:
Thank you very much, Mr. Chairman.
My name is Thomas Olson. I am the chairman of the Bison Producers of Alberta. Perhaps I can give a little background to the BPA and its interest in food safety.
Bison producers in Alberta represent approximately 25% of the bison production in the world. We supply bison throughout Canada, the United States, and Europe.
Food safety is an important issue to us. A previous failure in Canadian food safety almost destroyed the bison industry in Canada and Alberta, through no fault of the bison producers. In 2003, BSE was discovered in a beef cow in Alberta. The borders immediately closed. Bison meat, which was mostly exported, was now unable to move across international borders and, unfortunately, because of rules in Canada, was not able to move across provincial borders either. A disease that bison does not get, from feeding practices that bison producers do not use, caused a financial meltdown in the bison industry from which it has not yet recovered.
This was a problem that we understand was due to irresponsible behaviour by CFIA in failing to prohibit feeding practices that could reasonably cause BSE. We understand that it was not a failure of science, but a failure of political and bureaucratic will--a failure to do what was right. Unfortunately, those who caused the problem did not bear the consequences of that problem.
What is the role of a primary producer in food safety? Bison ranchers expect to do their part. Clearly, food safety begins on the ranch, and ranching practices can affect not only the quality of the food but the safety of the food also.
Because bison were the keystone species on the prairies, they have a natural ability to deal with our climate and our rangeland. Bison are naturally healthy animals, with highly evolved immune systems that help them to deal with disease more effectively than domesticated and imported livestock species. Accordingly, bison producers avoid using chemicals that could have the effect or perceived effect of compromising food safety. Antibiotics are not common with bison producers. Many ranchers do not use them at all, and those who use them use them sparingly and with the advice of a veterinarian. Certainly, they are not part of the regular diet of bison.
Because bison are well adapted to native rangeland, there is less need for producers to rely on various pesticides, which have become perhaps all too standard in agriculture. We do not use growth stimulants, including hormones, in bison. We adhere to the philosophy that bison are healthiest and produce healthy food when they are not unnaturally crowded or subject to unnatural stressors.
The BPA would like to emphasize two objectives for food safety.
First, BPA believes that the protocols and enforcement of food safety must be effective; that is, they must achieve the desired results. It should be done with a scalpel, not with a meat clever. It must precisely deal with the potential food safety problems. Without effective food safety protocols, we cannot assure the consumers in Canada of the safety of their food, nor assure our trading partners of the safety of our food.
Secondly, food safety protocols must be reasonable and practical. In our rush to ensure food safety, we cannot substitute effective protocols with endless paperwork and other busy work; otherwise we will have either more expensive food or a food industry that is not competitive, or both.
The cost of food safety is a societal cost and should not be borne by the producer alone. There is a tempting trend amongst governments to offload the cost of food safety onto primary producers or perhaps others in the food chain. Food safety is a public issue and needs public funding. If all of the costs of food safety are borne by producers, the following consequence will arise: the cost of food will increase. To the extent that food safety causes increased food costs, it becomes a regressive tax. Certainly the costs of food safety should not be borne by those most vulnerable in our society, including children. This is a society cost and must be borne by society.
Primary producers and others in the food chain may become uncompetitive in Canada and abroad. This will mean a reduced food industry in Canada, less tax revenues and less employment. Certainly there is no need to hamstring the cashflows of the food industry with the costs that should truly be public costs. Food safety should be part of the Canadian infrastructure.
Already, over half the bison in Canada are exported live to the United States to be processed there. There are many reasons for this, but the main reason is that it is simply cheaper to process animals in the United States than it is in Canada. Adding more costs to the Canadian system will only cause it to sink under the weight of endless bureaucracy.
Processors and, indirectly, producers already pay for food safety features, including the cost of inspectors, rendering costs, and the costs of increasingly expensive testing. These costs are significant and make our industry less economic and our food more expensive.
Food safety protocols must be practical and reasonable. The BPA has had great frustration with CFIA and its political overlords, who have accepted some of CFIA's practices that might be summarized in some cases as straining at gnats and swallowing camels.
