Evaluation of the Canadian Integrated Food Safety Initiative

November 4, 2014

Office of Audit and Evaluation

List of Acronyms

AAFC: Agriculture and Agri-Food Canada
APF: Agricultural Policy Framework
ATQ: Agri-Traçabilité Québec
BSE: Bovine Spongiform Encephalopathy
CBWA: Canadian Bottled Water Association
CCA: Canadian Co-operative Association
CGC: Canadian Grain Commission
CFIA: Canadian Food Inspection Agency
CHC: Canadian Horticulture Council
CHSNC: Canadian Herb, Spice and Natural Health Product Coalition
CPMA: Canadian Pari-Mutuel Agency
CIFSI: Canadian Integrated Food Safety Initiative
CLTS: Canadian Livestock Tracking System
FSMA: Food Safety Modernization Act
FSRP: Food Safety Recognition Program
GFSI: Global Food Safety Initiative
HACCP: Hazard Analysis and Critical Control Points
IGAC: Industry Government Advisory Committee
MISB: Market and Industry Services Branch
MOU: Memorandum of Understanding
NAFTS: National Agriculture and Food Traceability System
OFFS: On Farm Food Safety
RFID: Radio Frequency Identification technology
TFC: Turkey Farmers of Canada
TNIP: Traceability National Information Portal

Executive Summary

This document constitutes the final report of the Evaluation of the Canadian Integrated Food Safety Initiative (CIFSI), whose primary purpose is to support the economic growth of the agriculture and agri-food sector and to provide assurances relating to the safety of the food Canadians are consuming. The evaluation is conducted in accordance with the federal government’s Policy on Evaluation and it focuses on the relevance of the CIFSI and its performance over the five-year period covered by the Initiative, which is from 2008–2009 to 2012–2013.

Description of the Initiative

National Food Safety Systems Development focused on developing food safety systems by national organizations, as well as the Canadian Food Inspection Agency’s (CFIA) On–Farm and Post-Farm Food Safety Recognition Program (FSRP). Food Safety Systems Development is primarily a continuation of what was delivered under the APF. Through the CIFSI, Agriculture and Agri-Food Canada (AAFC) signed contribution agreements with national organizations to provide financial support for the development or enhancement of food safety systems. These systems could cover both on-farm and post-farm activities. The range of activities that could be funded under this component included the development of Hazard Analysis and Critical Control Points (HACCP)-based food safety models and programs, producer manuals, work books, training and audit manuals and CFIA recognition process. Once a food safety system has been established, the sponsoring organization could decide, based on industry/sector requirements to have its system formally recognized by the CFIA.
National Biosecurity Standards Development focused on developing standards specific to biosecurity (CFIA-led); it responded to a need identified through the review of the APF. AAFC signed a Memorandum of Understanding with the CFIA to develop nationally consistent plant and animal biosecurity standards. These standards were developed in conjunction with industry, national commodity organizations and provinces to mitigate risks to the plant and animal resource base.
Developing National Traceability Systems focused on developing traceability processes and systems through national organizations. The positive results of a pilot project implemented under APF, led to expanded traceability activities under GF. In addition, the first elements of a National Agriculture and Food Traceability System (NAFTS) were put in place incrementally, starting with livestock and poultry. The scope of activities undertaken during the CIFSI included the definition of technological requirements, the establishment of the legislative and regulatory framework and the support for the actual development of traceability systems.

AAFC with support from the CFIA led the systems/standards development at a national level while AAFC’s cost-shared programming supported the work of provinces, territories and producers on the implementation of these systems/standards at the farm level.

Financial resources

The federal government allocated $107 million ($60 million in Vote 1 and $47 million in Vote 10) over five years (2008-2009 to 2012-2013) in support of the CIFSI.

Methodology

To assess the performance of the CIFSI, the evaluation included the following tasks:

Document review: A document review was undertaken to examine information related to the relevance of food safety, traceability, and biosecurity in the context of trade, risk management/mitigation, consumer/market expectations, and government priorities. Other documents provided information related to the performance of the Initiative, including the review of the CFIA’s components of CIFSI.
Literature review: A literature review was conducted to provide information on Canadian food safety, traceability, and biosecurity within a global context.
Data review: An analysis of program administrative and performance data was undertaken to assess the results and resource utilization of AAFC’s Food Safety Systems Development and Industry Traceability Infrastructure. In addition, data from Statistic Canada’s Farm Financial Survey related to producer participation in HACCP-based food safety programs was reviewed.
Interviews: 38 key informant interviews were conducted, including 13 industry representatives, 12 federal government representatives, 10 representatives of provincial governments, and three external experts. The evaluation team consulted with the Market Access Secretariat of the Market and Industry Services Branch for information related to the extent to which food safety and traceability had afforded market opportunities for the Canadian sector.
Case studies: Six case studies were undertaken of CIFSI projects including: three food safety, two traceability, and one biosecurity case study.

Evaluation Findings

Relevance of the CIFSI

Evaluation findings confirm the pivotal role that food safety and traceability systems play for market access and growth of the Canadian agriculture and agri-food sector. With exports standing at over $35 billion annually and a market that remains highly concentrated, Canada must be able to meet its commercial partner food safety and traceability requirements.

In addition to securing critical economic markets, food safety initiatives also provide assurances to Canadians that the food they acquire does meet standards relating to food safety.

The CIFSI directly supported the set of strategic goals pursued by AAFC and the CFIA under Growing Forward.

Effectiveness

The CIFSI has transformed the overall environment in which the agriculture and agri-food sector is currently operating. Through the financial support provided by the CIFSI, major components of the agriculture and agri-food sectors have succeeded in developing or enhancing their respective food safety systems. In terms of animal and commodity traceability, through the funding provided by the CIFSI, several commodity sectors in addition to the cattle sector have initiated preparatory work and developed or enhanced their traceability systems. Canada is now well-positioned to meet food safety requirements from trading partners in addition to managing food-related incidents triggered by contamination. Due to the development of HACCP-based food safety systems, Canadian grain producers have been able to meet the requirements of the United Kingdom; pork producers have had easier access to the Asian market; and Canada has secured the Japanese market for honey-related products. Traceability efforts have contributed to allowing the beef sector to regain United States and Asian markets it had lost due to the Bovine Spongiform Encephalopathy (BSE) outbreak and meet the proof-of-age requirement applicable to cattle aged 30 months or less, which is required to enter the Japanese market^{Footnote 1}. In regards to managing food-related incidents, a control point near the Manitoba and Ontario borders to control movement of animals and their products during a foreign animal disease outbreak was recognized by the United States in 2013.

Activities undertaken through the CIFSI have allowed for targeted outputs associated with food safety systems, traceability systems, and biosecurity standards to be produced.

What has yet to be fully measured and evaluated is the extent to which all these outputs have contributed to the agriculture and agri-food sector’s achievement of the CIFSI’s economic goals. As there are currently limited regulatory requirements for these systems in Canada, the vast majority of systems and standards established to date are voluntary, market driven standards. In addition, under Growing Forward, the policy and program support to facilitate implementation of these systems and standards are a provincial responsibility. The early data on participation indicate that it varies widely across sectors, with larger export oriented producers, and supply managed systems, being more likely to have adopted these types of systems and standards.

It is unlikely that the progress achieved over the period covered by the CIFSI in enhancing Canada’s food safety capacity would have been realized without the financial support provided by the Initiative. The complexity of the agriculture and agri-food sector, combined with the presence of multiple stakeholders (including provincial and territorial governments), required a federal leadership that the CIFSI has facilitated.

Because of the preventative nature of the CIFSI and the methodological limitations of this evaluation, it is impossible to demonstrate a direct causal relationship between the CIFSI and its economic outcomes.

Efficiency and Economy

The agriculture and agri-food sector is a multi-billion dollar industry that plays a critical role in Canada’s economy, and, as illustrated in crises such as BSE, it takes a single affected animal to shut down a whole component of the sector, with economic costs measured in the billions of dollars. From this perspective, investing $107 million to secure a multi-billion dollar industry can be dramatically more efficient than providing no investment and having to manage the negative consequences associated with another BSE crisis.

The work realized under each of the three components of the CIFSI has been realized with fewer resources than initially anticipated. While other factors have contributed to this financial outcome, the process used to allocate funding related to food safety systems and traceability systems has allowed AAFC to target projects that appeared to be most suitable in pursuing the economic goals associated with the CIFSI.

1.0 Introduction

This document constitutes the final report of the Evaluation of the Canadian Integrated Food Safety Initiative (also referred to as the Initiative or CIFSI). The Department of Agriculture and Agri-Food Canada (AAFC) with the support of the Canadian Food Inspection Agency (CFIA) have led the implementation of the CIFSI, which supports the economic growth of the agriculture and agri-food sector and supports systems development to provide assurances relating to the safety of the food Canadians are consuming.

1.1 Context for the Evaluation

Market considerations, more than anything else, have driven AAFC’s efforts relating to food safety, particularly those efforts in support of the Canadian Integrated Food Safety Initiative. Perhaps the most visible illustration of this emerged on January 31, 2003, when the first cow was diagnosed with bovine spongiform encephalopathy (BSE) triggered one of the most profound crises in the history of the Canadian cattle industry. In terms of human health, to date not a single Canadian beef has been linked to cases of variant Creutzfeldt-Jakob disease. However, exports of beef were largely shut down, when BSE was found in Canada and the painful rebuilding of that market took years to achieve and came with a price tag that has been estimated at $7 billion. The following year, Canada detected highly pathogenic avian influenza in an area of highly concentrated poultry production in British Columbia. This led to the eventual culling of 17 million birds causing a loss of $380 million in gross economic costs.

