealers. It also inspected some 3,000 federally registered establishments for compliance with federal Food Safety Regulations and good food handling practices; conducted health and safety inspections in 160 hatcheries and 350 egg grading stations; and graded 13 million hog carcasses, 2.5 million beef carcasses and a smaller number of veal and lamb carcasses. It should be noted, however, that the Branch has no responsibility for monitoring establishments involved only with intra-provincial trade in agricultural products.

8.16 In 1987-88, the program used some 2,375 person-years and $112 million, of which the Meat Hygiene sub-program accounted for 1,660 person-years and $80 million.

8.17 In the Food Safety and Inspection program we focussed our audit on activities in support of the Branch's results statement: "to prevent/remove human health and safety threats created through chemical and bacterial hazards associated with food and agricultural products".

8.18 Canadians expect the foods they consume to be not only wholesome but also safe. For instance, public and media attention today turns to the potential risks to human health and safety from chemical residues in foods - such as pesticides, heavy metals, animal growth promotants, antibiotic drugs, feed additives and other substances - as well as the risks from bacteria such as Salmonella and Listeria, and parasitic hazards such as Trichinosis.

8.19 In 1975, the Advisory Committee on Food Safety Assessment, reporting to the Department of National Health and Welfare, found that the Canadian food supply was generally safe. However, the Committee's report also stated that between 1,000 and 2,000 cases of food poisoning were reported annually, and cited evidence that the total number of cases may have been as high as 400,000. Although allocation of responsibility among processors, inspectors, retailers and consumers is difficult to estimate, it is generally assumed that a large portion is due to consumer mishandling of foods.

8.20 Ten years later, in 1985, the Ministerial Task Force on Program Review concluded that consumers' confidence in the safety of foods was justified, and that Canada had an effective food inspection system. It stated that the Branch had taken many initiatives to respond to past challenges in health and safety, disease control and quality assurance. In response to the recommendations of the Ministerial Task Force, the Branch created a National Food Safety Advisory Group in December 1986, representing producers, processors, consumers and federal and provincial government departments. Its purpose is to advise on an appropriate level of food safety inspections, balancing the potential risks to human health and the resources to be devoted to inspections. The Food Safety Advisory Group concluded that "the Meat Hygiene Program is detecting problems and adequately giving assurance that a wholesome meat supply is reaching the Canadian Public."

8.21 Based on our audit findings outlined below, we have concluded that inspection practices need to be strengthened to permit the Branch to provide reasonable assurance that human health and safety threats caused by chemical or bacterial hazards associated with food and agricultural products are identified, prevented and removed.

8.22 Health risk assessment. In January 1988, the Advisory Board assessed the risks to human health caused by bacteria, parasites and chemical hazards in domestic and exported meats. It estimated that the annual health and economic costs, such as for medical care, loss of productivity and business, investigation of illness and legal action associated with these hazards range from about $1.1 billion to $1.6 billion. Food poisoning and economic costs caused by Salmonella alone were estimated at $477 million. We are concerned about the threats presented by the most significant of these risks, particularly Salmonella. Its effects have been known for 15 years through studies undertaken and international symposia attended by program managers. Although the Program determined, in 1986, that 51 to 72 percent of broiler chickens tested at the plant level were found to be contaminated by Salmonella, its in-plant inspections have only recently been geared to controlling this. We have been advised that a detailed plan has now been drafted for reducing the level of Salmonella contamination and that its implementation began in late 1987.

8.23 For meat processing, where plants are assessed to determine risk, the Branch does not know whether the plants with higher risks get more rigorous inspections. For example, it conducts national audits of all meat processing plants and establishes ratings ranging from "AAA" to "F". According to the Meat Hygiene Inspection Manual, plants rated "B" and "C" require increased surveillance and monitoring inspections, to correct identified deficiencies. However, because of several operational deficiencies, the Branch does not know whether or not there is an increase in the rigour of inspections for riskier plants.

8.24 For other food commodities, such as dairy products, fresh and processed fruit and vegetables and imported meats, no meaningful risk assessments have been done. As a result, management does not know the extent of human health risks posed by chemical and bacterial contamination in these foods and cannot assure itself that its inspection resources are directed where these risks are greatest.

8.25 The Branch should fully determine the relative risks to human health and safety posed by the chemical and bacterial hazards associated with food and agricultural products. The results of these assessments should be used to direct existing inspection resources to areas of greatest risk.

Management's response: We agree, and the Branch is already acting to determine risk levels and to modify Branch activities. In response to Nielsen, a Quality Assurance and Food Safety Advisory Board was created in 1986. To date, the Advisory Board has completed an assessment of the risks associated with meats. Currently, it is evaluating dairy, red meat grading, poultry and egg products programs. Subsequently, it will assess fruits, vegetables, honey and maple syrup. As well, in April of 1988, the Department created the Agri-Food Safety Division. This organization has assumed the departmental responsibility for risk assessment in food and agricultural products.

8.26 Reliance on sensory inspections. The Food Safety and Inspection program conducts extensive visual and other sensory ante- and post-mortem inspections designed to detect human health risks posed by pathological animal diseases such as tuberculosis, and to find gross contamination. There are also inspections of the meat processing lines according to a detailed Meat Hygiene Manual.

8.27 However, while indicators of health risks from chemical or bacterial contamination in food and agricultural products can be reduced by visual inspection, such risks can generally only be detected and measured by laboratory analysis. Limited laboratory tests are conducted to detect such contamination. For example, the Branch's own documents indicate that residue testing on imported products - largely meats, fruit and vegetables - should be quadrupled. Also, in the Meat Hygiene sub-program, residue and bacterial laboratory testing account for a very small fraction of the budget. A 1986 document issued by Meat Hygiene officials indicates that the budget should be tripled to "ensure the safety of meat products and maintenance of (Canada's) export trade". Without sufficient laboratory testing, food-borne chemical and bacterial contamination could go undetected.

8.28 In the case of surveillance inspections, the carcass is detained until the related laboratory tests are received. However, where meat samples are taken as part of general monitoring, laboratory analysis of them requires anywhere from a few days to a few weeks. The carcass from which the sample was taken is not withheld from distribution pending the results of laboratory testing but leaves the processing plant and is shipped to retailers, regardless of whether the tests later find chemical or bacterial contamination.

8.29 The Branch is aware that several rapid diagnostic tests are available to detect certain chemical residues and bacterial food hazards, and uses a few of these. Such tests can be conducted quickly in the plant by food inspectors, do not require laboratory analysis and can be completed in up to 24 hours. The meat sample could then be traced back to a particular carcass if the results revealed the presence of chemical or bacterial contamination. However, the Branch has not fully assessed the practicality of these rapid diagnostic tests to augment its sensory inspections and current laboratory testing.