A costly example of CFIA's failure is its failure to provide for interprovincial meat sales from provincial processing plants that meet food safety requirements. We understand that CFIA does not dispute that most provincial plants in Alberta meet all reasonable food safety requirements, yet CFIA has not allowed interprovincial meat sales from Alberta plants. This exacerbated the problem that arose from BSE when Alberta producers, who produce a quarter of the bison in the world, had to consume most of that bison in Alberta because we could not get it across provincial borders.
The issue of the lack of bureaucratic will masquerading as food safety has been on our agenda for a long time. I met with the former Prime Minister and the former Minister of Agriculture and explained the problem to them. The former Prime Minister said, “So you're telling me that a bison slaughtered in Alberta and processed in Alberta is safe for an Albertan but not safe for an Ontarian.” When I replied “yes”, he turned to the Minister of Agriculture and said, “That's stupid. Fix it.” It's now several years later and it's not fixed. In fact, it's on the waiting list for surgery and may never get fixed.
I would like to say just as an afterthought that while this committee is looking at food safety, I cannot help but comment that it seems odd that we focus so narrowly on disease that comes from unsafe food but, at the same time, do not discuss disease that comes from unhealthy food. If we were to solve all of our food safety issues, we would still have a food supply that is often unhealthy. Never has so much “safe” food caused so much disease in the people of this nation.
Illnesses from unsafe food, while important, pale in comparison to illnesses that arise from unhealthy but safe food. We have a nation with a tremendous amount of obesity, heart disease, adult onset diabetes, and similar diseases. Bison is low in fat, high in protein, and high in micronutrients, yet schools are full of unhealthy food and snacks. There is little consumer education or awareness about the healthy Canadian food choices that are out there. When will the healthy food that we produce in this country get the support from government to compete with the unhealthy food that is far more lucrative and far more promoted in advertising?
In closing, I wish to reiterate that food safety protocols must be effective, practical, and reasonable. We hope this will start with the Government of Canada properly bearing its share of the costs of food safety and with CFIA providing for the interprovincial sale of meat from safe provincial processing facilities.
Thank you, Mr. Chairman.
:
I'm going to be speaking first. I'll do my comments in French. Peter will complete his comments in English.
[Translation]
Good afternoon, everyone. My name is James Laws and I am the Executive Director of the Canadian Meat Council in Ottawa. With me today is Peter Stein, Director, Quality Assurance and Food Safety, Piller Sausages and Delicatessens Ltd.
Piller's is one of North America's largest producers of European sausages and delicatessen-style meats, famous for award-winning products, such as Black Forest ham and European- style dry cured salamis. They also make the number-one selling dry- cured pepperoni in Canada according to ACNielsen data. They are headquartered in Waterloo, Ontario.
Their customers are nation-wide and they also export to the United States. And some of their customers are considered high-risk customers like hospitals, retirement homes etc. They recognize, as do others, the responsibility of supplying these types of customers from the top down.
Piller Sausages and Delicatessens Ltd. has been a member of the Canadian Meat Council for 35 years. Just last month in Montreal at our 89th annual conference Wilhelm Huber Senior, the founder of Piller's, was presented with our President's award for outstanding service and support to the Canadian Meat Council. He served on our board for many years as does his son Conrad Huber, now a past president and a member of our executive committee.
Wilhelm Huber Senior is the founder and chairman of the board of the Piller's group of companies and he has been a fourth generation master butcher and sausage-maker since 1949—that's 60 years. He immigrated to Canada in 1954 from Austria with only two suitcases and got his first job in Montreal with Sepp's Sausages as master sausage-maker. In 1957, he moved his family to Waterloo, Ontario with $500 and started a company called Piller Sausages and Delicatessens Ltd.
Today, the Piller's group of five federally registered companies consists of Piller's Sausages, Kretschmar, Golden Valley Farms, Piller’s Fine Foods and Piller's Distribution Centre and employs over 700 people. And Piller's is still a Canadian family-owned and run business with Wilhelm's two nephews and three sons on the senior management team. In fact I believe there is a history book on the family that is currently being passed around the table.