It is in this context that AAFC launched, in 2003, its five-year Agricultural Policy Framework (APF) whose purpose was to position Canada as a world leader in food safety, innovation and environmentally-responsible practices. The transition rested on three pillars: innovation, environmental stewardship, and food safety and quality. New programming was designed, along with new initiatives relating to business risk management. In particular, the APF included the Canadian Food Safety and Quality Program (with its National Food Safety Systems component) and the Developing National Traceability Systems element, which was implemented on a pilot project basis. The need to address biosecurity concerns emerged during the later stage of the APF.

Building on the achievement of the APF, and wishing to address new priorities around biosecurity, the federal government unveiled, in 2008, its five-year Growing Forward framework, including the Canadian Integrated Food Safety Initiative. The focus of the Initiative was on pursuing the development of food safety systems, establishing a framework that would complement industry traceability system components, supporting the development and implementation of traceability systems, and establishing national biosecurity standards.

1.2 Scope and Objectives of the Evaluation

This evaluation is conducted in accordance with the federal government’s Policy on Evaluation. As such, it focuses on the relevance of the CIFSI and its performance over the five-year period covered by the Initiative, which is from 2008–2009 to 2012–2013. More specifically, the evaluation explores the continued need for the Initiative, its alignment with government priorities and federal roles and responsibilities, the extent to which it has achieved its expected outcomes, and the extent to which efficiency and economy have been demonstrated.

This evaluation is expected to inform the ongoing activities that AAFC is undertaking in relation to food safety, traceability and biosecurity particularly in light of the Growing Forward 2 framework, which covers the next five years, from 2013–2014 to 2017–2018.

1.3 Structure of the Report

This report is divided in five sections, including this introduction. Section 2.0 describes the Initiative, including its expected program logic. On that basis, Section 3.0 presents the methodology retained to address the set of evaluation questions, including a discussion of the methodological limitations of the evaluation. Section 4.0 summarizes all relevant findings that emerged from the data collection and covers three evaluation topics (relevance, effectiveness, and economy and efficiency). Finally, Section 5.0 includes the conclusions of the evaluation and their associated recommendations.

1.4 Acknowledgment

The contribution and collaboration of many individuals have made this evaluation possible. We wish to thank all of those who participated in interviews, provided information, and responded to inquiries.

2.0 Description of the Initiative

The federal government provided AAFC with $107 million ($60 million in Vote 1 and $47 million in Vote 10) over five years (2008-2009 to 2012-2013) to pursue the market access related goals associated with the Initiative. This section of the report describes the core components of the CIFSI, the governance structure to manage them, the distribution of financial resources, and the outcomes that were expected to be realized through their implementation. Under Growing Forward, the implementation of systems and standards developed under CIFSI is a provincial/territorial responsibility.

2.1 Overview of the Initiative

Growing Forward (GF) (2008-2013) built upon the Agricultural Policy Framework (APF) (2003-2008) through an integrated and comprehensive framework that focused on key results in the areas of competitiveness and innovation, society’s priorities and proactive risk management. In terms of food safety, it focused on supporting the enhancement of food safety systems and committed federal, provincial and territorial governments to continue to work with the sector to put in place traceability and biosecurity systems. In particular, CIFSI, a suite of programs under Growing Forward, was expected to contribute to the vision of Growing Forward whereby a profitable and innovative agriculture, agri-food, and agri-based products industry is seizing economic opportunities, managing risks, and responding to consumers’ increased expectations related to food safety. It was designed to integrate a complementary and mutually reinforcing set of programs, made up of three components: the development of food safety systems, the development of national traceability systems, and the development of national biosecurity standards.

There is not a single, universally-accepted definition of what constitutes food safety, biosecurity, or even traceability (although the latter term is better defined). To avoid confusion, in the following sub-sections, a description of each concept is presented, acknowledging that they are meant to be used in the specific context of this evaluation and may not be universally applicable.

2.2 Core Components

National Food Safety Systems Development

The first component of the Initiative supports the development of food safety systems. Generally speaking, the notion of food safety system refers to the documentation of a phased and integrated approach to managing food safety risks that includes preventative food safety control.

These food safety systems are typically based on the model referred to as the Hazard Analysis and Critical Control Points (HACCP). This model promotes a scientific and systemic approach to identify, assess and control hazards during the production, processing, manufacturing, preparation and use of food. The World Health Organization and the Food and Agriculture Organization of the United Nations have included the HACCP model in their series of international food standards known as the Codex Alimentarius. Also, the International Organization for Standardization (ISO) has integrated the HACCP principles in the voluntary international standards it has developed to deal specifically with food safety (ISO 22000), which industries may use to structure their food safety approach.

In Canada, the federal government has supported the agriculture and agri-food sector in its efforts to develop food safety systems. Under the Agricultural Policy Framework (2003 to 2008), the National Food Safety Systems component provided financial support for the development of such systems. These efforts have been expanded under Growing Forward through the CIFSI (2008–2013).

Food safety system development

Through the CIFSI, in line with its role and mandate, the Federal Government supported the development of national food safety systems. In this respect, AAFC signed contribution agreements with eligible recipients in order to provide financial support for the development or enhancement of food safety systems. These systems may cover both on-farm and post-farm activities. Two levels of support could be provided:

phase 1 projects: Financial resources were provided to recipient organizations to support the design of strategies that lay the groundwork for the set of activities leading up to the development of food safety systems; and,
phase 2 projects: Funding was provided to recipient organizations to develop (or enhance) food safety systems.

The range of activities that could be funded under this component includes (but is not limited to) the development of a food safety management strategy, HACCP-based food safety models and programs, producer manuals, work books, training and audit manuals and activities leading to the CFIA recognition process.

Once these phases were complete, it was the responsibility of the provinces/territories, under AAFC’s cost shared programming, to help producers implement these systems and standards.

CFIA Food Safety Recognition Program

In its role as food regulator in Canada, the CFIA is the federal agency that manages both the On-Farm and Post-Farm Food Safety Recognition Programs which provides technical expertise to organizations in developing their on-farm and/or post-farm food safety systems and the government recognition of HACCP-based food safety systems. As such, once a food safety system has been established, the sponsoring organization may decide, based on industry/sector requirements, to have its system formally recognized by the CFIA. Where market conditions require an assessment, the recognition process involves three steps:

Technical review (Part 1 and 2): During the first phase of the technical review, the CFIA and interested provinces and territories proceed with a review of the proposed HACCP based documentation submitted by the sponsoring organization. This documentation typically includes food safety manuals for producers or processors, and a description of the HACCP based generic food safety model. Part 2 of the technical review involves a gap analysis that is focused on management systems and training materials. At the completion of each phase of the technical review, the CFIA issues a Letter of Completion.
National producer organization implementation and third party audit: At this stage, the sponsoring organization implements the management system and an independent, third-party auditor assesses the extent to which the implementation of the new system is proceeding efficiently and as planned.
CFIA implementation assessment: During that last stage, the CFIA proceeds with a detailed review of the audit and of all related information that confirms that the prescribed procedures are being followed. This leads to a formal Letter of Recognition that the CFIA issues to the sponsoring organization.

Development of National Traceability Systems

The second component of the Initiative relates to the establishment of a national traceability system, whose purpose is to allow a targeted item or group of items to be monitored from one point to another in the supply chain. While food safety systems tend to focus on preventing foodborne illness, traceability focuses on risk management, by providing critical information that assists in deploying a quick and efficient response in cases of contamination or other disease-related incidents.

Many countries around the world, notably those in the European Union, the United States, and Australia, have developed traceability systems. The Codex Alimentarius also provides a set of common principles to assist authorities in integrating a traceability component to their food inspection and certification systems.

In Canada, the federal, provincial, and territorial governments recognized the need to coordinate efforts in order to build a National Agriculture and Food Traceability System (NAFTS) for livestock and poultry. In 2006, industry and governments committed to working together to establish a NAFTS beginning with livestock and poultry and established an Industry Government Advisory Committee (IGAC) to lead its development and implementation.

Traceability systems are based on three pillars: animal/product identification, premises identification and movement reporting. Full livestock/poultry traceability is the ability to trace an animal through all stages of life from farm of origin/import to slaughter/export. Establishing a livestock traceability system has required an incremental approach due to the number of jurisdictions, sectors and organizations involved, all of which were at various stages of implementation. For example, provincial governments are responsible for the implementation of premises identification (PID) systems. At the start of the initiative, some provinces were still in the planning phase, while others were already implementing PID systems. Further, some provinces took voluntary approaches, some mandatory (via PID regulations), and others voluntary with cross-compliance. Species organizations were at various stages of traceability plan implementation.

