Do Regulations Make Food Safe?

Generally, farmers are not big fans of increased regulations and are always pushing for a streamlining and reduction of regulations. Some farmers and operators in Canada have more influence over this effort than others. And that really shows up in the proposed Safe Food for Canadians regulations.
The Safe Food regulations will streamline food safety regulations for producers who are required to be Canada GAP or HACCP certified. But how will it affect the rest of us? And how it will affect organic operations differently?

There are a few different aspects to think about.

1. The Canada Organic Regulation will fall under the Safe Food Regulation. This does not mean the Organic Standards will change (the organic standards can only change with a full review from the whole 46-member, consensus-based Organic Committee which is made up of farmers, processors, consumers, retailers, extension specialists and other farm support people). The Organic Regulation is the part that sits within the government (CFIA). They still need to have public consultations before they change the Organic Regulation but they’ll need to hear a lot of voices to take our points of view into account.

2. Because the Organic Regulation will fall under this new Safe Food for Canadians Act, the government (CFIA) has proposed some changes to it. Some are good and some not so good. This is also our chance to propose other changes that we want made to the Organic Regulation.

a. Good: Aquaponics that can be called Organic are being limited to ‘aquatic species’ which they’ve defined as plants that would naturally grow in water. This means that land-based plants like lettuce, basil, tomatoes, chard, kale, etc could not be grown aquaponically and called Organic. This is in line with the fact that hydroponics in Canada cannot be called Organic. The Canadian Organic Aquaculture industry is planning on fighting this one and letting the land-based crops that are grown aquaponically be called Organic. If you feel strongly that land-based plants should not be allowed to be called Organic if grown in an aquaponic system, let the CFIA know that you support their proposed definition of the term aquatic species and that organic aquaponics only include these aquatic species.

b. Not so good: The proposal is that ‘various activities’ within the organic food chain be required to be certified organic. This would include ‘conveyance systems’ or transportation. And slaughterhouses. So, for organic grain farmers, who currently get trucking companies, VIA rail, or shipping boats to transport their product – these transportation companies would be required to become certified organic. Right now, they need to clean out their containers and sign affidavits, but they don’t need to become certified organic. Same with slaughterhouses. Do you think they’ll certify organic? It’s highly unlikely. Unless we can change this, this could really hurt the organic livestock and grain sectors. As a few organic farmers from across the country have said, ‘this feels like an attack on the organic sector!’

c. What might we want to change: No one in the organic sector thinks that the Canada Organic Regulation is perfect. And there have been things that folks have wanted to change for many years. Since the CFIA wants to change things now, this could be a great opportunity to suggest some changes. Like what? Well, imagine there was an allowance for some operators to be deemed ‘low-risk’ and then be inspected only every 2nd year? That could reduce a lot of cost to certify. And it could increase the number of small-scale farms in particular who decide to certify.

Besides the issues to organic operators, there are other things you might want to think about and comment on.
1. Right now, the Safe Food regulation says that anyone crossing a provincial border will need a Preventive Control Plan (PCP) unless their gross sales are under $30,000 per year. Why did they come up with this number? We can assume because of people asking for scale-appropriate regulations. So, it’s great that they’re listening to that. But sales revenue per year isn’t necessarily the best indicator of size of farm. Especially because there are differences in how much a farm might make per year based on what they produce. There are many small, 1 -acre vegetable or fruit farms across our country that make more than $30,000 in sales per year. Should these farms not be considered small farms?

2. Based on the outcome hoped for by the CFIA of increased transparency, direct-marketing farms should more appropriately be exempted from needing a PCP. Farms that direct-market are the leaders in a transparent food system. There are many communities across Canada that reside near provincial borders. In particular, here in Atlantic Canada, our provincial borders are closer given the smaller size of our provinces.

3. Why should a small, direct-marketing farm that crosses a provincial border be required to follow stricter regulations than a much larger farm with many more employees that sells within provincial borders?