8.30 To meet its stated objectives, the Branch should increase its laboratory testing for chemical residues and bacterial contamination of human health significance in meat and in fruits and vegetables. It should also fully assess the practicality of using rapid diagnostic tests to augment its laboratory testing.

Management's response: We agree that laboratory testing should continue to increase, and during the last three years chemical and biological residue testing programs in meats have been augmented approximately 20% per annum. Also, through liaison with Health and Welfare Canada, duplication in testing has been eliminated, and efficiency improved.

The Branch is fully committed to developing and utilizing practical and rapid diagnostic tests. At present, the Branch has several rapid tests in place. These include the S.T.O.P. (swab test on premises for detection of antibiotic residues), C.A.S.T. (calf antibiotic screening test), and swab tests to determine bacterial loads on equipment. Currently, we are evaluating a commercial diagnostic kit for salmonella, and a card test for detecting sulfa drugs.

8.31 Sampling. In view of the volume of products requiring inspection and laboratory testing to detect chemical and bacterial contamination, food inspectors cannot examine each commodity unit. They must rely on statistical sampling plans to select the units that are to be inspected and sent for laboratory testing.

8.32 The sampling plan used in the Branch is patterned after one developed by the United States Department of Agriculture, and is of the type known as a discovery or exploratory sampling plan. It is used to monitor the incidence of contaminated units of a particular commodity in a population; such as in all hogs or all cattle slaughtered in a particular geographic region over the course of a year. A contaminated unit is one whose level of a particular residue - an animal growth hormone, for example - exceeds a level specified in the Food and Drug Act or the Branch's food safety regulations. The sampling plan is designed to detect, 95 times out of 100, a small but undesirable incidence. This incidence is assumed to reflect the risks to human health posed by specific chemical or bacterial contamination of the particular commodity. The program usually sets the minimum incidence at one percent and this dictates a sample size of some 300 units for each of the five regions. Should one or more sampled units prove contaminated, a surveillance operation may be put into effect, as is the case for certain residues in pork.

8.33 Sampling plans for detecting chemical residues and bacteria have been implemented for domestic slaughtered animals and, to a limited degree, for imported meats. They are used as a basis for a national chemical and antibiotic residue detection plan for meat and poultry of over 10,000 samples annually, and an ongoing meat safety program for parasitic and bacterial organisms of human health significance. The results of laboratory analyses, published annually in summary form, are used to monitor the levels of chemical residues and bacterial contamination across Canada.

8.34 During our audit, we found a number of areas where these sampling plans and their assumptions could be improved:

    - The incidence level is not based on a complete assessment of the health risks posed by potential chemical and bacterial hazards and, as such, may not offer sufficient consumer protection against all of these risks.
    - The Branch recognizes that any assumption about statistical uniformity within particular food commodities is questionable. However, it asserts that its use of random selection compensates for this weakness. We have considered this but believe that variations in the degree of contamination, for instance in hogs, within a geographic region and over time, are inevitable and will weaken the results of the sampling plans. Shifts below the designated incidence level will have no detrimental effect but those to higher levels could go undetected.
8.35 As a consequence of these weaknesses, the 95 percent confidence that the sampling plans are expected to provide, in detecting human health and safety threats associated with chemical and bacterial hazards in food and agricultural products, is not attained.

8.36 We found that for both domestic and imported fresh and processed fruits and vegetables, worth $3 billion annually, there is very limited testing for chemical residues. Imports are estimated to represent approximately 50 percent of the fruits and 30 percent of the vegetables available in Canada. We have been advised by program officials that sampling plans have now been developed to test for chemical residues in fruits and vegetables in the future.

8.37 Also, the program generally considers that imported meat has been inspected and tested for residues and bacterial contamination in the country of origin, under the "equivalency principle" of import trade. The Branch has not fully evaluated the adequacy of the testing programs of several of Canada's trading partners. Where a particular program appears to be less than adequate, the Branch has not required that it be modified to fulfil minimum Canadian requirements, or has not conducted additional inspections or laboratory testing.

8.38 To avoid bacterial contamination in domestic processed meat products, the Branch relies primarily on good manufacturing practices and draws a sample of only five packages from each lot chosen for testing. The lot is accepted if the organism count in each package is below the maximum level specified. Such a small sample is intended as a deterrent against industry's neglect of good manufacturing practices but it is not designed to, and cannot, distinguish unsafe from safe product.

8.39 We noted the claim in the Advisory Board's report "that there is virtually no risk to consumers associated with the present level of residues". However, our audit noted areas where the sampling plans could be improved, the very limited chemical residue testing in fresh and processed fruit and vegetables, both imported and domestic, and the gaps in testing meat imports.

8.40 The Branch should complete its evaluations of the adequacy of Canada's trading partners' programs for controlling chemical and bacterial hazards, where imported foods are accepted as safe. It should also review its own approach to statistical sampling for residues. In particular, it should:

    - examine the assumption of statistical uniformity within particular food commodities as well as the set incidence levels;
    - extend revised sampling plans to include detection of chemical residues and bacterial hazards in dairy products, fresh and processed fruits and vegetables and meats, both imported and domestic.
Management's response: The Branch agrees that it should complete its current evaluation of Canada's trading partners' residue control programs. The evaluation of meat products is well under way, the countries which remain to be assessed account for less than 6% of meat imports, and the risk for these last countries is considered to be low. The completion target date for meat products is March, 1989. As well, the Branch has initiated an assessment of the remaining food commodities; completion target date is March 1990.

By September 1988, the Branch will be reviewing its sampling plans to determine what changes might be required to ensure that the principles of statistical uniformity and incidence levels are respected.

Sampling plans have been implemented for a wide range of chemical residues in imported fruits and vegetables. Sampling plans for bacterial hazards will be completed by the end of January, 1989.

8.41 Inspector training. We noted that veterinary technical inspectors are not provided with in-depth training in food sciences, a prerequisite if inspections are to ensure food safety. Under existing legislative authority, veterinarians are responsible for the inspection of meat and meat products. There is a complete and extensive training program to help inspectors detect pathological animal diseases that may pose human health threats, and quality deficiencies, in meats. However, they are not trained to know the dangers to health inherent in some of the substances used in processing or preserving foods, or in appropriate statistical quality control procedures for evaluating the safety of food processing operations.

