Roles and Responsibilities CFIA Linda Leblanc & Adrienne Kong Foodborne Diseases Investigation & Management: An Ontario Symposium March 1, 2010

© 2007 Her Majesty the Queen in Right of Canada (Canadian Food Inspection Agency), all rights reserved. Use without permission is prohibited.

Canadian Food Inspection Agency – Food related mandate 

CFIA’s mandate: “safeguarding food, animal and plants…”

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CFIA is responsible for the enforcement of the Food and Drugs Act (FDA) as it relates to food,

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and the administration of the provisions of the FDA as it relates to food except those that relate to public health, safety or nutrition

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Legislation (1)

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CFIA enforces or administers 13 Acts and Regulations related to plants, animal or food

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In food safety investigations, CFIA inspectors mainly apply the Food and Drugs Act

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Legislation (2) – FDA – Section 23 – Powers of Inspectors Power         

Section

Enter and inspect 23(1) Open and examine containers and receptacles 23(1)(b) Take samples 23(1)(a) Examine and make copies of documents 23(1)(c) Seize and detain articles 23(1)(d) Enter a conveyance and examine articles & take samples of product 23(1)(a.1) Enter a dwelling-place with the consent of the occupant or under the authority of a warrant 23(1.1) Direct storage and removal of a seized thing 25 Use of force when executing a warrant 23 (1.3)

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Legislation (3) 

Canadian Food Inspection Act, Section 19.(1) • “…Where the Minister believes on reasonable grounds

that a product regulated under an Act or provision that the Agency enforces or administers by virtue of Section 11, poses a risk to public, animal or plant health, the Minister may, by notice served on any person selling, marketing or distributing the product, order that the product be recalled or sent to a place designated by the Minister.”

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The Recall Process

Trigger

Recall Effectiveness Verification

Food Safety Investigation

Recall Implementation

Health Risk Assessment

Recall Decision-making

Corrective Action/ Follow-up

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Involvement with Outbreak Management – Food Safety Investigation 

Conducted to determine the nature, extent and the cause of the problem  Intended to confirm whether a health hazard exists  Support to the outbreak investigation: traceback from all levels of distribution, plant inspection, importer inspection  Ad hoc inspection activities:  Process review, plant practices observations, processing

records review, document review, equipment inspection, etc.  Bracketing the problem (when it started / ended)

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Involvement with Outbreak Management – Food Safety Investigation: Traceback 

Systematic process used to follow the food in the distribution system from the consumer to the manufacturer, importer or to the raw material’s origin if needed  Traceback challenges:  Product information, i.e. manufacturer label, retail label,

unlabelled product  Retail practices, i.e. repackaging, multiple suppliers, record keeping, inventory practices  Manufacturing practices, i.e. rework, co-mingling, mixed codes in shipments  Jurisdiction, i.e. domestic or imported

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Involvement with Outbreak Management – Sample Collection & Lab Testing 

Samples are obtained at all levels of distribution including the consumer/complainant, retailer, institutions, distributors, importer and producer/manufacturer

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Samples may also be provided by other government departments or industry (e.g. retention samples)

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Types of samples: open, unopened and retention samples

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Unopened samples are preferred in order to limit external contamination of the sample

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Sampling is conducted according to appropriate procedures and using aseptic techniques and equipment

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Involvement with Outbreak Management – Recall Decision (1) 

Based on a Health Risk Assessment from CFIA technical specialists and/or Health Canada 

where standards exist, the CFIA Technical Specialist usually conducts the HRA  where no standards exist, the CFIA Technical Specialist requests that Health Canada conducts the HRA

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May be based on an epidemiological assessment

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Decision will take into account additional factors, for example:  Susceptible population  Product distribution / availability at the consumer’s home

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Involvement with Outbreak Management – Recall Decision (2) 

There are various factors that can delay HRAs:       

Incomplete information Changing/conflicting or unclear information Establishment of an epidemiological link Laboratory tests Trace back or trace forward investigations Information from a foreign manufacturer or authority Complexity of the issue

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Involvement with Outbreak Management – Recall Decision (3) 

Office of Food Safety and Recall (OFSR) determines the Class and Depth of the recall  

3 classes of recall based on the level of health risk: Class I, Class II, Class III 3 level of action: warehouse, retail, consumer

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Most recalls are voluntarily conducted by the industry

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Mandatory recall may be used if the recalling firm cannot be reached or identified, or refuses to conduct the recall

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Beyond serving of the mandatory order, a voluntary or mandatory recall mostly involves the same steps in the marketplace

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Involvement with Outbreak Management – Recall Implementation 

Recalling firm has the responsibility of conducting the recall and for ensuring that its actions have been effective in removing the product from the marketplace

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Recalling firm identifies and notifies accounts of recall

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Recalling firm provides clear instructions for disposition of recalled product

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Each point along the product distribution chain (including wholesalers, distributors and retail stores) has the responsibility of removing the affected product when advised of a product recall

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Involvement with Outbreak Management – Monitoring Recall Effectiveness 

100% effectiveness checks of all retail outlets are not part of the process due to the sheer magnitude of the task

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Statistical sampling plans are used to monitor the recall

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Objective is to verify that the selected accounts were adequately notified of the recall and have removed the product

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Information is used to assess the effectiveness of the recall and take further action if not satisfactory

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Internal Communication 

Within CFIA, an outbreak-related food safety investigation is coordinated by the OFSR

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Contact with local or provincial public health authorities is established by the CFIA Area Recall Coordinator (ARC) or a CFIA inspector

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Food safety investigation updates are shared on a regular basis with the outbreak coordinating committee

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CFIA will work collaboratively with the outbreak coordinating committee to identify gaps in information and to determine investigation avenues

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External Communication 

CFIA communications will focus on the food aspect

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In outbreaks, CFIA issues Health Hazard Alerts to advise the public not to consume an identifiable food product

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CFIA provides Health Hazard Alerts to media newswire services and to CFIA web subscribers

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CFIA spokespersons will answer media interview requests

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General communication strategy is established by CFIA Public Affairs division 16

Traceback and Traceforward Investigations of Food Items in a Foodborne Outbreak Investigation 

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Traceback: a method to determine and document with a high degree of confidence the origin and distribution of a particular food; focus is on the food Traceforward: a method to determine and document with a high degree of confidence the distribution and final destination of a particular food; begins at any identified point of distribution Document outlines the roles and responsibilities of various government stakeholders, the recommended lead agency, and their respective legislation Developed by the multi-agency working group Guidance document only 17

QUESTIONS?

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