In fact, the bulk of this work was expected to occur during the period covered by the CIFSI and was divided into three components, involving AAFC with support from CFIA:

Work on technological requirements (total investment of $12,745,069 in Vote 1 from 2009-2010 to 2012-2013): The establishment of a national traceability system did not entail the creation of a new and separate database. Instead, the system was expected to integrate traceability information from multiple data sources. Under the Initiative, the CFIA was mandated to oversee the establishment of this new system, referred to as the Traceability National Information Portal (TNIP). This work entailed the planning of this system, its definition, its approval, and its launch. Once launched in 2013, the management of the portal was transferred to AAFC.
Work on the legislative and regulatory framework (total investment of $15,250,000 in Vote 1 to AAFC over four years (2009-2010 to 2012-2013) which includes $3,000,000 over these four years, to be transferred to CFIA). Under the Initiative, both AAFC and the CFIA were mandated to establish a Traceability Management Office that could work specifically on the establishment of these legislative and regulatory frameworks. AAFC provided funding to CFIA in view of the fact that CFIA is the regulator responsible for traceability legislation and regulation. At the operational level, CFIA led the development of the required legislation, regulation, and information sharing agreements with industry and provinces and territories. As for AAFC, through its Traceability Management Office, it managed partnerships among key stakeholders (industries, federal government, and provinces and territories). AAFC also provided secretariat support to both the Industry-Government Advisory Committee and the Federal-Provincial-Territorial Traceability Task Team.
Support for the development of traceability systems: Parallel to the work of the CFIA on the Traceability National Information Portal, the Initiative allowed AAFC to sign contribution agreements with eligible recipients to provide financial support for the development and implementation of commodity-specific traceability systems. The range of activities funded under this component could include (but was not limited to) developing strategic assessment and analysis, implementing pilot projects, designing data collection and storage systems, testing and implementing new systems, and auditing and verification activities.

National Biosecurity Standards Development

The third component of the Initiative relates to the development of national biosecurity standards at the farm level to assist producers with measures they can take to mitigate risks to animal and plants. In the Canadian context, biosecurity is about mitigating risks of introducing pathogens that can trigger serious health issues in animals and plants. As such, Canadian biosecurity standards tend to focus on the following:

managing access to the farm;
the management of animal and plant movement, to avoid potential contamination risks;
the movement of people, vehicles, and equipment that can come into contact with livestock or plants;
the management of animal and plant health practices; and,
education, planning, and recording biosecurity protocols and incidents.

As opposed to the two other components of the Initiative, the biosecurity component did not provide financial support to eligible recipients. AAFC signed a Memorandum of Understanding (MOU) with the CFIA, in view of their expertise in biosecurity, to support the development of biosecurity standards relating to priority commodity sectors: dairy cattle, beef cattle, goat, sheep, grains and oilseeds, bees, mink, and potato. In addition, to the commodity specific biosecurity standards, the CFIA developed two general commodity biosecurity standards, one for the plant and one for the animal commodity sectors.

2.3 Management Structure

AAFC, which had received the funding for the CIFSI, allocated a portion of it to the CFIA via two MOUs, under Growing Forward. The initial MOU in 2009 was for CFIA to provide scientific and technical support for food safety systems recognition, traceability (including the planning of TNIP), and biosecurity standards based on their expertise as a regulator and biosecurity experts. A second MOU in 2011 was specifically for the development of TNIP, an electronic information sharing mechanism that will allow authorized users to search multiple databases simultaneously for attributes related to the three pillars of livestock traceability - animal identification, location and movement, and tracing these attributes along the farm-to-slaughter continuum.

As illustrated in Table 1, AAFC is the leading entity in charge of providing financial support for the development of new food safety systems and new traceability systems, and providing financial support to organizations that engage in the CFIA’s food safety system recognition. AAFC also manages industry-government and federal-provincial-territorial partnerships in the area of traceability and biosecurity. As the regulator, CFIA manages the FSRP, and manages the required legislative and regulatory framework in support of the national traceability system. The agency also provides technical support during the development of new food safety and traceability systems and new biosecurity standards.

In accordance with the MOU, both the CFIA’s Traceability Unit and the AAFC’s Integrated Traceability Unit jointly managed the TNIP. It was overseen by a joint AAFC-CFIA executive management group.

Table 1: Allocation of main responsibility by components of the CIFSI

Components	AAFC	CFIA
Food safety system - Development of new food safety systems	yes	(support)
Food safety system - Recognition of new food safety systems	(support)	yes
National traceability system - Technological requirements (TNIP)	(support)	yes
National traceability system - Legislative and regulatory framework	(support)	yes
National traceability system - Development of new traceability systems	yes
National biosecurity standards - Development of new biosecurity standards	(support)	yes

2.4 Financial Resources

The federal government allocated $107 million over five years (2008-2009 to 2012-2013) in support of the CIFSI as seen in Table 2^{Footnote 2}. As illustrated in Table 3, the distribution of resources among the types of activities reflects the division of roles and responsibilities between AAFC and the CFIA. As already noted, financial resources to the CFIA were provided through two MOUs.

Table 2: Total Budgeted TBS Allocation for CIFSI by Vote Type – 2008-2013 ($’s)

	AAFC	CFIA	Total
Source: Program Foundational Documentation.
Vote 1	27,580,000	32,541,069	60,121,069
Vote 10	47,165,000^{Footnote 3}	N/A	47,165,000
Total	74,745,000	32,541,069	107,286,069

Table 3: Budgeted TBS Allocation for CIFSI by component– 2008-2013 ($’s)

	Food Safety Systems Development	CFIA Food Safety Recognition Program	National Biosecurity Standards Development	Government Traceability Infrastructure - Traceability Management Office	Government Traceability Infrastructure - Traceability Information Sharing Solution	Industry Traceability Infrastructure
	National Food Safety Systems		National Biosecurity Standards Development	Developing National Traceability Systems
Source: Program Foundational Documentation, Memorandum of Understanding Growing Forward Program Initiatives Development; Memorandum of Understanding Growing Forward Development of Traceability National Information Portal.
2008-2009	49,505	0	8,000	2,011,000	0	0
2009-2010	11,021,401	2,100,000	2,166,000	3,178,000	1,056,000	9,165,119
2010-2011	8,680,188	2,100,000	2,035,000	3,406,000	5,949,743	9,743,210
2011-2012	5,012,412	1,920,000	2,538,000	3,406,000	3,325,243	6,898,784
2012-2013	5,825,026	1,140,000	2,789,000	3,250,000	2,414,083	6,102,281
Sub-Total	30,588,532	7,260,000	9,536,000	15,251,000	12,745,069	31,909,394
Grand Total: 107,289,995

2.5 Logic of the Initiative

Through the implementation of the CIFSI, both the AAFC and the CFIA advanced their respective mandates, specifically:

AAFC’s mandate is to provide information, research, technology, and policies and programs to achieve security of the food system, health of the environment, and innovation for growth.
The CFIA’s mandate is to safeguard Canada’s food supply and the plants and animals upon which safe and high-quality food depends through inspection and compliance activities and the development of policies and regulation.

On that basis, the Growing Forward policy framework pursues, through the implementation of the CIFSI, the following two outcomes:

a sector that contributes to society’s priorities, promoting food safety and environmentally-responsible agriculture; and,
a sector that is proactive in managing risks.

The set of activities and outputs associated with the Initiative are expected to contribute to the achievement of these two outcomes by covering the following key dimensions:

focusing on the broader environment, the establishment of farm-level biosecurity standards are expected to support producers’ efforts to limit the likelihood of having pathogens and/or pests introduced and spread to animal and plants by increased awareness of biosecurity measures and risks that may be associated with their business activities such as, the movement of animals, plants, people, or equipment;
focusing on the actual production of food, the establishment of food safety systems ensures that adequate practices are in place to increase Canadian producers’ competitiveness to maintain or gain access to foreign markets; and,
finally, from a risk-management perspective, establishing traceability capacity ensures a prompt and efficient response in cases of contamination or other disease-related incidents.

Taken as a whole, these three components strengthen the ability of the Canadian agriculture and agri-food sector to maintain and expand its export markets, in addition to providing Canadians with assurances as to the safety of the food they consume.

3.0 Methodology

3.1 Evaluation Scope and Approach

The evaluation examined the relevance and performance of CIFSI. Under relevance, the evaluation looked at continued need for the program, alignment with federal roles and responsibilities, and alignment with the department’s priorities and strategic outcomes. In terms of performance, the evaluation examined effectiveness, efficiency and economy. In its assessment of resource utilization the evaluation focused primarily on National Food Safety Systems Development and Industry Traceability Infrastructure, which had the highest degree of materiality of all CIFSI components.

The evaluation covered programming under multiple components of AAFC’s Program Alignment Architecture under Growing Forward, as illustrated in Table 4. The evaluation examined only CIFSI, and did not include cost-shared programming under Growing Forward or other food safety, traceability or biosecurity programming. These programs are covered under other evaluations in accordance with AAFC’s Five-Year Strategic Evaluation Plan.

Table 4: Components of AAFC Program Activity Architecture (2012–2013) covered by the evaluation

Program activity - 2.2 Food Safety and Biosecurity Risk Management Systems

Sub-activity - 2.2.1 Biosecurity (Biosecurity activities under CIFSI did not include a sub-sub-activity.)
Sub-activity - 2.2.3 Food Safety Systems
- Sub-Sub Activity - 2.2.3.1 Food Safety Systems Development
Sub-activity - 2.2.4 Traceability
- Sub-Sub Activity - 2.2.4.1 Traceability – Government Infrastructure
- Sub-Sub Activity - 2.2.4.2 Traceability – Industry Infrastructure

3.2 Data Collection Methods

The evaluation included the following data collection methods:

Document review: A document review was undertaken to examine information related to the relevance of food safety, traceability, and biosecurity in the context of trade, risk management/mitigation, consumer/market expectations, and government priorities. Other documents provided information related to the performance of the Initiative, including the review of the CFIA’s components of CIFSI.
Literature review: A literature review was conducted to provide information on Canadian food safety, traceability, and biosecurity within a global context.
Data review: An analysis of program administrative and performance data was undertaken to assess the results and resource utilization of AAFC’s Food Safety Systems Development and Industry Traceability Infrastructure. In addition, data from Statistic Canada’s Farm Financial Survey related to producer participation in HACCP-based food safety programs was reviewed.
Interviews: 38 key informant interviews were conducted, including 13 industry representatives, 12 federal government representatives, 10 representatives of provincial governments, and three external experts. The evaluation team consulted with the Market Access Secretariat of the Market and Industry Services Branch for information related to the extent to which food safety and traceability had afforded market opportunities for the Canadian sector. Interviewees for the evaluation were selected to include a wide range of perspectives on the relevance and performance of the Initiative. Interviewees were selected to include a range of perspectives on all three components of CIFSI.
Case studies: Six case studies were undertaken of CIFSI projects including: three food safety, two traceability, and one biosecurity case study. These included the following:
- Canada Sheep and Lamb Food Safe Farm Practices;
- Integration of CanadaGAP and the Repackaging and Wholesale Food Safety Program;
- Canadian Bee Industry Safety Quality Traceability;
- Canadian Livestock Tracking System;
- West Hawk Lake Initiative; and,
- Canadian Beef Cattle On-Farm Biosecurity Standard.