8.42 We also found a need for improved training in employer-employee relations for the veterinarians responsible for managing meat plant inspections. This is particularly important in view of the large number of grievances lodged by Meat Hygiene inspectors and the management time and effort required to resolve these.

8.43 Food safety technical inspectors should receive in-depth training in appropriate areas of food sciences and other relevant subjects. Also, veterinarians with management responsibility should receive training in employer-employee relations.

Management's response: We agree with an increased training orientation in food sciences. This shift in training is consistent with the Branch's policy decision to strengthen food safety programs; a direction the Department decided to take in 1986. The Branch has encouraged supervisory staff to take employer-employee relations training. By October 1988, the Branch will incorporate into its training policy a plan whereby a veterinary supervisor with five or more employees must receive this training within the first six months of appointment.

8.44 Medical testing. In the Food Safety and Inspection program, primary products inspectors carry out a wide range of inspection activities that rely heavily on sensory acuity. Despite this reliance on the senses, inspectors performing this work in one region were not given medical tests for colour blindness or other sensory defects. In the same region we also found that workers in meat plants and other Agriculture inspectors cross-utilized in veterinary inspection roles were not subject to medical testing, even though regulations require that all employees of such plants be free of communicable diseases.

8.45 Authorities. Fundamental problems with the Department of National Health and Welfare relating to jurisdictional, legislative, regulatory and inspection concerns have now been resolved. Cabinet has reaffirmed that Health and Welfare has primacy under the Food and Drug Act for defining human health and safety hazards caused by chemical, bacterial and other hazards in food. And it designated the Branch as the primary delivery arm for inspection of all establishments registered by the Department of Agriculture according to food regulations under its jurisdiction.

8.46 Since 1986, an inter-departmental committee has met frequently to address these concerns. In April and May 1988, the two departments signed a memorandum of understanding and several detailed technical appendices. These clarify their mutual responsibilities for ensuring the marketing in Canada of agricultural products which are safe and wholesome, through the enforcement of the Canada Agricultural Products Standards Act and Regulations, the Meat Inspection Act and Regulations, and the Food and Drug Act and Regulations.

8.47 The Branch is in the process of adopting, by reference, all relevant provisions of the Food and Drug Act, such as specifying tolerance levels for chemical, bacterial and other human health and safety hazards in foods, to provide the necessary regulatory base for its inspections. At the conclusion of our audit this had not been completed.

8.48 The Branch should ensure that its regulations incorporate tolerance levels specified for chemical, bacterial and other human health and safety hazards in food and agricultural products.

Management's response: The Branch agrees that tolerance levels should be specified for chemical safety hazards in food and agricultural products. The Branch will adopt, by reference, tolerances as they are published by the Department of National Health and Welfare. It is worth noting that on July 7, 1988, an amended Canadian Agricultural Products Act received royal assent. This is a major piece of legislation for food inspection, and its regulations are being updated to incorporate reference to tolerance levels set by Health and Welfare.

Pesticide Registration and Regulation

8.49 The Plant Health program includes a Pesticide component which, under the authority of the Pest Control Products (PCP) Act and Regulations, is responsible for the registration and regulation of pesticide products in Canada. In operational terms, the program works to ensure that chemical products for controlling agricultural pests are effective, and pose minimal or no risk to human health and the environment. This program operates in a controversial environment; it must respond to the needs of the farming and chemical industries for effective and timely pest control products and to the health and environmental concerns of the Canadian people (see photo).

8.50 The assessment of pest control products requires co-operation between the Department of Agriculture and other federal departments. The Departments of National Health and Welfare and Environment provide, respectively, advice and recommendations on potential human health hazards from pesticide products and the risk these pose for environmental contamination. Memoranda of understanding have been signed or are being drafted with these departments to help to clarify policy matters. Working level co-ordination has also been established between the Pesticide program and these other departments to facilitate the process.

8.51 However, on the basis of the audit findings outlined below, the Pesticide program needs to strengthen the current procedures for registering and regulating pesticides, to have a basis for providing reasonable assurance that all pesticide products used in Canada are effective and pose minimal or no risk to human health and the environment. Also, many potentially useful pesticide products are not readily available because of delays in registering them.

8.52 Risk management. Since 1985, the Pesticide program has moved toward a risk management process where the risks and benefits of pesticides are assessed and the results used to make decisions on new or continued product registration. However, there are no formal guidelines for applying the process, which can lead to inconsistencies in its application.

8.53 Currently registered products. We found there is a need to re-evaluate many products, some of which have been registered on the basis of data subsequently found to be invalid. Many were registered prior to 1980 and were not given the same scrutiny that is now required. The federal government may be subject to criticism if it continues the registration of pesticides supported by suspect test data. Also, many currently registered pesticide products have not been fully evaluated for environmental risks. There is no legislative requirement for systematic re-evaluation of registered products, even those where health and safety concerns are high. In practice, pesticide registrations are virtually automatically renewed for a further five years on request and payment of a minimal fee.

8.54 We note that the Pesticide program has recently begun to systematically re-evaluate pesticide products on a limited basis. At the present rate of re-evaluation, however, it will take an estimated 37 to 55 years to complete, and 15 years to review even the highest priority and highest volume products.

8.55 In addition, there are now 150 pesticide products with temporary registrations, normally issued for one year, to permit further product testing. These can also be renewed annually, and the PCP Act does not limit the number of renewals; some products have had temporary registrations for many years. The renewals give the products the same standing as a full registration would, without having to meet the same requirements. In fact, temporary registrations have been issued for pesticide products which were effective in controlling a crop pest but were known to be hazardous to human health. One such pesticide had its temporary registration renewed in 1987 even though management considered its safety studies incomplete and potential human health concerns were evident. The registration was renewed because no alternative control products were available. This is one example of the trade-offs the Branch has to make between economic benefits and human health and safety. Also, the Pesticide program does very limited monitoring to ensure that products are used in compliance with temporary registration conditions - in fact, its work plans do not call for this type of monitoring.

8.56 There is little evidence to show whether pesticide products are manufactured under safe conditions. Although the PCP Act, which has been in force for years, specifically prohibits manufacture of products under unsafe conditions, the Pesticide program has only recently begun to evaluate and inspect the more than 400 pesticide manufacturing facilities in Canada to ensure compliance with the PCP Act and Regulations. These inspections, however, have not provided much information on the safety of manufacturing conditions because they have assessed only laboratory facilities; plant operations have not been reviewed. While inspections of manufacturing plants are desirable, the PCP Act and Regulations do not provide clear and simple authority to support these inspections or to enforce any recommendations for compliance that the Pesticide program might make to the manufacturer.