As meat processors we are one link in the food safety chain in Canada. From the farmer to the slaughter and cut plants to the processors like Piller's to the retailers and finally the end user we all need to have food safety up front and centre so that we pass on a safe product to the next link in the chain. This chain is the same and carries the same responsibility no matter if you're a local, provincial or federally registered establishment. It's a matter of principle, attitude and accountability.
Piller's was a provincial plant 41 years ago. And then they made the change to become federal in 1968. They have been very successful since then proving that the successful transition from provincial to federal is very possible.
Peter Stein was hired by Piller's in February of this year to be their new Director, Quality Assurance and Food Safety. Peter has been active on our technical committee for 12 years and has been a member of our Listeria working group since last summer. He is also on the industry best practice committee specifically contributing to the sanitization component. Peter worked for over 20 years for JohnsonDiversey—a leading global provider of commercial cleaning and hygiene products and technical support for food safety. Peter specifically provided the technical support to the meat and poultry sectors in plant hygiene and sanitation programs. Peter has been through most federal meat processing plants across Canada and many in the United States, and he likely knows more about in-plant Listeria control than anyone I know.
Listeria control is about good plant hygiene—good manufacturing practices, and cleaning the plant and equipment. But, it's also about equipment and building design; it's about proper maintenance and cross-contamination control; it's about control of the flow of people and products in the work environment and it's about environmental sampling of the packaging room and slicers and beyond.
I'll pass it over to Peter to explain what's been happening at Piller's.
:
Thank you very much, Jim.
What I'd like to do first is to pass around some of our products, just to show you some of the things we make, and then I'll continue on with my thoughts.
Good evening, everyone. As Jim said, my name is Peter Stein and I'm the director of quality assurance and food safety for Piller's.
I first wish, on behalf of the Piller's group of companies, to extend our condolences to the families who experienced loss during last year's listeriosis outbreak.
As an industry, we share in the responsibility of food safety in Canada and beyond. We believe that food safety is not a competitive edge, and we are working with the Canadian Meat Council and industry to focus on improving food safety in our own plants and across the industry. At Piller's, we have internally raised the bar in food safety and we take full responsibility and ownership of the commitment to ensure that our plants produce safe product for our retail and food service customers and, ultimately, the end consumer.
I have been looking forward to presenting to you today and discussing who we are and what we are doing to improve food safety in our facilities. Of course, I can only speak for our organization on these matters, and I look forward to your questions afterwards.
Last summer the processed meat industry changed forever in public perception and confidence. This, in turn, has changed the food industry, and I think the same can be said for the CFlA. We all need to work together and do the right things to improve and restore consumer confidence and product safety, by walking hand in hand down the same road in the same direction.
I assure you that recently the pace of change has increased significantly: changes in what the end consumer expects from our industry, confidence in the food safety of the products they buy. But end consumers also want more value, lower salt, less fat, allergen controls, and a cleaner ingredient list. As well, our customers have expectations for us to produce products with a longer shelf life, and we experience market pressures from imports and changing Canadian export regulations.
For us at Piller's, we are singularly focused on stepping up a number of programs and initiatives in each plant to be proactive in an ever-changing environment. As a result, we have been continually improving our food safety programs and systems corporately. We look for potential issues and concerns, then investigate the risk and follow the science in making our corrective action decisions.
These would include more aggressive sanitation practices, including two equipment inspections during the sanitation shift. We have implemented daily food-contact surface sanitizing before production starts, at breaks, lunch, and shift changes. We have new sanitation equipment that allows better cleaning of parts that are normally difficult to clean by hand. We are changing sanitizer chemistry to a more effective and aggressive program that is less affected by water quality and is specific to proteins. We have implemented a three-tier program for packaging equipment disassembly and cleaning protocol, including deep internal testing for bacteria. We are increasing our quality assurance staff in every plant to improve our monitoring capabilities. We hired a corporate quality assurance and food safety director to help bring an overall consistent focus on food safety. We are on track to double our micro-testing across the board for environmental and product testing. We are actively looking for problems even where we currently have no surface evidence of there being any.