Case studies were selected to provide information on all three major components of CIFSI: food safety, traceability, and biosecurity. For food safety and traceability, other criteria were developed to guide the selection of case studies, including range of:

project statuses (in-progress, completed at time of evaluation);
project scopes (review/enhancement, Phase 1, Phase 2, for example); and,
agricultural commodities were represented.

The biosecurity case study was selected as it comprised a completed biosecurity standard for a commodity that makes up a large portion of the Gross Domestic Product and Canadian exports.

3.3 Limitations of the Evaluation

The main limitation associated with this evaluation relates to the lack of quantitative data on longer-term impacts of food safety, traceability systems, and biosecurity standards. These were not identified in the Initiative’s performance measurement strategy and thus were not collected. To mitigate the impact of this limitation, the evaluation collected some information on the longer-term impacts of the Initiative through interviews and case studies. An additional limitation is the exclusive use of secondary data of the CFIA’s components of CIFSI. AAFC relied on the results of CFIA’s Review to assess the performance of CFIA’s components of CIFSI.

4.0 Evaluation Findings

This section of the report presents key findings related to the CIFSI. More specifically, it explores the relevance of the Initiative, its effectiveness and the extent to which efficiency and economy have been realized.

4.1 Relevance

From market access, food safety and risk mitigation perspectives, there is a strong rationale for governments and the agriculture and agri-food sector to engage in food safety. In this context, the CIFSI is providing a framework that supports actions on three key pillars: biosecurity, food safety systems, and traceability. This subsection of the report further explores these findings.

4.1.1 The rationale for food safety

Food safety is a widely shared responsibility. In a typical year, close to four million cases of foodborne incidents are reported in Canada^{Footnote 4}. The vast majority of these cases (estimated at around 80%) occur during the later stage of the food chain, namely in restaurants and, just as importantly, at home. Public education and awareness on the proper handling and preparation of food aim to counter these food-related risks. Although most of these incidents do not lead to serious health problems, some do and studies show that the impact of an incident is more severe at the primary production, manufacturing, and processing stages of the food production chain^{Footnote 5}. Canadians were reminded of this during the 2008 outbreak of listeriosis linked to cold cuts from a Maple Leaf plant in Toronto. Out of 57 confirmed cases, 22 individuals died as a result of this food-related incident^{Footnote 6}. These incidents raise consumer concerns about food safety and highlight the need for federal government involvement.

Acknowledging the importance of ensuring access to safe food, governments have long recognized the deep interconnectivity that exists among nations throughout the production, processing, and distribution of food. As a result, food safety has required actions within national borders, as well as the surveillance and monitoring of food that enters one’s country. And while Canada does rely on imports to satisfy Canadian’s food requirements, it remains a vastly export-oriented country whose access to foreign markets is essential for the sustainability of this economic sector. In 2010, Canada stood as the fifth-largest exporters of food commodities in the world, with exports valued at $35.5 billion. Grains and grain products, oilseed and oilseed products, live animal, red meats and other animal products accounted for the bulk of these exports. Not surprisingly, while Canada exports to more than 160 countries, it is the United States that remains its principal market. No less than half of all food-related Canadian exports end up in the United States. Other significant markets include Japan (8.4% of all exports), China (7.5%), the European Union (5.9%) and Mexico (4.0%).^{Footnote 7}

In this context, the rationale for food safety includes a large market-science component. To maintain its standing as one of the prime exporter of food-related commodities, Canada must demonstrate its ability to produce safe food and to effectively manage any incident that may occur along the food production process. This is particularly critical as some countries, including the United States, Canada’s main food-related market, is adopting specific requirements that must be met by those countries from which food-related imports come from. The Food Safety Modernization Act (FSMA) adopted by the United States in 2011 provides a clear illustration of this evolving trend. This legislation establishes standards related to food safety that must be met by both American and foreign food producers wishing to enter the American market^{Footnote 8}.

4.1.2 The federal role in food safety

Arguably, every government around the world is involved in food safety. How they decide to intervene, however, varies widely. Beyond the range of activities that they may decide to pursue, governments typically favour one of two approaches to food safety^{Footnote 9}. Under the first model, it is the performance of food producers that becomes the focus. A great deal of latitude is provided to food producers in framing their approach to food safety or traceability systems, as long as the expected outcome (safe food) is achieved by producers. Under that model, rewards (certification) or swift penalties (fine, recall, plant closure) become the privileged tools used to frame and monitor the food producing industry. The second model tends to focus on the process leading up to food being produced. Here, the focus is placed on the procedures used along the food producing chain. Food safety systems (particularly those systems based on the HACCP approach) and traceability system become the government’s focus, including the option of making a number of these systems mandatory. As one may expect, those two models are not mutually exclusive, as one government may use portions of each model.

While government strategies towards food safety differ among countries, there seems to be a consistent trend of governments, not the industry, being charged with leading biosecurity initiatives.

As the CIFSI illustrates, the Canadian approach to food safety relies heavily on the establishment of food safety and traceability systems, and Canada differs significantly from many other industrialized countries in the financial support it offers for the development of these systems. Countries such as the United States, the United Kingdom, and Australia provide technical assistance for the establishment of these systems. In this context, is CIFSI the right type of funding vehicle for the agriculture and agri-food industry in Canada? Individuals consulted as part of this evaluation offered a number of perspectives, including the following:

The industry had been involved in food safety well before the Agriculture Policy Framework or the CIFSI emerged. However, through these two complementary initiatives and the financial support it entailed, the federal government has created momentum that has accelerated the establishment of food safety measures.
In a country as vast as Canada, with multiple players including several food-related industry sectors, provincial and territorial governments, and the federal government, there is a need for central leadership, which is illustrated through the CIFSI.
According to the 2011 Farm Financial Survey, implementation rates for on-farm HACCP-based food safety systems in 2011 varied widely by sector and farm size. The uneven uptake of food safety systems within some sectors has led some to question the rationale of pressing so actively for some of the measures included in the CIFSI.
Finally, with the CIFSI being a five-year initiative, it remains unclear how in the longer term the systems being established through the CIFSI will be maintained or updated.

4.1.3 The suitability of the CIFSI

Considering the predominant role of food-related exports in Canada’s economy, there is a need to ensure that appropriate measures are adopted in relation to food safety. The CIFSI is providing a framework that allows the federal government to support three components: the protection of animals and plants from pathogens and/or pests, establishment of sound food safety systems, and the ability to trace back components of the food chain to effectively respond to contaminations or other related incidents. In Canada, as well as around the world, activities in all three components remains a work in progress, as the coverage of these systems has not reached all sectors of the agriculture and agri-food sector.

The Initiative falls within the specific mandate of AAFC, which is to support producers in managing risks associated with the spread of animal and plant diseases as it relates to the Canadian agriculture and agri-food sector’s competitiveness in maintaining or gaining access to international markets and responding to Canadians’ priorities for safe food. More specifically, the CIFSI supports the strategic outcomes of both AAFC and the CFIA:

AAFC Strategic Outcome: A competitive agriculture, agri-food, and agri-based products sector that proactively manage risks.
CFIA Strategic Outcomes: safe and sustainable plant and animal resource base and public health risks associated with the food supply and transmission of animal diseases to humans are minimized and managed.

4.2 Effectiveness

This subsection of the report explores the effectiveness of the CIFSI. It addresses the overall achievement of the Initiative, and includes specific analyses for each of its three main components.

4.2.1 Overall achievement of the CIFSI

Efforts undertaken as part of the CIFSI have profoundly modified the environment in which the agriculture and agri-food sector operates in Canada. Being highly export-driven, the development of HACCP-based food safety and traceability systems has better equipped the sector to demonstrate its commitment to food safety. Due in part to the development of HACCP-based food safety systems, Canadian grain producers have been able to meet the requirements of the United Kingdom; pork producers have had easier access to the Asian market; and honey producers have been able to secure the Japanese market for honey-related products. Biosecurity standards are available to help mitigate the risks associated with pathogens and/or diseases and pests for the priority commodity sectors, food safety systems are being implemented to systematically manage the risk of foodborne emergence along the food chain, and the work on traceability has been significantly advanced to ensure a prompt response in case of contamination or other related food-related incidents. While additional work is required to complete the establishment of this framework, it nevertheless positions Canada to compete in desired international markets, in addition to providing assurances to Canadians in relation to the safety of the food they consume. Traceability efforts have contributed to allowing the beef sector to regain the United States and Asian markets it had lost due to BSE outbreak and meet the proof-of-age requirement applicable to cattle aged 30 months or less, which is required to enter the Japanese market. In regards to managing food-related incidents, a control point near the Manitoba and Ontario borders to control movement of animals and their products during a foreign animal disease outbreak was recognized by the United States in 2013.