8.57 The Pesticide program receives approximately 2,000 requests annually for registrations or modifications. We found an accumulation of 3,500 submissions waiting for registration. According to 1987-88 program documents, the registration process for a new active ingredient requires from 12 to 36 months. This appears to result not only from the time required to obtain information when it is needed from other involved departments, but also because of the more intensive and rigorous registration process now being followed. The effect of the delay is to keep pesticide products from being marketed, thus depriving agricultural producers of their use and possibly leading to importation of illegal products. In fact, there is limited import monitoring to determine the extent to which unregistered or illegal pesticide products are being brought into Canada.

8.58 The training provided to Agriculture inspectors who are cross-utilized to monitor pesticides appeared to be inadequate; there is a lack of training plans, and employees learn about pesticides by studying the literature, with no formal instruction. The inspectors themselves feel ill equipped to answer inquiries from industry.

8.59 Authorities. We found three gaps in the legislation, two of which have some direct cost implications. First, the PCP Act and Regulations are unclear about who is responsible for the disposal of seized or detained pesticide products. For example, the program detained 560,000 litres of a pesticide product after cancelling its registration. Because this product was still marketed in the United States, the manufacturer voluntarily removed the product. Had this not happened, the Branch might have been liable for the costly disposal of this toxic substance.

8.60 Second, when a product's registration has been cancelled, the PCP Regulations permit a registrant to have the decision reviewed by a Board appointed by the Minister. The total cost of the review is borne by the Crown even though requested by the registrant. A recent review board, for example, cost the Crown some $1 million. As the program undertakes the re-evaluation of registered products, many of which are based on weak information, this costly and time-consuming review procedure may be called for more frequently.

8.61 Finally, there are no operational or special legislative definitions of "safety", "merit", or "value". As these are the conditions under which products are registered, clear definitions of these terms would help in determining the acceptability of a pesticide product and prevent inequities in product registration or cancellation. We understand that these and other regulatory amendments are being actively sought by program officials.

8.62 The Branch should complete its evaluation, as quickly as possible, of currently registered pesticide products on the basis of highest risk and, as a minimum, operational guidelines should be introduced to stipulate the conditions under which this must be done. Also, there should be operational guidelines to limit renewals of temporary registrations, and compliance with registration conditions should be monitored.

Management's response: The Branch agrees that currently registered pesticides be re-evaluated on the basis of highest risk. A systematic process has already been established to determine re-evaluation priorities on the basis of risk-ranking and volume of use. Further, the Branch is exploring alternative delivery mechanisms including a closer liaison with U.S. authorities to investigate opportunities for joint or interchangeable reviews.

Consultations have already begun to establish formal operational guidelines for temporary registration. Efforts will continue to carry out selective monitoring, based on volume of use and potential risk, of registration conditions.

8.63 Manufacturing plant operations should be inspected to assess the safety of manufacturing conditions, and the Act and Regulations should be amended to provide enforcement authority.

Management's response: The Branch agrees that it should pursue its recent initiatives to assess manufacturing operations to ensure product safety. This will be done by monitoring plant laboratory operations. An evaluation of the enforcement authority in the Acts and Regulations will be made.

8.64 The Branch should take steps to reduce the accumulation of submissions for pesticide product registrations.

Management's response: We agree with the desirability of this recommendation. The Branch will continue to examine the possibility of applying further resources in the registration activity, and will continue to streamline operating procedures and improve efficiency. Finally, we will not introduce shortcuts that will unduly compromise the thoroughness of reviews of human health or environmental quality considerations.

8.65 The training provided to Agriculture inspectors cross-utilized for pesticide inspections should be improved to address pesticide inspection requirements.

Management's response: We agree, and the Branch has to date provided regional pesticides officers/specialists with "hands-on" technical instructions. Further work will be done in developing and refining procedures manuals and training modules supported by audio-visual material.

Animal and Plant Disease Prevention and Control

8.66 In addition to human and environmental health and safety, animal and plant disease prevention and control are also important aspects of the Branch's mandate. The Animal Health program is intended to protect and improve the health of Canadian livestock, thereby contributing to the maintenance of markets for Canadian livestock, meat and animal products, and to reducing the transmission of animal diseases to humans. The Plant Health program is intended to control plant diseases and pests.

Preventing the Introduction of Dangerous Foreign Animal and Plant Diseases

8.67 We examined Animal and Plant Health policies and program delivery in relation to the objective stated by the Branch - that is, to prevent the introduction into Canada of exotic (foreign) diseases, insects, weeds and other dangerous entities of plant or animal origin.

8.68 High numbers of air travellers (10 million in 1987) and large volumes of imported agricultural products arrive at hundreds of Canadian airports (see photo), seaports and land ports of entry. The Plant Health program's internal reports indicate that some 513 million plants are imported each year from the United States and 43 million propagative plants from 17 other countries. Also, more than 1 million kilograms of soil and some 72,500 cubic metres of forest products are imported annually.

8.69 We noted the challenges inherent in preventing the introduction into Canada of plant and animal diseases that are prevalent in many parts of the world. Many of these, such as karnal bunt or rust in wheat plants and foot-and-mouth disease in cattle, could be introduced by travellers or through imported commercial products. Canada's plants or forests could become infested with a foreign plant pest carried on imported plants or soil that contained a plant fungus, insect or nematode - a tiny worm-like parasite. Canadian livestock and poultry could contract a foreign disease from live animal imports, or viruses contained in imported meat, dairy or other agricultural commodities. Outbreaks of foreign animal disease, in Canada and elsewhere, have been caused when scraps of meat containing a foreign animal disease virus were fed to domestic livestock. These viruses can be quite durable; for example, research has shown that the foot-and-mouth disease virus can survive in meat for extended periods. If a foreign animal or plant disease were to break out in Canada, the impact on the economy and export trade could be substantial. For example, it is estimated that an outbreak of foot-and-mouth disease in Canada would cost as much as $2.8 billion in reduced farm cash receipts.

8.70 The Plant Health program is responsible for enforcing the Plant Quarantine Act, which requires that all imported plant or other material likely to be infested with a plant pest be accompanied by a Canadian import permit and a health certificate (phytosanitary certificate) from the exporting country. The Animal Health program is responsible for enforcing the Animal Disease and Protection Act that prohibits, restricts or controls the importation of animals and animal products. At ports of entry, Customs and Excise officers act as the first line of defence. On referral from Customs and Excise, Agriculture inspectors monitor travellers and commercial imports for prohibited agricultural products that should be seized or refused entry into Canada. The efficiency and effectiveness of inspection depends in part on the training provided to both Customs and Agriculture inspectors, and on inspection policies and standards.