Our most recent food safety news is that we have installed two new high-pressure cold pasteurization machines that cost our company over $8 million. We are taking food safety seriously. We invested heavily in this new processing technology, including the two largest high-pressure processing units in North America. Piller's had looked into this technology years ago and decided to move forward in November 2006. The initial reason for entering into this $8 million investment was for removing additives and preservatives from the ingredient lists, as requested by our customers. This technology kills all bacteria, including pathogens, from the products already in their retail packages without the additives. I have some examples here of samples that are treated and untreated just to show you that there really is no difference in the appearance of the product.
Having said all this, Piller's did have their first voluntary product recall this April. There were no illnesses reported. It was a small recall, with very little product, involving only one plant and involving only one piece of equipment in that plant. We did go over and above what CFIA recommended and voluntarily recalled any product that was still in circulation from that line. We acted quickly and made the right decision with no hesitation. What happened to us this April just confirmed to us that listeria is a clean-plant concern, and no matter what is being done in the name of food safety, there is always opportunity and the need for improvement.
In every one of our four production facilities in Ontario, we use state-of-the-art meat processing equipment, the most up-to-date smokehouses, and the highest quality slicing and packaging production machinery. All of our facilities are fully networked with the most advanced high-tech computer systems. As a result, we have the capability to manufacture all our products at any one of our facilities, so we can meet the demands of any customer, any request, any time of the year.
As of April 1 this year, the new listeria testing program has caused our registered warehouse facility in Waterloo to store over 700 additional pallets of product on a hold and release program, waiting for test results at any one given time. Meat processing facilities, including ours, employ highly professional food science and microbiology experts to maintain their food safety programs. We also endeavour to work closely and openly with CFIA to help them understand our processes and to implement and follow federal programs correctly. We do encourage CFIA to implement their new initiatives fully and properly in all federal establishments equally to ensure consistency and uniformity. We have recognized that this can be a challenge at times.
I didn't want to close without presenting a comment or a wish list. So some of the things we at Piller's feel strongly about are as follows:
One, imported products must meet the same standards and regulations as we face here in Canada.
Two, all plants, both provincial and federal, should be included in the scope of the new listeria policy released this past April 1. This safeguards all potential customers.
Three, more and faster access to new industry innovations and interventions is needed.
Four, the food industry is now the largest in Canada, recently surpassing the automotive industry. Therefore, we need the same access to government research and innovation funding to facilitate widespread food safety improvement nationally.
Five, we must have clarity of interpretation and consistent implementation of existing and new regulations and programs across Canada.
Thank you very much for your time. We look forward to any questions you may have.
:
Good afternoon, and thank you for the opportunity to present to you today the views of the Canadian Pork Council on food safety issues.
The production of safe food is of primary concern to all involved in the agrifood industry. Canadian hog producers see the implementation and demonstration of production practices that address food safety at the farm level as central to their business activities.
Beginning in 1995, the Canadian Pork Council assembled a team of food safety and production experts to develop a system that would be used by primary producers to evaluate, document, and have their production practices verified to demonstrate due diligence in their activities. When the program was launched in 1998, the hog industry was about to face a crash in the price of hogs, and producers questioned the necessity of implementing a program that reflected practices that were largely already in place. The answer then, as now, is that the program allows producers to demonstrate what they are doing.
The CQA program introduced the HACCP approach on the farm. At the time, HACCP was being widely adopted by the processing industry but was new to the farm sector. Since that time, 19 commodity groups, including the CPC, have agreed to create HACCP-based on-farm food safety programs. Simply put, we are HACCP-based rather than pure HACCP, because the risk analysis that is conducted is done at the national level and translated into materials for producers to use on the farm, rather than having each production unit develop its own HACCP model.