The fundamental questions that remain are to determine the extent to which the systems put in place will be adopted by industry, and are used in meeting future requirements. The ultimate value of the framework established through the CIFSI will be determined over time, as participation in these various components is tracked. On that point, the early findings presented in this evaluation present an uneven portrait. For those industries where food safety is seen as essential to access targeted markets, participation in these programs will become increasingly significant. For some sectors, these systems become the cost of doing business today, but also provide the foundation to meet the evolving market and regulatory requirements of tomorrow.

The following sub-sections review achievements related to each of the three components of the CIFSI.

4.2.2 Results of National Food Safety Systems Development

The assessment of results achieved under the food safety systems component of the CIFSI is framed by a number of considerations:

Coverage: Are food safety systems currently in place for all key on-farm and off-farm components of the agriculture and agri-food sector? In other words, do all farmers and producers have access to food safety systems that they can integrate into their operations?
Recognition: Of all the food systems in place, how many are formally recognized, and, if recognized, by whom?
Mandatory nature: Of all food safety systems in place, how many have anticipated mandatory requirements?
Participation: Of producers and processors involved in a component of the agriculture and agri-food sector covered by a voluntary food safety system, how many are actively participating out of a required market need?
Outcome: To what extent are the food safety systems assisting producers to remain competitive and gain access to foreign markets?

Coverage of food safety systems

Through the financial support provided by the CIFSI, major components of the agriculture and agri-food sectors have succeeded in developing or enhancing their respective food safety systems. As indicated in Table 5, large segments of on-farm and off-farm national organizations now have access to these systems. At the time of the evaluation, post-farm commodities were not in a position to apply for the CFIA’s post-farm recognition process as it was still in a pilot phase.

Table 5: Food safety systems established with the support of the CIFSI^{Footnote 10}

Commodity	Name of the system	CFIA recognition
Beef	Quality Starts Here	In progress
Chicken	Safe Safer Safest	Completed
Deer, elk	Cervid On-Farm Food Safety Program	In progress
Goat	Goat On-Farm Food Safety Program	In progress
Sheep	Food Safe Farm	In progress
Turkey	TFC On-Farm Food Safety Program	In progress
Veal	Verified Veal Program	In progress
Dairy	Canadian Quality Milk	In progress
Produce	CanadaGAP	In progress
Honey	Canadian Bee Industry Safety Quality Traceability Program	In progress
Grains	ExcelGrains	In progress
Wine	Safe Winemaking Program	Not applicable
Water	CBWA Food Safety Program	Not applicable
Packaging	PacSecure	In progress
Trucking	Trucking Food Safety Program	In progress
Retailers	Retail Food Safety Program	Not applicable

In addition to these initiatives, the CIFSI has supported related projects, including the following:

the development of food safety-related material to support food banks;
the development of resources to support the establishment of food safety audit infrastructure, including the qualification of food safety auditors;
the support to the Canadian Federation of Agriculture to support national producer organizations in establishing their food safety systems; and,
the support to organizations exploring food safety systems for kosher, organic, and gluten-free products.

It is also important to note that some sectors had already established their food safety programs prior to the implementation of the Initiative and have not sought support to enhance it during the period covered by the CIFSI. This is notably the case with the pork, eggs, and herbs sectors.

While major components of the agriculture and agri-food sector now have access to food safety systems, it remains unclear to what extent other commodities can be expected to seek the establishment of food safety systems. Findings gathered as part of this evaluation do not allow for a clear assessment of the extent to which a gap in coverage may remain.

Recognition

While having a food safety system formally recognized provides assurances as to its quality and comparability to other similar systems, it is important to note that the implementation of these systems is typically done on a volunteer basis. In other words, a system may be formally recognized, but only a fraction of the targeted producers may, in fact, be using it.

When pursuing the recognition avenue, producers have a number of options. They may seek CFIA recognition, as structured under the CIFSI; they may opt for the ISO 22000 certification; or they may seek the certification offered by the Global Food Safety Initiative (GFSI), a non-profit organization created in 2000 that benchmarks food safety systems against internationally-recognized minimum food safety requirements. It should be noted that obtaining one certification, the one offered by CFIA for instance, may facilitate a recognition process under ISO 22000 or the GFSI.

Evaluation findings indicate that several key on-farm national organizations have initiated the process of being formally recognized by the CFIA under the FSRP, but the only organization to successfully complete it is Chicken Farmers of Canada, which was granted the CFIA’s Letter of Recognition^{Footnote 11}. It should be emphasized that the CFIA has required more time than anticipated to establish the FSRP. Initially expected to be operational as of March 2010, the on-farm component of the FSRP has only been established since June 2012 and, at the time of the evaluation, the post-farm component was still under development. Also, evaluation findings indicate that it may take up to four years to complete all stages of the recognition program. As a result, many of these recognition processes are expected to occur during the post Growing Forward period. Appendix B provides an overview of the status of HACCP-based government recognized food safety systems.

Mandatory nature of food safety systems

Typically, it is up to each producer/commodity to decide whether they wish to implement a food safety system based on market demand or buyer requirements.

The limited scope of mandatory food safety systems currently found in Canada is largely in line with practices found in other countries. The United States government has implemented mandatory HACCP-based food safety systems regulations applicable to the meat, seafood, and juice industry. Along the same lines, the Australian government has a mandatory food safety system requirement applicable to the beef sector only.

While not required by national governments, some markets only allow products that have been produced in accordance with a government recognized (that is the CFIA’s On-Farm Food Safety Recognition Program) or a privately recognized food safety system (that is Global Food Safety Initiative). On that front, evaluation findings (case studies and interviews in particular) have pointed to a number of compelling cases, including the following:

the ExcelGrains program has allowed Canadian grain producers to meet the requirements of a baking company located in the United Kingdom;
the Canadian Quality Assurance Program, applicable to pork producers, is a selling point to access the Asian market;
the HACCP-based food system applicable to Canadian honey has played a key role in securing the Japanese market for honey-related products;
Loblaws and Metro require all produce suppliers to hold a certification that is based on a GFSI-recognized standard, which includes CanadaGAP, whose development has been supported by the CIFSI; and,
the wine industry has relied on a HACCP-based food safety system to comply with the Canadian Import and Interprovincial Requirements for Processed Products, which governs the interprovincial trade of wine.

It is worth noting that it is not necessary for a food safety system to be formally recognized in order to be used by the targeted producers. This has proven to be the case, in particular, with the food safety systems established for bees and winemaking. At this point, these two systems have not been formally recognized by the CFIA, but they have been successfully used by these industries.

Participation in food safety programs

As a result of the market driven nature of many of the CIFSI supported systems and standards, participation rates vary among commodity sectors. Data from the 2011 Farm Financial Survey (FFS) conducted by Statistics Canada confirms this trend^{Footnote 12}. As of 2011, and considering all sectors and farm sizes, the participation rate in HACCP-based on-farm safety programs stood at 47%, a level that has remained constant since 2008. When looking at some sectors more specifically, the survey indicates that high participation rates were found in the dairy (90%), pork and poultry (90%), and eggs (86%) sectors. Much lower rates of participations were found in the beef (27%), vegetable (38%), and fruit (44%) sectors. The top three possible reasons for the low participation rates provided in the 2012 FFS were: having not heard of the program (36%); there being no buyer requirement (24%); and not seeing a benefit (23%). This finding supports the earlier findings of the FFS 2009 which found that except for beef, larger livestock & poultry producers (sales of $250,000 and over) have a very high level of participation when compared to small livestock & poultry producers (sales of less than $250,000), who have a much lower level of participation.

Outcomes

Outcomes resulting from the implementation of food safety can be assessed at two levels: risk mitigation and economy. Given the preventative and risk-mitigating approach of the CIFSI, it is a challenge to measure and quantify risk-reduction effectiveness. These systems are expected to prevent foodborne illness from emerging during the various stages of food production, improving consumer confidence in the safety of Canadian food and helping the agriculture and agri-food sector to mitigate risks. From a practical perspective, it is impossible to measure the net impact of these preventative programs on the number of actual incidents occurring in Canada. The effectiveness of food safety outcomes can be more appropriately measured by the rigor of the systems developed under the program. The principles upon which these programs are based (the HACCP principles in particular) are widely recognized around the world and have been endorsed by leading public health organizations, including the World Health Organization. Moreover, biosecurity standards and traceability infrastructure development both rely on subject matter experts from federal, provincial, territorial governments and industry. As such, these programs benefit from a strong theory-based foundation.

The other type of impacts, related to food safety systems, is economic in nature. As already noted, the implementation of these programs allows Canadian producers to be well-positioned to maintain and expand their international markets, by clearly demonstrating their commitment to food safety. As food safety requirements keep expanding, the economic benefit of these programs is also expected to grow.

4.2.3 Results on the establishment of traceability infrastructures

Results related to traceability can be structured along the three components covered by the CIFSI: technological requirements, legislative and regulatory frameworks, and the establishment of traceability systems.

Technological requirements

The CFIA developed the material required to define and document the high-level requirements and the initial project planning associated with the Traceability National Information Portal, which is expected to cover animal identification, premise identification, and animal movement reporting. The agency produced the project charter, the business case, the business requirements, the risk and mitigation plans, and the project plan documents required for the establishment of the national traceability portal. This initial stage paved the way for the implementation of the actual portal, which became operational in February 2013, and for its transfer to AAFC under Growing Forward 2. Traceability information from Alberta, Manitoba and the Canadian Livestock Tracking System has been incorporated into the Portal. These three data sources represent the majority of traceability data in Canada.