8.71 A number of foreign plant pests with the potential to cause damage have gained entry to Canada and some are spreading, as outlined in Exhibit 8.4. We found that plant and, to a lesser extent, animal products and by-products import inspection practices need to be strengthened to reduce Canada's vulnerability to the introduction of a foreign animal or plant disease.

Exhibit not available

8.72 Risk management. In view of the volume of travellers and agriculture imports arriving in Canada, the size of the border with the United States and the different means of transportation, it is not feasible for the Animal and Plant Health programs to detect all the prohibited products (by regulation or otherwise), that can enter Canada. Risk assessments on a commodity and pest specific basis are needed to determine which imports are of highest risk - that is, most likely to cause disease and significant damage to Canadian plants or animals. Risk is a function of several factors, including the country of origin, the volume imported, and the possible health or economic threats associated with the commodity. After a complete risk assessment, import inspections could be better concentrated on those areas where risks are highest.

8.73 Plant material which may be infected now comes into Canada through as few as 80 and as many as 260 ports of entry. The Plant Quarantine Act and Regulations, however, state that such material shall only be imported through 34 specified ports of entry. This is a further indication of the need for determining the plant material with the highest risk of being infected so that the Branch can ensure the importation of such material complies with statutory requirements.

8.74 We found that the Plant and Animal Health programs have only considered some risks and have not conducted complete and systematic commodity and pest specific risk assessments. For Animal Health, internal reviews since 1979 have recommended that this be done. Some risk information is obtained from an international organization which disseminates information on animal diseases to member countries. For Plant Health, plant import permit requirements were relaxed in 1976 without a complete examination of the risks involved. The blanket exemption for plant import permits was subsequently cancelled.

8.75 In spite of dedicated inspectors, inspections may fail to detect a considerable amount of prohibited plant and animal products that are brought into Canada. Although inspectors seized 56,000 pounds of prohibited products in 1987 from air travellers alone, Branch studies found that in 1979, only 17.5 percent and in 1983, 36 percent of air travellers carrying prohibited goods were detected at one airport. Since then, air passenger volume has significantly increased, but no follow-up study has been done. For commercial imports, the Branch has not yet assessed the effectiveness of its detection capability. As a result, it does not know what proportion of prohibited products its inspection practices fail to detect or the risk this may pose for introducing foreign plant or animal diseases into Canada.

8.76 Currently, for example, there are limited inspections of rail cars and mail for plant pests; risk assessments would indicate whether this was appropriate. Also, significant plant pest risks may not be adequately addressed, such as those transported on or in seed. An example is a disease called blackleg of rapeseed (canola) that is infecting up to 1.5 million acres each year in Saskatchewan. It caused an estimated yield loss of about 25 percent in 1984 and 12 percent in 1985. We have been advised that the Plant and Animal Health programs have plans to conduct complete commodity and pest specific risk assessments in the near future. Once this has been done, the Animal and Plant Health programs would need to ensure that their import regulations, policies, staff capabilities and inspection practices were sufficient to detect unwanted material in the prime risk areas. Of particular importance is the need for the Plant Health program to improve its scientific diagnostic capabilities - at present, its laboratory resources are very limited.

8.77 In addition to these concerns about meaningful risk management, our audit found that the import practices noted below could cause a risk that foreign animal and plant diseases will be introduced into Canada.

8.78 Trade facilitation. In attempting to facilitate trade, Branch actions have permitted the importation of some plant material and animal products and by-products that contravene the Plant Quarantine and Animal Disease and Protection Acts and Regulations, and may also present a potential risk to Canada's plant and animal resource base. For example, the Plant Health program has granted exemptions from plant import permits and health certificates required to certify that the import is free of plant pests. It has also signed compliance agreements with importers which allow plant material to move from a foreign area that may contain a plant pest to a Canadian destination free of that pest if the importer agrees to certain terms and conditions intended to protect the country. However, not only is there no provision for such agreements under the Act, but we also found that the terms and conditions were not adequately monitored and enforced.

8.79 Also, in response to industry requests, the Plant Health program permitted unwashed potatoes to be imported into Ontario from an area it knew was infested with soybean cyst nematode, considered the pest most destructive of soybeans. Ontario is a prime growing area for soybeans. No import permit was required by Canada, and no health certificate from the exporting country. The importers did not carry out the terms of the compliance agreement intended to reduce the risks; for example, the trucks transporting the potatoes were not properly cleaned to destroy the pest. An inspection by Plant Health found nematode cysts in and around the importer's premises. The Plant Health program did not halt the importation because it considered the risks to be low; and it plans to allow the same imports in 1988, but under more rigid compliance terms and conditions to remove the risk of crop infestation.

8.80 Turning to an example in animal products and by-products, Animal Health program policies permit the importation of dairy products, such as soup and sauce mixes, from foot-and-mouth disease affected countries. But, the Regulations require that dairy products be imported from a country free of foot-and-mouth disease, or that the product "has been treated and on inspection is found to be safe". In an effort to minimize the risks of importing these dairy products, the program requires the exporting country to attest that specific heat treatments to inactivate the foot-and-mouth disease virus have been conducted. However, contrary to its Regulations, the program has not determined whether these imported products are actually safe - that is, that the required heat treatment was properly applied and the virus is actually inactivated.

8.81 Commercial cargo. Containerized overseas commercial agricultural cargo and settlers' effects are, at the port of entry, loaded onto rail cars and shipped across Canada to inland destinations based on a review of the shipping documents but with limited inspections to determine whether their contents pose any risk of animal or plant disease (see photo). Moreover, according to the Branch's internal audit reports, control over the movement and distribution of such containers for non-meat products at the inland receiving port is also weak. Settler's effects, according to a 1986 Animal Health directive, represent one of the most likely sources of foreign animal disease outbreak.

8.82 Training of inspectors. Training is of key importance if inspectors are to recognize significant animal diseases and plant pests and prohibit their introduction into Canada. In our 1982 audit of the Branch, we reported that the training of Plant Health inspectors was weak; five years later, we still found some training weaknesses. For example, import procedures manuals are only in draft form, and Branch officials were finalizing national policies, training modules, and standard accreditation for Plant Health inspectors. We met Plant Health inspectors clearly dedicated to their work who expressed difficulty in coping with the workload, frustration about the gaps in their training, and concern about how to meet the conflicting goals of facilitating trade on the one hand and meeting Canadian import requirements on the other. Plant Health officials have recently renewed efforts to correct the training weaknesses and will shortly be issuing operating manuals.