Participating production units are enrolled through the provincial hog boards and implement the program as it is laid out in the program materials. To gain and maintain recognition on the program, a production unit must undergo an annual validation, essentially an audit, to ensure that all CQA requirements are being met. These requirements address potential chemical, physical, and biological hazards that may be introduced to the pig during production. Hazards such as drug residues, broken needles, and bacterial contaminants are controlled on the farm through the implementation of strict protocols related to the use of medications, whether these are administered directly to the pig or delivered through feed or water; the storage, mixing, handling, and delivery of feed; barn sanitation and bio-security, including rodent control; and staff training. Bio-security will also be addressed through the newly created Canadian Swine Health Board, ensuring that hog producers have the latest information and approaches to minimize disease risks.
The success of the CQA program tells the story. There are approximately 7,000 production units, representing over 70% of total Canadian production and over 90% of hogs slaughtered in Canada. Almost all federally inspected packing plants and many provincially inspected plants have made CQA recognition a condition of sale. That is, producers can sell to these plants only if they are on the program.
The program provides assurances to customers and consumers that Canadian hog producers are committed to doing all they can at the farm to control potential food safety hazards. With pork exports to over 100 countries valued at $2.7 billion in 2008, providing these assurances is critical.
Although in its 11th year, the CQA program continues to evolve. Administrative and technical committees conduct ongoing work to ensure that the CQA program maintains currency in scientific understanding, production practices, and legislative developments.
With the program structure in place, we are now able to add new elements. Animal care has been identified as an important public concern. In consideration of that, an animal care program was introduced in 2005. While participation in this element is still growing, the CQA program and structure have made launching this initiative a smoother undertaking.
Additionally, new activities for access to specific export markets are also easier to implement. For example, a protocol for Paylean-free pork exports to certain countries has been developed, and we are looking at other possible initiatives.
The existence of a solid national on-farm food safety program is critical. It means that one standard is set for food safety, preventing a proliferation of company-specific or province-specific initiatives. While on-farm food safety programs are industry driven, government involvement is key. The collaboration of the Canadian Food Inspection Agency in the development of the programs and the recognition process is essential in providing credibility to customers of Canadian pork.
It can also be argued that government funding to help in the ongoing maintenance of these programs is important. Funding has been available for development and implementation, but not for ongoing program maintenance. Producers bear the cost of implementing these programs; there is no premium available to them. While these programs offer a benefit to the industry and a public good, they essentially add to the cost of production for our producers.
Funding for food safety research and the role of on-farm controls is also required.
Government commitment to on-farm food safety also needs to be in the domain of an efficient and streamlined regulatory system. Hog producers have been unable to access new veterinary products in as timely a fashion as producers in other countries. Despite the continual examination and review of Canada's drug licensing system, Canadian producers remain at a disadvantage. We recognize that Canada is a small market for veterinary products, but our sector is competing in the global market. It is critical that our regulatory system be the most competitive possible.
We cannot appear here today without mentioning the financial crisis facing Canadian hog farmers. Our industry has been a solid contributor to the Canadian economy, yet it has been faced with severe market shocks over the past three years, the most recent being the H1N1 influenza A, unfortunately known more commonly as swine flu.
Surveys conducted in the aftermath of H1N1 show that while most Canadian consumers remain confident about the safety of pork, fully 8% of those surveyed believed it was possible to get H1N1 from eating properly cooked pork. In addition, while 90% of consumers will not change their pork consumption as a result of H1N1, or will eat more pork, 10% are eating less pork. Some of this is likely to be permanent. These are serious impacts on consumers as a result of a virus that has nothing to do with food safety. This has impacted hog producers at a time when they can ill afford any more shocks.
Farmers are doing their part and will continue to do their part to produce safe food. Governments need to support these efforts and to ensure producers can operate in the most competitive environment possible.
Thank you.
:
Thank you, members of the committee, for the opportunity to be here today.
The Canadian Sheep Federation is a national non-profit organization that represents over 11,000 Canadian sheep producers. It has eight provincial members and three associate members: the Canadian Co-operative Wool Growers, the Canadian Sheep Breeders' Association, and the Canadian National Goat Federation. The Canadian Sheep Federation plays a key role in the development, implementation, and management of programs that enable the industry to remain competitive, innovative, and responsive, such as the voluntary scrapie flock certification program, the bluetongue insurance program, the Canadian sheep identification program, and the food safe farm practices program.