Legislative and Regulatory Frameworks

Work under the CIFSI has led to the establishment of the legislative framework required to support full traceability in Canada. The passage of the Safe Food for Canadians Act in November 2012, provides the overarching authorities to be able to pursue the traceability goals identified under the CIFSI. On that basis, work has been undertaken to prepare regulatory proposals for livestock traceability. At the time of the evaluation, identification regulations were in place for cattle, sheep, and bison; and work was initiated on proposed regulations for full traceability in cattle, bison, sheep, goats, pigs and farmed deer and elk (cervids). Once regulations come into force, traceability for the targeted sector becomes mandatory. Appendix C provides details about the achievements of this component.

Development of Traceability Systems

Livestock/poultry traceability in Canada is based on three pillars: animal identification, animal movement reporting and premises identification. Premises identification information is stored in provincial databases, while animal identification and movement information is stored in industry databases. For instance, outside of Quebec, cattle identification and movement information is stored in the Canadian Livestock Tracking System (CLTS), developed as part of the Canadian Cattle Identification Program (see Table 6). The Traceability National Information Portal (TNIP) was developed by the federal government to link existing traceability data sources in order to effectively respond to animal health or sanitary issues. As such, it is essential that livestock/poultry producers implementing traceability identify a database to store their species-specific information.

In terms of animal and commodity traceability, through the funding provided by the CIFSI, several commodity sectors in addition to the cattle sector have initiated preparatory work and developed or enhanced their traceability systems. Table 6 provides an overview of the traceability systems being supported through the CIFSI.

Table 6: Traceability Systems established with the support of the CIFSI

Commodity	Name of the system	Status[a]
[a] Status valid at the time of the evaluation.
Cattle	Canadian Cattle Identification Program	Mandatory Identification
Pork	PigTrace	Voluntary
Equine	CanEQUID	Voluntary
Sheep and goats	Canadian Sheep Identification Program	Mandatory Identification
Bison	Bison Industry Traceability Program	Mandatory Identification
Deer and elk	Cervid Industry Traceability Program	Voluntary
Dairy	National Dairy Traceability System	Voluntary
Eggs	Egg Industry Traceability System	Voluntary
Wild capture fisheries	National Seafood Certification and Traceability Project	Voluntary
Lobster	Lobster Traceability Pilot Project	Voluntary
Aquaculture	National Seafood Certification & Traceability Project	Voluntary
Maple syrup	Identification des barils de sirops d’érable par puces électroniques	Voluntary
Herbs and spices	CHSNC Traceability Tools	Voluntary

For traceability purposes, as of July 2010, cattle producers are required to use ear tags that are based on radio frequency identification (RFID) technology, which conforms to a number of international standards. The CIFSI supported studies concerning the use of this technology in Canada.

As for premises identification, the attribution of a unique national number assigned by provincial or territorial governments to a parcel of land where animals or food are kept, assembled, grown or disposed of, the CIFSI has supported the work of provincial and territorial governments. The Industry-Government Advisory Committee and the Federal-Provincial-Territorial Traceability Task Teams have proven to be efficient venues to advance and share premises identification initiatives, which according to interviews conducted as part of this evaluation, has proven to be a particularly complex topic. More generally, the work of these two committees has facilitated progress towards an agreement on national standards and performance targets for livestock traceability, the development of industry-led sector implementation strategies, and the development of a national strategic management plan in support of the traceability system.

At the time of the evaluation, all provincial and territorial governments had the ability to issue premises identification numbers. Alberta, Manitoba, Quebec and Prince Edward Island have Premises Identification (PID) systems supported by regulations. British Columbia, Ontario and New Brunswick have voluntary PID systems.

As more traceability systems are established, data-sharing agreements must be established to allow for centralized access to this information through the national traceability portal. At the time of the evaluation, such agreements were in place for Prince Edward Island, Manitoba, and Alberta. These agreements allow provincial data on premise identification to be linked to data gathered by the CFIA on animal identification.

Outcomes

At the time of the evaluation, efforts undertaken as part of the traceability component of the CIFSI were still very much a work in progress. The adoption of the required regulatory framework related to a number of commodities, the full implementation of several traceability systems, and the signing of data-sharing agreements with several provinces and territories were still needed to achieve the goal of having full traceability capability in Canada.

Recognizing that many steps have yet to be completed in the field of traceability, evaluation findings (case studies and interviews in particular) point to some tangible benefits from what has been done to date. Traceability efforts, among other factors, have contributed to:

the Canadian beef sector being able to regain the United States and Asian markets it had lost due to BSE outbreak;^{Footnote 13}
Canadian exporters being able to meet the proof-of-age requirement applicable to cattle aged 30 months or less, which is required to enter the Japanese market;^{Footnote 14}
Maple Leaf Food’s being able to receive a premium for its pork products, at a time when other countries’ industries were unable to demonstrate the same degree of quality assurance according to interviews and case studies; and,
through the West Hawk Lake Zone Initiative, a control point had been established near the border between Manitoba and Ontario to control movement of animals and their products during a foreign animal disease outbreak. The United States had recognized this zone in 2013^{Footnote 15}. However, due to a lack of funding this initiative was terminated.

4.2.4 Results on the establishment of biosecurity standards

Through the Initiative, the CFIA, in close collaboration with industry and provincial and territorial governments, has developed the following farm-level biosecurity standards:

bees;
beef cattle;
dairy cattle;
potato;
grains and oilseeds;
goat;
mink;
sheep;
generic plant; and,
generic animal.

Under Growing Forward 2, biosecurity standards are expected to be identified for other priority commodities or other food-related sectors wishing to develop their own biosecurity standards. Generic biosecurity standards have been developed for plant and animal. In addition, the CFIA has established a third-party biosecurity farm level standard review and evaluation submission process. This allows stakeholders associated with a specific sector to develop their standards and have them reviewed by the CFIA to confirm that they do meet the criteria to be considered a national agri-commodity biosecurity standard. This third-party submission process has been successfully used by the swine industry, which has had its biosecurity standards recognized by the CFIA.

The goal under the CIFSI was to ensure the establishment of the targeted biosecurity standards. The implementation of these standards falls within the area of responsibility of provincial/territorial governments. The implementation of the biosecurity standards was expected to be undertaken during the post-CIFSI period.

Consequently, results associated with biosecurity standards remain largely within the realm of outputs. The standards are in place, but their actual impact on the industry has yet to be established.

4.3 Efficiency and Economy

This subsection of the report explores how AAFC has utilized the resources that the federal government assigned to the Initiative. As noted in the description of the Initiative, a total of $107 million has been allocated to support the achievement of the Initiative’s expected outcomes.

In accordance with the Policy on Evaluation, assessing the performance of a program entails a two-staged analytical process. First, the evaluation must assess the effectiveness of the program, which is the extent to which the program has reached its expected outcomes. This analysis is included in subsection 4.2 of the report. On that basis, the analysis relating to the efficiency and economy addresses the issue of whether the identified results have been achieved with an optimal level of resources. For the purpose of the CIFSI, the report discusses the level of operational efficiency achieved, as well as the demonstration of economy.

4.3.1 Operational efficiency

An analysis of operational efficiency is specifically focused on the level of resources (input) required to create the outputs associated with a program. In the case of the CIFSI, the set of expected outputs is fairly straightforward:

required food safety systems are in place;
required traceability systems are in place; and,
required biosecurity standards are adopted.

As already noted, the extent to which these outputs contribute to the broader market access and food safety outcomes associated with the AAFC is a larger question. For the purpose of the operational efficiency analysis, the question is specifically focusing on whether the resources (inputs) have been optimized to generate the greatest level of outputs.

Many of the methodological approaches for assessing the operational efficiency of a program are based on some type of cost comparison. This specific analytical angle is not practical in the case of the CIFSI. As already noted in this report, Canada appears to be the only country that provides direct financial support for the creation of these outputs. Obviously, from a purely technical point of view, one could argue that providing no financial support would have been the most efficient approach. But for reasons already discussed, providing no financial support, in the Canadian context, could have jeopardized the achievement of the ultimate goals pursed by the CIFSI, particularly the market access goals. The agriculture and agri-food sector is a multi-billion dollar industry that plays a critical role in Canada’s economy, and, as illustrated in crises such as the BSE one, it takes a single contaminated animal to shut down a whole component of that sector, in which case the economic costs are measured in the billions of dollars. In that sense, investing $107 million to secure a multi-billion dollar industry can be dramatically more efficient than providing no investment and having to manage the negative consequences associated with another BSE crisis.

In that context, another analytical approach for assessing operational efficiency involves comparing planned and actual costs of the program. On that front, evaluation findings indicate that the CIFSI has been operationally efficient. For both the food safety system component and the traceability system component, AAFC has been in a position to support the implementation of a number of targeted projects, with an overall financial commitment that has proven to be lower than initially anticipated. The department proceeded on the basis of contribution agreements signed with third parties. This process allowed AAFC to assess each funding request and screen out those requests that did meet the program’s goals and objectives. Appendix D provides details on the projects that were funded. Of the 48 funding proposals submitted in relation to food safety systems, 36 received funding. Of the 38 funding proposals submitted in relation to traceability systems, 29 received funding. This explains, in part, why not the entire planned budget for these two components has been used. By the end of the five-year period covered by the CIFSI, 51% of the planned Vote 10 funding associated with food safety systems ($18.75M) and 31% of the planned Vote 10 funding associated with traceability systems ($28.41M) had not been required. It should be noted, however, that other factors have contributed to this financial outcome. First, no funding was provided during the fiscal year 2008–2009, as these new programs were being established. Secondly, the time required to review funding proposals has proven to be significant. On average, it took close to six months for AAFC to complete this review process and render a financial decision.