8.83 Liaison with Customs officials. A memorandum of understanding between the Departments of Agriculture and Customs and Excise was signed in 1985, setting out their respective responsibilities. Liaison continues and, in response to the recommendations of the Ministerial Task Force on Program Review, a study is under way to facilitate Customs' referrals to Agriculture. However, we found there were two gaps in the implementation of the memorandum of understanding. First, there are areas where the training Agriculture provides to Customs' officials could be improved. The approach is not consistent across the country; training objectives do not specify what the Customs employee should learn, and the trainee's learning is not assessed. Second, no performance measurement system has been implemented to determine Customs' effectiveness in carrying out the functions required by the memorandum.

8.84 Authorities. The Branch has found that the Plant Quarantine and the Animal Disease and Protection Acts and Regulations are outdated and require amendments to provide needed authorities for improved import control. These Acts do not provide a sufficient range of sanctions, nor do they provide authority for the Branch's current practice of cross-utilizing plant health inspectors to conduct animal health inspections at ports of entry. While the Branch has recognized these problems, and has proposed amendments for several years to the Acts, they remain in draft stage. Branch officials expect that these amendments will be made in the near future.

8.85 The Branch should:

    - conduct commodity and pest specific assessments to fully determine the risks of introducing plant or animal diseases into Canada;
    - strengthen training and inspection resources in import areas of higher risks;
    - increase its laboratory testing for plant pests.
Management's response: We agree that the work which has commenced to assess specific commodity and pest risks should be completed. At present, the Branch's pest risk assessment process is based on international risk assessments combined with the expertise of our professional officers. The Branch will continue its work in this area to complete documentation of risk assessment by commodity and country of origin.

We agree, and the Branch will enhance its training program through the preparation of inspection manuals and self-instructional training modules. The manuals will be completed by September 1989, with training modules being produced by September 1990. With respect to inspection, the Branch has provided its import inspectors with a simple information base on Canada's import requirements for plants and plant products. This computerized system is now available on their monitors at the ports of entry and the inspectors have been trained in its application.

We agree, and the testing capabilities of the Plant Protection laboratory network are being strengthened by the establishment of additional Plant Health laboratories. The Branch will continue to examine possibilities for application of further resources in this area.

8.86 The memorandum of understanding with Customs and Excise should be implemented, including improvement of the training provided by the Department of Agriculture to Customs officials and implementation of a performance measurement system to determine Customs' effectiveness in carrying out the functions outlined in the memorandum.

Management's response: the Branch agrees that the Memorandum of Understanding with Customs and Excise should be implemented insofar as it relates to improved training and co-operation. The intent of the Memorandum will be further supported by simplifying the demands made on Customs, and by streamlining Agriculture's inspection procedures at ports of entry.

8.87 The Branch should discontinue any import practices that do not comply with the Regulations, and the Plant Quarantine and the Animal Disease and Protection Acts and Regulations should be amended on an urgent basis to provide needed authorities.

Management's response: We agree, and the Branch has drafted amendments to strengthen the Plant Quarantine and Animal Disease and Protection Acts. Further, the Branch will ensure that all plant and animal import practices are in compliance with the Acts and Regulations.

Preventing, Controlling and Eradicating Plant and Animal Diseases

8.88 Our audit also examined Plant and Animal Health practices with respect to program delivery in relation to the Branch statements of objectives directed at improving the health of Canada's plant and animal resource base. These objectives are:

    - control and eradication of exotic diseases, insects, weeds and other dangerous entities of plant or animal origin which gain entry; and
    - prevent/control/eradicate domestic animal and plant diseases of economic and human health significance.
8.89 Plant diseases. The intent of Plant Health's disease control program is to prevent the spread of a plant pest likely to cause significant damage. Although we noted a few initiatives to control plant pests, we found there was little in the way of program delivery to halt the spread of the many plant pests in Canada, some of which are outlined in Exhibit 8.4.

Exhibit not available

8.90 For the most part, the Plant Health program only monitors where these diseases are. While foreign pests exist in Canada, the program has a limited process for deciding what to do, or when, where and how to do it. Authorized contingency plans are not in place, and any eradication and control measures are usually taken in co-operation with provincial authorities, and are limited. The Plant Health program has not fully quantified the economic losses caused by plant pests in Canada, as a basis for identifying priorities or developing a national strategy. We found incomplete information about the economic significance of some of these plant diseases as described in Exhibit 8.4. Also, we found that the Plant Health program does little to control the interprovincial movement of plant material in Canada. Also, more could be done to inform industry of regulatory requirements for transporting plant products within and between provinces of Canada.

Exhibit not available

8.91 We found only a limited integrated pest management strategy at work to control plant pests and diseases within Canada. Such a strategy would combine research priorities and quarantine activities and incorporate various pest control tactics. Through such a strategy it might be possible to encourage greater reliance on biological and cultivation control techniques in combination with the use of pesticides. We believe this limited strategy results, in part, from failure to carry out complete pest risk assessments and lack of co-ordination between the Plant Health and Pesticides programs. Steps have been taken in an effort to improve internal communication.

8.92 The Branch should co-ordinate its plant pest control functions to ensure that domestic plant disease control programs are focussed on plant pests of highest risk and significance.

Management's response: We agree with this recommendation, and the Branch is currently reviewing all domestically regulated plant pests for risk and economic significance. Closer co-operation with the provinces in the area of domestic pest control is also being pursued. A national meeting in September 1990, between federal and provincial departments of agriculture to formalize an integrated domestic pest control program is planned.

8.93 Animal diseases. The Animal Disease and Protection Act provides the Animal Health program with extensive powers to prevent, control and eradicate animal diseases. As well, the Branch's stated objective is to prevent, control and eradicate domestic animal diseases of economic and human health significance. The program received international recognition in 1985 for eradicating brucellosis in Canadian cattle and is close to eradicating cattle tuberculosis. Both are serious animal diseases that pose a threat to human health. Also, it has eradicated some foreign animal diseases that gained entry into Canada. However, a recent internal study found that there is no program involvement in most domestic animal diseases considered significant by industry. These include domestic diseases of cattle, swine, poultry, sheep and goats which can affect export trade opportunities and, in two cases, may also affect public health. Livestock losses from animal diseases were estimated by the Science Council in 1985 at $1.2 billion annually.