4. What is a PCP? A Preventive Control Plan is basically a food safety plan a farm must follow that is quite similar to already existing Canada GAP or HACCP plans. As an example of how this might affect a 1-acre farm that direct markets all of its products where all the labour is provided by the farm owners (no employees): they would require a wash station that is fully enclosed, single-use towels (paper towels that are then thrown away) to dry hands at hand-washing sink throughout harvest, cleaning schedule and chart for bathroom and cooler to be signed, no twist top water bottles used for drinking unless hands washed between each drinking episode.

5. What about a license? So far, it is vague on what activities would require a license. It is possible that any rinsing, washing, or trimming of produce would be referred to as ‘processing’ and then would require a license. Not great for vegetable farms that rinse off their carrots for display at farmers’ market or for anyone growing salad mix who is trimming the tops off the lettuce plants to sell as mesclun.

As you can see, there are a lot of issues jumbled into this one regulation. It seems very confusing to sort through it all (unless you have lawyers to do it for you). The CFIA has been saying that their information is written in ‘plain language’ but, without real-life examples, it’s not super clear.

We only have until April 21st to send CFIA our thoughts on what changes we would like to see. We should send them comments as individual farmers, as organizations, and as groups of operators. As many as we can. They have said that each submission’s issues will be discussed and addressed by their staff. Phrases like ‘impact on my livelihood’ can be great motivators, as can specific dollar figures (though don’t let lack of knowledge of this impede you just giving your comments).

To comment, here’s the link: http://www.inspection.gc.ca/about-the-cfia/acts-and-regulations/regulatory-initiatives/sfca/consultation/have-your-say/eng/1482239403639/1482239479767

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Above:  Shannon Jones of Broadfork Farm

Further reading for some of these issues brought up:

On how it will affect organic farmers specifically:
Canada Organic Trade Association (COTA) recorded webinar. COTA hired lawyers to go through the proposed regulations and they brought up some issues they found at this webinar. There were also a lot of great questions and comments at the end by people from across Canada in the organic sector. Most surprising: There were many who were for slaughterhouses being certified organic, as well as many against. The link: http://us8.campaign-archive1.com/?u=f64400aad0f09f97483d2c4d3&id=37460b077b&e=ee9c820d35

You can also read COTA’s comments here: http://us8.campaign-archive1.com/?u=f64400aad0f09f97483d2c4d3&id=5f30b93732&e=f4dbf299e3
Aquaponics: Not enough people are talking about this one yet (except the Organic Aquaculture industry who really want Organic Aquaponics of land-based plants). The Organic Federation of Canada (OFC) polled people last year about their thoughts on this issue: https://ofcfbc.wordpress.com/2016/05/24/aquaponics-an-organic-production-system/

On how it will affect farms generally:
Find out if your farm/operation would need a Preventive Control Plan (PCP): http://inspection.sondages-surveys.ca/surveys/CFIA-ACIA/would-you-need-a-pcp/?l=en

Find out if your farm/operation would need a license: http://inspection.sondages-surveys.ca/surveys/CFIA-ACIA/copy-would-you-need-a-licence/?l=en
Tim Livingstone’s open letter to the CFIA: http://cumberlandfoodactionnetwork.ca/public-consultation-to-all-farmers-and-consumers/

Learn more about how it might affect you: http://www.inspection.gc.ca/about-the-cfia/acts-and-regulations/regulatory-initiatives/sfca/consultation/learn/eng/1427299500843/1427299800380

Guest Blog by: Shannon Jones

Shannon owns and operates Broadfork Farm in River Hebert, NS, with her partner Bryan. As a volunteer board member for a number of farming organizations, including the Cumberland Food Action Network, ACORN, the Organic Federation of Canada and the Canadian Organic Growers, she often has the opportunity to hear many different perspectives on issues that affect farmers and eater. She tries her best to share her perspective on her farm Facebook page: http://www.facebook.com/BroadforkFarm

Adventures in Local Food is your source for food news in Nova Scotia, from pickles to policy. It is a project organized by the Ecology Action Centre .Learn more about our program at https://www.ecologyaction.ca/ourfood

Or follow us on:
Twitter: @OurFoodProject
Facebook: The Ecology Action Centre

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