4.3.2 Economy

The analytical component related to economy seeks to determine whether a minimum of resources have been used to achieve the ultimate outcomes of the CIFSI. In addressing this, it must first be acknowledged that these ultimate outcomes, both market access and food safety, have yet to be fully realized, for reasons explained in this report. Nonetheless, as the analysis on operational efficiency has demonstrated, actual costs for all three components of the Initiative have been less than initially anticipated, which confirms, at a minimum, that fewer resources than initially anticipated have been required to generate the program’s outputs.

Another perspective that can be pursued in addressing the economy question is to assess whether the various outputs could have been realized as effectively with fewer resources. This question becomes particularly relevant in relation to the traceability system component (but could also be applied to food safety systems). Since traceability systems entail significant technological investments, they are bound to require regular updates and upgrades to keep pace with technological innovations. These costs are to be expected and are worth incurring if these systems are used to their full potential. This brings up the issue of participation in traceability initiatives. As noted in this report, findings to date indicate that participation levels vary among various sectors. It will become particularly important to monitor participation trends related to traceability systems to ensure that resources are invested in infrastructures that are, in fact, utilized by targeted sectors. The same applies to food safety systems, although they do not entail the same level of capital investment in new technologies.

5.0 Conclusions

This section of the report provides conclusions on each of the key evaluation issues addressed in this report.

5.1 Relevance of the CIFSI

Evaluation findings confirm the pivotal role that food safety plays for market access and growth of the Canadian agriculture and agri-food sector. With exports standing at over $35 billion annually and a market that remains highly concentrated, Canadian producers and on-farm and post-farm businesses must be able to meet any food safety and traceability requirements imposed by potential importers of Canadian agri-products.

As structured, the CIFSI covers three components: the establishment of food safety systems, the establishment of traceability systems, and the development of biosecurity standards covering priority animal and plant commodities.

In addition to improving Canadian producers’ competitiveness, securing critical markets, food safety assurances also provide assurances to Canadians that the food they acquire does meet standards relating to food safety.

The CIFSI directly supported the set of strategic goals pursued by AAFC and the CFIA under Growing Forward.

5.2 Effectiveness

Being highly export-driven, the development of HACCP-based food safety and traceability systems has better equipped the sector to demonstrate its commitment to food safety. Due in part to the development of HACCP-based food safety systems, Canadian grain producers have been able to meet the requirements of the United Kingdom; pork producers have had easier access to the Asian market; and honey producers have been able to secure the Japanese market for honey-related products. Biosecurity standards are in place to help mitigate against risks from diseases and pests for the priority commodity sectors, food safety systems are being implemented to systematically manage the risk of foodborne emergence along the food chain, and the work on traceability has been significantly advanced to ensure a prompt response in case of contamination or other related food-related incidents. While additional work is required to complete the establishment of this framework, it nevertheless positions Canada to compete in desired international markets, in addition to providing assurances to Canadians in relation to the safety of the food they consume. Traceability efforts have contributed to allowing the beef sector to regain the United States and Asian markets it had lost due to BSE outbreak and meet the proof-of-age requirement applicable to cattle aged 30 months or less, which is required to enter the Japanese market. In regards to managing food-related incidents, a control point near the Manitoba and Ontario borders to control movement of animals and their products during a foreign animal disease outbreak was recognized by the United States in 2013.

Canada is now better positioned to meet food safety requirements from potential importers of Canadian agri-food and agri-products in addition to managing food-related incidents triggered by contamination. Activities undertaken through the CIFSI have allowed for targeted outputs associated with each of the three components to be produced (food safety systems, traceability systems, and biosecurity standards).

The fundamental questions that remain are to determine the extent to which the systems put in place will be adopted by industry, and are used in meeting future requirements. The ultimate value of the framework established through the CIFSI will be determined over time, as participation in these various components is tracked. On that point, the early findings presented in this evaluation present a mixed portrait. For those industries where food safety is seen as essential to access targeted markets, participation in these programs is significant; Where food safety control systems are only an anticipatory requirement, participation is less even.

5.3 Efficiency and Economy

The agriculture and agri-food sector is a multi-billion dollar industry that plays a critical role in Canada’s economy, and, as illustrated in crises such as the BSE one, it takes a single contaminated animal to shut down a whole component of that sector, in which case the economic costs are measured in the billions of dollars. In that sense, investing $107 million to secure a multi-billion dollar industry can be dramatically more efficient than providing no investment and having to manage the negative consequences associated with another BSE crisis.

The extent to which the ultimate goals of the CIFSI will have been efficiently realized with the least amount of resources possible will be largely determined by the extent to which the set of systems and standards established through the CIFSI will be used by the agriculture and agri-food industry. As already noted, participation levels are an indicator of the extent to which each of these systems and standards were required to secure Canada’s access to food-related markets and to ensure that the highest level of food safety is offered to Canadians. This, in turn, largely determines the extent to which efficiency and economy were demonstrated as part of the CIFSI’s implementation.

6.0 Issues and Recommendations

Issue #1

The evaluation found that there appears to be variation among sectors in the relevance of HACCP-based food safety systems. In addition, the anticipated amount of funding required by industry to develop food safety systems and industry led-traceability systems was not as high as originally anticipated. These key findings suggest that AAFC’s programing and industry’s needs may not be aligned.

Recommendation #1

AAFC’s Strategic Policy Branch, in consultation with other branches, should complete a needs assessment examining current industry and market needs and priorities related to assurance systems, to inform future AAFC policy and programming decisions.

Appendix A: Management response and action plan

Recommendation	Management Response And Action Plan (MRAP)	Target Date	Responsible Position(s)
AAFC’s Strategic Policy Branch, in consultation with other branches, should complete a needs assessment examining current industry and market needs and priorities related to assurance systems, to inform future AAFC policy and programming decisions.	CIFSI programming was originally focused on on-farm systems development. New programming will need to focus on buyer requirements along the agri-food chain. As part of the Growing Forward 2 policy development framework, the department performed targeted research and analysis in order to capture the evolving market and regulatory food safety context and related industry requirements, both short and long-term. In order to help position the sector for early adoption of anticipated requirements (i.e. sector responsiveness and ability to adapt), and in preparation for the next policy framework, we will perform a needs assessment to determine if a more targeted programming approach for specific sectors along the agri-food chain (particularly on-farm / post-farm) is required.	December 2016	SPB with PB and MISB

Recommendation

Management Response And Action Plan (MRAP)

Target Date

Responsible Position(s)

CIFSI programming was originally focused on on-farm systems development. New programming will need to focus on buyer requirements along the agri-food chain.

As part of the Growing Forward 2 policy development framework, the department performed targeted research and analysis in order to capture the evolving market and regulatory food safety context and related industry requirements, both short and long-term.

In order to help position the sector for early adoption of anticipated requirements (i.e. sector responsiveness and ability to adapt), and in preparation for the next policy framework, we will perform a needs assessment to determine if a more targeted programming approach for specific sectors along the agri-food chain (particularly on-farm / post-farm) is required.

December 2016

SPB with PB and MISB

Appendix B: Status of Food Safety Systems following Growing Forward

Sector	Name of System	System Status
Sector	Name of System	Technical Review Part 1 (HACCP Plan)	Technical Review Part 2 (Audit & Management)	18 month review (ongoing CFIA oversight)	Full CFIA Recognition
*CanadaGAP now includes the Re-Packing and Wholesale Food Safety Program
Beef	Quality Starts Here / Verified Beef Production	2009		Yes
Dairy	Canadian Quality Milk	2003	2006	Yes
Pork	Canadian Quality Assurance Program	2004		Yes
Turkey	TFC On-Farm Food Safety Program	2006	2011	Yes
Chicken	Safe Safer Safest	2002	2006	Yes	2013
Chicken	Free Range	2011		Yes
Produce	CanadaGAP 6 commodity groupings*	2006-2009		Yes
Eggs	Start Clean, Stay Clean	2004	2007	Yes
Broiler hatching eggs	Canadian Hatching Egg Quality	2004		Yes
Grains	ExcelGrains	2006	2009	Yes
Sheep	Food Safe Farm	2012		Yes
Goat	Goat On-Farm Food Safety Program	2013		Yes
Deer, elk	Cervid On-Farm Food Safety Program	2013		Yes
Veal	Verified Veal Program / Fédération des producteurs de bovins du Québec	2010		Yes
Honey	Canadian Bee Industry Safety Quality Traceability	In progress		Yes
Herbs	Good Agriculture and Collection Practices	2008		Yes

Post-Farm Programs

Sector	Name of System
Wine	Safe Winemaking Program
Packing	PACsecure
Retailers	Retail Food Safety Program
Water	CBWA Food Safety & Quality Program
Trucking	Trucking Food Safety Program

Appendix C: Government Traceability Infrastructure, Major CFIA Results

Government traceability infrastructure	Major CFIA results
Legislative framework	The Safe Food for Canadians Act, which came into force in November 2012, amended authorities to provide all of the essential regulation-making authorities required for full traceability.
Regulatory framework	A proposed amendment to the Health of Animals Regulations for pig traceability was published in Canada Gazette Part 1. The Health of Animals Regulations was amended in 2010-2011 to revoke all non-electronic cattle tags, which would lead to a system where all tags were electronic. A proposed multi-species regulatory framework for traceability was developed, for use in future consultations and regulatory modernization. CFIA also completed various policy analyses, including related to information sharing, use of information, legal considerations, international traceability, and other activities.
Administrator agreements	An administrator agreement was revised and signed between CFIA and the Canadian Cattle Identification Agency in 2012. CFIA worked with the Canadian Pork Council to develop an administrator agreement. When pig regulations come into force in January 2014, it is expected that the Canadian Pork Council will become the administrator of the pig traceability system. Criteria for an organization to be qualified as an administrator were developed.
Privacy Impact Assessments (PIAs) on administrator agreements	CFIA completed a PIA for the data collected by the CCIA in 2009-2010. Completed threat risk assessments for ATQ and PigTrace database.
Information-sharing agreements with provinces for sharing premises identification data	Information sharing agreements were signed with Manitoba (in 2011-12) and Alberta (in 2012-13). Other agreements were in development.