8.94 To date, the Animal Health program has compiled only limited information on the incidence, epidemiology and related economic losses of significant animal diseases. It is currently piloting a national disease information system which, if implemented as planned, would systematically collect data that could be used to identify priorities for disease control at the national, provincial or producer level.

8.95 We are not suggesting that any one method of controlling animal diseases, such as that used for brucellosis, is necessarily the most appropriate. We would, however, expect the program to document its assessment of the significance of each animal disease of concern in Canada, whether it should or should not be prevented or controlled and, if the prevention or control option is selected, how this could best be achieved. We were advised that no such documentation is available. In light of the Branch's objective, we found differing views in the Branch and among outside experts as to whether there were significant animal diseases that warranted federal intervention. We were further informed that in one view of the Branch the control of domestic animal disease is considered to be primarily a private sector responsibility. If the program is no longer attempting the control of significant domestic animal diseases, it should advise Parliament of this and the reasons, and amend its objectives and resource requirements accordingly.

8.96 To carry out its stated objective, the Branch should clarify and communicate the direction of the Animal Health program with respect to significant animal diseases in Canada.

Management's response: We agree, and the Branch's animal health business statement will be revised and communicated during future consultative meetings on animal diseases.

8.97 Animal disease vaccines. We reviewed the licensing of veterinary biologic products, mainly bacterial and viral vaccines to combat animal diseases. Under the Animal Disease and Protection Act, the Animal Health program has a mandate to ensure that the safety, potency, purity and efficacy of these products is established. However, we found that licenses have been issued and renewed for many products whose efficacy under farm and feedlot conditions has been widely disputed in the scientific literature over many years, notwithstanding that they were tested in a laboratory setting. These disputed products comprise a large proportion of the licensed cattle and pig biologic products. Although the legislation requires annual relicensing, the program does not take the opportunity to require manufacturers to submit additional data to dispel the concerns about product efficacy.

8.98 In 1979, a Branch committee recommended that a laboratory be established to test the safety, potency, purity and efficacy of veterinary biologics and that criteria for field trials be revised. After seven years, a small facility was set up with the expected capacity of one field test a year. Two years later, the first efficacy field trial has yet to begin, although it is now expected in the next two years.

8.99 We also found a long-standing lack of jurisdictional clarity between the Departments of Agriculture and National Health and Welfare over the registration of biologics produced by biotechnology or genetic engineering. New techniques of genetic engineering are expected to result in both large advances and large increases in numbers of vaccines and drugs for animals. Yet the jurisdictional issues between these two departments have remained unresolved for some years. A private company wishing to register its biotechnology products for the Canadian market has had to apply to both departments because of the lack of clarity about who is responsible.

8.100 The Branch should clarify its policies and develop guidelines to specify the extent to which it will be involved in testing veterinary biologic products under farm and feedlot conditions. It should also work with Health and Welfare to resolve jurisdictional issues for registering biotechnology products.

Management's response: We agree, and the Branch will reassess and clarify its policy and guidelines with industry and Health and Welfare at the next consultative meeting on veterinary biologics.

Inspecting and Certifying Agricultural Exports

8.101 The Branch's objective in this area is to provide the inspection and certification required for the export of billions of dollars of agricultural, food and forestry products, as outlined in Exhibit 8.5, for conditions specified by the importing country. There appears to be confidence in Canada's export certification system, and new markets have been established. We selected for audit the Branch's export certification process for forest and agricultural products.

Exhibit not available

8.102 Effective plant pest control cannot be achieved without international co-operation. A high degree of interdependence, where seller protects buyer, underlies the International Plant Protection Convention (IPPC), adopted by the Food and Agriculture Organization of the United Nations in 1951. It replaced a series of international agreements dating back to 1881. Canada played a key role in establishing the first IPPC, which was ratified in 1953.

8.103 The primary objective of the convention is to prevent the spread of plant pests, in part through an international system of phytosanitary (plant health) certification. This requires each government to inspect its agricultural and forestry exports and attest to the absence of plant pests of particular concern to member importing countries. The IPPC was updated in 1979, largely as a result of Canada's initiatives, to cover non-propagative plant material such as grain, which was previously excluded, and to establish a model health certificate. Plant Health inspectors issued some 40,000 certificates in 1987, without which valuable exports of Canadian agricultural and forestry commodities would not have been possible. This is a considerable workload and responsibility.

8.104 We found that, for the most part, the Plant Health program provides the inspection and certification services for agricultural and forest products in accordance with the international convention. Certain practices, however, need to be strengthened to meet the requirements of the convention. The extent of these problems has not yet been fully investigated by the Plant Health program.

8.105 Until a few years ago, trade sampling, where exporters provide samples of their own product to the Plant Health program for inspection, was common in the export of certain commodities. However, it conflicts with the IPPC, since private sector employees are not formally authorized to sample, and there is potential for abuse because the sample cannot be verified. Although the program has reduced its reliance on trade samples, some work remains to be done to eliminate them.

8.106 According to the IPPC, inspections are to be carried out and certificates issued only by or under the authority of qualified and authorized officers. However, we found variations in certification procedures, an absence of comprehensive inspection guidelines, and lack of control over the documents themselves. For example, we noted instances where blank certificates were provided to exporters for completion, with varying degrees of control over their use. Also, some certificates were dated after shipments arrived at their destination or were signed by an unauthorized officer, raising questions of whether inspections were actually carried out. We also noted instances where certificates were altered by third parties after completion and became invalid. Commercial information was sometimes added, quantities changed or special treatments indicated.

8.107 Despite efforts to keep up with information from foreign countries, agriculture inspectors in the field are not always provided with current and concise descriptions of the import requirements of Canada's trading partners. As a result, officers who issue certificates have some difficulty in keeping abreast of what pests are of current quarantine significance to the importing country.

8.108 Although the IPPC intends that plant health certificates be used only as documents from one plant protection service to another, relating to removing biological barriers to trade, certificates are commonly used for purposes unrelated to basic plant health concerns. For example, they are used to satisfy letter of credit requirements or as additional security for shipments. The Plant Health program has not, as yet, developed a complete policy to guide inspectors faced with such commercial uses of phytosanitary certificates. Such a policy would outline an appropriate balance between facilitating trade and preventing the spread of plant pests.

8.109 The Branch should further develop policies and procedures for issuing phytosanitary certificates and ensure compliance with them. Control over these documents should be strengthened.

Management's response: We agree, and the Branch's current inspection directive on the issuance of phytosanitary certificates is being updated, and a self-instructional training module is being developed. Finally, an audit program for reviewing phytosanitary certificates issued to client countries is being prepared. All this work will be completed by April 1, 1989.