Food safe farm practices is a national HACCP-based program that the industry began working on in 1997. The development of this program was truly a collaborative initiative, with representatives from both federal and provincial governments, member associations, and producers working together. In 2005, the program received technical recognition from the Canadian Food Inspection Agency. This producer-driven program examines all areas of production and outlines management options that are designed to minimize food safety risks. It is based on "must do" good production practices. Good production practices are operating procedures that promote food safety and production efficiency. The program also makes recommendations on practices geared to facilitating the production of a safe, high-quality product.
To date, the CSF has provided training to over 1,000 producers, either through workshops or through online training. In addition to training producers, the federation is working towards technical recognition for its management manual. Canadian sheep producers understand the importance of, and are committed to, supplying safe, high-quality lamb. The food safe farm practices program is just one program that they have access to. They also participate in the Canadian sheep identification program and various health programs that contribute to the safety and quality of their product. Together, these programs allow producers to anticipate problems, develop troubleshooting techniques, and reduce on-farm risks to food safety. The food safe farm practices program, in particular, allows producers to prove that they are doing what they can to minimize food safety risks.
One of the challenges the industry has with the food safe farm practices program is the producer's ability to recoup the additional costs of implementation. There needs to be some incentive for producers to participate. In the best-case scenario, producers will be implementing the program in response to market incentives under which they get paid a premium for the added assurance that they have been certified by a food safety program.
Especially in the lamb industry, where so much of the lamb being consumed is imported, there is a real need to ensure that the programs producers participate in do not put them at a competitive disadvantage. It is the issue of competitiveness that may cause some producers to hesitate when being asked to implement the program. One way to ensure that Canadian lamb producers remain competitive is to require imported products to meet the same standards that Canadian producers must meet.
Work also needs to be done to harmonize meat processing codes in Canada into a single standard. Currently, it is difficult for Canadian lamb producers to access some Canadian markets. With 60% of Canadian lambs being processed in Ontario—90% are processed in provincially inspected plants—it's difficult for Canadian producers to have access to, let alone compete in, markets such as British Columbia, which is Canada's second largest lamb-consuming market.
Producers must also be price competitive. The food safe farm practices program has the potential to increase production costs for lamb producers, and they have limited options for cost recovery. This could cause the program to be too costly to implement, or it could drive up the cost of Canadian lamb, making the imported product more attractive to consumers. Both scenarios are troubling. In both cases, there is the potential to lose Canadian producers and there is limited ability to ensure that Canadian consumers have access to high-quality, safe product, especially when the imported product does not have to meet the same standards as the Canadian product does. Food safety is not just the responsibility of Canadian producers.
If we are going to continue to deliver the safe, high-quality food that Canadian consumers have come to expect, then a collaborative approach, which includes producers, processors, retailers, consumers, and government, is required. With such an approach, the cost of ensuring the supply of safe, high-quality food is shared.
To date, the industry and government have enjoyed a collaborative approach to on-farm food safety. Both recognize the need for on-farm food safety programs, and while the government has provided some financial support, expertise, and guidance during the development, they have recognized that in order to be successful, food safety programs need to be developed and managed by industry in order to ensure that they are practical on farm and meet individual industry requirements.
Government support with development and training has been greatly appreciated. However, the issue now is program implementation, ensuring that producers are audited and that commodity organizations have the resources for ongoing maintenance of the program.
It should be noted that the costs of developing the on-farm food safety programs have not rested solely on the shoulders of government. One of the real benefits of this process has been the recognition of producer time as a contribution to the cost of development. Additionally, national and provincial organizations, which are funded through producer levies, have also contributed substantial amounts of time and money.
Canada's collaborative approach to on-farm food safety programs is also seen among the commodity groups. The commodity organizations that are currently working on their food safety programs sit together around the Canadian On-Farm Food Safety Working Group table, where they can discuss common challenges and share information. The capacity to do this has proven to be invaluable. It is vital that this collaborative approach to on-farm food safety continue. While Canadian lamb producers remain dedicated to the production of safe, high-quality product, the Canadian government must make this same commitment and ensure that Canadian producers remain competitive.