Appendix D: Project activities under Growing Forward for Food Safety Systems Development and Industry Traceability

Food Safety Systems Development

Commodity	Name of System	Growing Forward Funding Received For
Beef	Quality Starts Here / Verified Beef Production Program	Review/enhancement of system after 18-month review For the development of additional tools for producers for education and record-keeping, and also to promote the program to producers in a continued effort. The CCA, along with CGC, developed of an electronic database to help with the management of the on-farm food safety conformance system.
Dairy	Canadian Quality Milk	For the development of a national database ((National Electronic Administration System (NEAS)) for their Canadian Quality Milk (CQM) food safety program.
Turkey	TFC On-Farm Food Safety Program	Update system and completion of the Management System and the CFIA Technical Review Part 2
Chicken	Safe Safer Safest	Pilot of final phase (3^rd party audit) of CFIA’s Recognition protocol
Produce	CanadaGAP	Food safety system for 6 commodity groupings; Technical Review Part 1; benchmarking against GFSI Integration of CHC’s CanadaGAP and CPMA RWFSP
Produce	Re-Packing and Wholesale Food Safety Program (RWFSP) (now integrated in CanadaGAP)	Feasibility study for integrating the delivery of two food safety systems – CanadaGAP and RWFSP To undergo CFIA Technical Review Part 1 recognition process
Grains	ExcelGrains	To update the food safety system Integrate biosecurity protocols; training sessions, communications and awareness activities, develop auditor competencies and qualifications, incorporate producer and auditor data into software system
Sheep	Food Safe Farm	Develop OFFS Management System; Train-the-trainer; training auditors; completing Technical Review Part 1 and updating generic model; completing producer manual Enhance system, training; development of management manual for Technical Review Part 2
Goat	Goat On-Farm Food Safety Program	Completing Technical Review Part 1; Develop mgmt. system; communication and train-the-trainer
Deer, elk	Cervid On-Farm Food Safety Program	Complete Technical Review Part 1, to develop communication and training tools, to develop on-farm management software
Veal	Verified Veal Program / Fédération des producteurs de bovins du Québec	To undergo CFIA Technical Review Part 1 recognition process
Honey	Canadian Bee Industry Safety Quality Traceability Program	Update system and prepare for submission to CFIA for Technical Review Part 1. Translate documents for Technical Review Part 1
Wine	Safe Winemaking Program	Improvement to Good Winery Practices food safety material Develop implementation and system management tools
Individual packaging materials	PacSecure	Develop new subsections to existing food safety program; online training and train-the-trainer program; develop an audit process; pilot recall and traceability components of standard; perform annual review; communication materials Undertake Technical Review Part 1 process
Retailers	Retail Food Safety Program	The development of support material for the Retail Food Safety Program and the Safe Food, Safe Customer Program; and effectiveness reviews of program revision and new support material.
Water	CBWA Food Safety & Quality Program	Develop new food safety materials Develop a management system for their Plant Inspection Program, to develop a management system for document control of their Food Safety & Quality Program and to create an online training program for plant operators.
Trucking	Trucking Food Safety Program	Update existing system and develop an management system
Food banks (Food Banks Canada)	Food Handling Program	Develop materials for trainers, and hold "train-the-trainer sessions"
Canadian Supply Chain Food Safety Coalition		Competencies and qualification of food safety auditors and develop of food safety audit infrastructure
Canadian Federation of Agriculture		Provide support and training for national producer organizations
Kosher	Canada Kosher 22000	Examine and integrate food safety issues related to kosher products Pilot standards and audit methodology Test standards and audit previously developed and introduce completed standards for recognition program, develop sustainable business model
Organic		Feasibility study to either develop new food safety systems for organic producers or work to adapt existing systems.
Gluten-free foods (Canadian Celiac Association)	CCA Gluten-Free Management System, Standard and Tools Development	Development of a strategic plan to address gluten-free claims and feasibility of a certification process Develop on-farm and post-farm gluten-free modules and tools, to complement existing food safety systems

Industry Traceability Infrastructure

Commodity	Name of System	Growing Forward Funding Received For
Pork	PigTrace	To develop an ID and traceability system for the hog sector Aggregating swine movement info into a centralized database
Cattle	Canadian Cattle Identification Program	Researching reading equipment at auction markets Strategic Assessment of tag distribution system Communication roll-out of de-listing of barcoded dangle tags Upgrades to the Canadian Livestock Tracking System Researching tag distribution models and develop a business plan Evaluating impact of RFID tags on commerce at auction markets and prepare business case To make data integrity changes to the CLTS To work with ATQ to develop a plan to create a national traceability database
	ATQ	Improvements to Agri-Trace’s automation and validation functions Reinforce capacity to improve traceability data by removing errors
Livestock	West Hawk Lake Zone Initiative	Develop zoning capability in Canada
Equine	CanEQUID	Study and strategy to prepare the sector for a national equine traceability program
Sheep	Canadian Sheep Identification Program	Pilot the implementation of RFIP technology Continue to pilot-test the implementation of RFID technology and explain the benefits to producers
Sheep & Goats	Animal ID Traceability Program	Animal Identification and traceability education; development of implementation plan for sheep and for goat. To implement communication strategies for sheep, implement mandatory ID for goats, implement mandatory RFID for sheep; promotion, awareness and education materials
Bison	Bison Industry Traceability Program	Development of premises ID and animal movement
Deer and elk	Cervid Industry Traceability Initiative	Develop traceability and management system
Dairy	National Dairy Traceability System	Develop a plan to deliver a national traceability system for the dairy industry
Dairy	National Dairy Traceability System	Develop an industry –wide strategic plan to implement the national traceability system
Eggs	Egg Industry Traceability System	To establish national traceability standards
Wild Capture Fisheries	National Seafood Certification and Traceability Project: Capture Fisheries Certification and Chain of Custody Components	Development of an industry-led Canadian system to certify capture fisheries and fishery product chain of custody compliant with the FAO marine fishery guidelines.
Maple syrup	Identification des barils de sirop d’érable par puces électroniques	To examine the feasibility of replacing paper labels with electronic chips on barrels of maple syrup
Lobster	Lobster Traceability Pilot Project	Develop traceability system, test implementation
Aquaculture	National Seafood Certification & Traceability Project: Aquaculture Sector Certification and Chain of Custody Components	Develop an industry-led Canadian system to certify aquaculture and aquaculture product chain of custody compliant with the FAO aquaculture guidelines
Herbs and Spices	CHSNC Traceability Tools	Develop a series of traceability tools The project established the form of the tools developed in the previous project.

Footnotes

Footnote 1

Canadian Cattle Identification Agency. Summary of Cattle Industry Traceability Plan. 2012. Edge. J. Grant, M. and Howard, A. Forging Stronger Links: Traceability and the Canadian Food Supply Chain; Traceability (Product Tracing) in Food Systems. 2012. New Russia, Japan Meat Trade Policies Highlight Food Safety Issues. International Centre for Trade and Sustainable Development, Volume 17, Number 4, February 6, 2013.

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Footnote 2

The initial funding for the CIFSI was set at $95.6 million over five years (2008-2009 to 2012-2013). An additional $11.6 million was allocated in March 2011 in support of the Government Traceability Infrastructure for the TNIP.

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Footnote 3

TBS Budgeted Vote 10 funding was to be distributed over five years between Food Safety Systems Development ( $18.75M) and Industry Traceability Infrastructure ($28.41M).

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Footnote 4

Public Health Agency of Canada website

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Footnote 5

Ibid

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Footnote 6

"Listeria monocytogenes outbreak". Canadian Food Inspection Agency. 2009-03-12. Archived from the original on 7 February 2009. Retrieved 2009-03-20.

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Footnote 7

An Overview Of the Canadian Agriculture and Agri-Food System, 2012.

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Footnote 8

FDA US Food and Drug Administration: About FSMA, Accessed. Feb.10, 2013.

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Footnote 9

USDA Food Safety Innovation in the United States: Economic Theory and Empirical Evidence from the Meat Industry

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Footnote 10

Information valid as of October 2013.

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Footnote 11

At the time of the evaluation, the grain and aquaculture sectors had not initiated the recognition of their food safety systems and had not expressed an intention to do so.

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Footnote 12

Data presented in this report are based on a series of voluntary questions included in the Farm Financial Survey conducted by Statistics Canada in 2006, 2009, and 2012.

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Footnote 13

Canadian Cattle Identification Agency. Summary of Cattle Industry Traceability Plan. 2012.

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Footnote 14

Edge. J. Grant, M. and Howard, A. Forging Stronger Links: Traceability and the Canadian Food Supply Chain; Traceability (Product Tracing) in Food Systems. 2012. New Russia, Japan Meat Trade Policies

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Footnote 15

Canadian Food Inspection Agency. Canada and the United States sign agreement on animal disease zoning .Media release. January 2013.

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