8.110 The Branch should improve and implement systems to provide plant health inspectors with current descriptions of the import requirements of Canada's trading partners and guidance in the use of such information.

Management's response: We agree, and the Branch has now completed a comprehensive registry of import requirements for Canada's major trading partners. Inspectors at all ports of entry have been provided with the proper equipment and training necessary to access and interpret this information. Updates to the central computer registry can be made instantaneously.

Information to Parliament

8.111 Part III of the Estimates offers an opportunity to communicate to Members of Parliament and the public assurance about food quality and safety as well as animal and plant health and disease control. We examined the information provided in Part III of the Estimates and found that it is often ambiguous and inadequate in terms of reporting on the achievement of results.

8.112 The Branch has stated the results it expects to achieve, and approaches for measuring these, in its Operational Plan Framework. However, Part III provides insufficient data on their achievement. For example, in relation to the Branch's objective "to prevent, control and eradicate domestic animal and plant diseases of economic or human health significance", little information is provided to help the reader answer questions such as:

    - What is the incidence of domestic animal and plant diseases of concern in Canada? Which are the most significant?
    - What has been their impact on the agricultural community, export trade and human health?
    - Which diseases is the Branch seeking to prevent, eradicate or control and against what targets?
    - What success has been achieved in these areas?
8.113 In fact, because of its objectives, the Branch should but does not have much of this information. For the most part, Part III simply describes the various inspection programs and future plans for them. It does not provide program performance data in relation to intended results on a basis consistent from year to year to facilitate meaningful comparisons or accountability.

8.114 Also, some information provided in Part III is not correct. For example, the 1987-88 document states that "Agriculture Canada has evaluated the testing requirements which would ensure that residue levels in meat, dairy, fruit and vegetable products are within acceptable levels". Again, in 1988-89, Part III states that "residue testing will continue to be a high priority for such commodities as meat, dairy, fruit and vegetables". Our audit found that Branch residue testing procedures are not sufficient to provide reasonable assurance that residues and other chemical or bacterial contamination in domestic food and agricultural products are detected, prevented or removed. Also, we found that very limited residue testing had been undertaken for fruit and vegetables, imported or domestic, in 1987-88 or before.

8.115 The 1987-88 and 1988-89 Part IIIs summarize positive effectiveness results of program evaluation studies, but with no discussion of the studies' limitations. For example, for Meat Hygiene, the 1987-88 Part III states that: "public expenditures on Meat Hygiene activities have generated benefits over the 1970-84 period of $22.5 billion (in 1984 dollars) ... the overall ratio of benefits to costs was 10:3". However, we found the basis of these net benefit calculations was limited to a comparison between no Meat Hygiene program and the status quo. Estimating the nature and magnitude of price changes and production levels in the absence of any program is questionable.

8.116 In continuing the development of better Part III of the Estimates, the Branch should provide clear data on program achievements in relation to objectives, on a basis consistent from year to year.

Management's response: The Department agrees with this principle, and is committed to providing accurate, clear and reliable data to Parliament. Future submissions to Part III of the Estimates will be reviewed to ensure that clear relationships to program objectives and consistency with previous reports are demonstrated.


Mr. Kenneth Dye

Office of the Auditor General

240 Sparks Street

7th Floor, West Tower

Ottawa, Ontario

K1A 0C6

Dear Mr. Dye:

This concerns your audit report on our Food Production and Inspection Branch. I wanted to make some general observations to emphasize points made in particular management responses.

The Department appreciated very much your favorable comments on the dedication and high international reputation of the management and inspection staff in the Branch. We have worked very hard to achieve that level of competence and it is encouraging to have it recognized so prominently.

It would probably have been helpful to point out that implementation of the total package of recommendations in the report would require significant increases in resources. Knowledge of this fact is important if we are to make informed judgements on the degree of risk that would be acceptable.

A recurring theme of your report is that resources should be allocated on the basis of risk. We agree entirely. However, the fact that the Branch has already made substantial reallocations to higher risk food safety areas does not seem to have been emphasized. There is also plenty of room for honest differences of opinion in the ranking of various risks.

Agriculture Canada is only one of the components in food inspection in this country. This responsibility is shared with several federal departments including Fisheries and Oceans, Health and Welfare, and Consumer and Corporate Affairs, as well as provincial and municipal jurisdictions. The interdependency of food inspection services could have been more completely addressed by broadening the scope of your audit. This would have allowed you to recognize more fully the accomplishments realized in this difficult environment.

We would have also appreciated your acknowledging the Branch's shift in emphasis from quality assurance to food safety in its business statements some two years ago. These statements have provided clear, precise messages both to industry and inspection staff.

The Department agrees with you about the direction in which we should be heading. I am simply concerned that the public realize we are farther down the road than your report might lead them to believe.

Thank you for providing me with this opportunity for comment.

Yours sincerely,

Jean-Jacques Noreau


Mr. Kenneth Dye, F.C.A

Auditor General of Canada

240 Sparks Street

Ottawa, Ontario

K1A 0G6

Dear Mr. Dye:

The Assistant Deputy Minister Food Production and Inspection Branch Agriculture Canada provided the Department with a copy of your draft chapter. Although the mandate is covered in the chapter, upon reading it, I feel that the following brief but concise passage would more clearly define my Department's mandate and role.

The food regulation and inspection system is the responsibility of several federal and provincial agencies.

With respect to food safety, in 1986 the government reaffirmed the absolute primacy of the Minister of National Health and Welfare in all matters affecting health, safety and nutrition. At the same time, the Department of Agriculture was directed to introduce regulatory amendments to adopt by reference under its statues all relevant health and safety regulations under the Food and Drugs Act in order to reduce, and eventually eliminate, any inconsistencies and contradictions in federal regulations. With respect to the regulation of food safety and health in establishments registered by the Department of Agriculture, a "single federal contact department" approach was adopted. National Health and Welfare establishes guidelines and standards under the Food and Drugs Act, and carries out inspection audits. Agriculture Canada conducts the ongoing inspections (in non-registered plants Health Protection Branch carries out its own inspection activity). An interdepartmental Committee of Deputy Ministers responsible for food regulation and inspection was also established under the chairmanship of the Deputy Minister of National Health and Welfare to improve coordination and reduce inconsistencies in federal regulatory activities.

These program and policy decisions were taken to maintain and enhance Canada's reputation for excellence in food production.

Yours truly,

Maureen Law