Thank you.
:
Thank you. That's a very interesting question.
When you go through a situation like that at any scale, certainly the responsibility is with the facility and with management, whether it be ownership or not. However, you are dealing directly with CFIA, and dealing with different branches of CFIA, whether operations or the OFSR. It would be better, in my opinion from having gone through it, to work as a team and to approach the media and the public as a team, to work together in that sense rather than have the onus of response be on the facility or on management.
I understand your question very well. It's not to say that CFIA, when we had our incident, wasn't there. They were, and the people we know and work with every day were very helpful. At the same time, different programs and different departments kick in once this happens, and because of that, at least we noticed that there was a bit of a disconnect. We took the initiative and did what we had to do, above and beyond what was required or even necessary. That's just the way our company is. Those are the morals and the ethics of the way we do business.
But yes, it would be nice to work together with CFIA or with government agencies, to approach the public together and move forward that way through any kind of incident like that, absolutely.
:
Thank you for your question.
Perhaps Martin could pass around a few of our products. Please note that in the case of a product like pepperoni, which is dry and salted, Listeria cannot develop, from a scientific perspective. We have a policy that varies according to three different categories. If you use an anti-microbial agent, the number of mandatory tests is reduced. If you use an anti-microbial agent and there is a packaging process, the number is further reduced. On the other hand, people want the policy to be the same for a product like pepperoni and for a product that contains much more water, in which Listeria could very well develop. We believe that makes no sense, from a scientific point of view. We want to have some flexibility.
Perhaps we could get some products from the corner and pass them around.
There is the process that Peter explained to you. The company is using very high pressure. A product that is processed in the big machine we are talking about and that has been submitted to a pressure of 87,000 inches per... It is impossible for Listeria to survive under this pressure. We therefore believe that the policy should be amended to reflect this reality. That is why, in our opinion, there is not enough flexibility.
Furthermore, imagine that someone has built a state-of-the-art plant, that is only one or two years old, and that has separate rooms for each line. Then imagine that there is another building, perhaps even older than I am, that requires much more testing because of its design. There must be some kind of compensation for companies that show they always have excellent results. We are talking about mandatory agency tests.
:
Absolutely. Thank you very much for the question.
I think everybody has seen this picture. This is a picture of one our machines in one of our facilities. We use these two machines to treat or process all the products that go through that one particular facility.
The product is packaged in its finished package, and then it is put into this machine. The machine is closed, the chamber is filled with water, and then the water is pressurized to 87,000 pounds. It sits at that pressure for a number of minutes, then the pressure is released. The product comes out the other end and looks the same as when it went in.
What happens in the process is that any living organism cannot withstand that pressure, the microbial functions that bacteria go through can no longer function, they're disrupted, and they die. That's why it's in its finished product, in its package, and nothing can survive that process. It's a very clean, efficient process. The only net effect to the product is it comes out a little bit wet, and then we dry it off and package it off.
It's a very good procedure for killing the bacteria, if there are any in the product. We already have typically less than 10, or even less than three, count per gram going in anyway, which is a very low count. But you get a four-, five-, or six-log reduction from going through this piece of equipment, and you really have no bacteria. There are no bacteria left. We are continually doing tests. We have zero count coming out the other end. It's a great technology for that.
The problem is that it's very expensive. It's a batch system, not a continuous system, and to be able to do all the volume that we have in all our facilities would require many machines. So it's an expensive proposition, and of course you have to pick the products that you put through there, whether they be a lower-salt or a higher-risk product or what have you. But the technology is excellent, and we're using it on a full-time basis.
I think yes, absolutely, it's something that the industry is going to use and embrace, and you will see more of this technology in the coming years.
It's important to note that this technology really allows the ingredient list to be backed off. In other words, you don't necessarily need to put the preservatives into your ingredient list that you would if you didn't use this technology. This is a benefit and is really the primary reason Piller looked into this a few years back.
Also, as Jim mentioned, the testing protocol that we have to undergo from CFIA is the same for any product, even for a product that goes through this technology. As a matter of fact, this is pretty new technology. There is nothing in the regulations that dictates how we deal with this. We may be able to lower one category in testing, but honestly, the product is pasteurized in its package. Really, there is no risk to this product once it passes through the system. It passes through the system only in one way. If there are any faults or errors, the system shuts down and doesn't open. It has to be recovered, and we go through the system properly, maintaining and reaching that 87,000 psi, so there is really no way for anything to go through that isn't treated. It's a very safe, very accurate technology that gives us tremendous results.
As I said, it's definitely something that's going to be at the forefront; however, it's extremely expensive. It adds cost to the product, very minimal, but it's something that we feel in our organization is a very proactive approach to providing our customers with peace of mind on the food safety aspect of our products.
I'm not sure if everybody can do it, but certainly we made the investment before any of the listeria outbreak last summer and so forth. This was already in the works a year before that, so I think you will definitely see an increase in the use of this.
It was originally started to treat vegetables, I believe, and the units were very small, or much smaller. It has now been adapted for larger types of processing. You can treat hundreds of kilograms at a time in one cycle of this unit. The way the technology has improved over the years shows in how large a batch this technology can process. This unit is fully 20 feet high and 50 feet long. It's a big piece of equipment and weighs in excess of 200,000 pounds. It's a very robust piece of equipment that needs to be that size if you're going to be containing that much pressure. But we feel that's definitely part of the way of the future for food safety.
:
For some of our diets--mine included--you're probably correct. Some of us don't always make the best choices, and unfortunately, parliamentarians don't necessarily get to make the best choices here either sometimes.
What I've heard from nearly every group that's been represented--and the clerk will correct me if I'm wrong--is that it seems to me that every group primarily represents producers. And I'm looking at Ms. MacTavish now and Ms. Lawrence and Mr. Rice and Mr. Olson, for that matter, who have all talked about the cost. Whether it be a HACCP or farm safety program, or whatever acronym one uses--because we all love acronyms, I know--they work wonderfully well, but one of the things is the cost.
I don't want to sound overly naive, but no one has actually asked the question, what does it cost you? I want to preface that by understanding that we're not talking thousands of dollars per animal, and we all kind of get that, I think. But no one has ever said to us, “Well, this is the actual cost” in the sense that we can't recover. That seems to be the other piece of that question, because there isn't a way to incentivize it, as you said, when it comes to selling the product, because folks simply expect the food to be safe.
So if the government is going to pick up the cost--and I know I probably don't have much time to get it--but what is the sense of the cost there? Do you have a sense of that cost?
:
I certainly can. Thanks for the question.
We had read in some media reports that some groups had been saying that this pre-market label approval process was a food safety issue. I did send a letter to each member of this food committee, wanting to clarify that we, the Canadian Meat Council and our members, strongly disagree.
Getting a label pre-approved—that's the important part, pre-approved—by somebody sitting in Ottawa who may never have been into a meat plant in their lives has nothing to do with food safety. What does have to do with food safety is making sure that the label on the container is correct.
The meat industry gets a double whammy. We have to go through this pre-market label approval process, but we already have inspectors in the plant. I mean, that's where the rubber hits the road. We have inspectors in the plant, and they can go up and say, “All right, what are you making today?” They can check the product formulation. They can check the label. That's what the inspectors should be doing in the plant. They have to make sure that whatever is on the container is in there. The consumer, if they have child who's allergic to peanuts, wants to make sure that there are no peanuts in that. Somebody sitting in Ottawa who may pre-approve the label has nothing to do with it. They have no idea whether the guy has accidentally put peanuts in or not.
So that's where it stops. As well, if a product label says that the product is either fully cooked or not fully cooked, the guy sitting in Ottawa has no idea whether that product has been cooked or fully cooked. Another important consideration is cooking instructions.
We all know that the products recalled last year--resulting in this committee's creation--all had labels that were pre-approved in Ottawa, showing you again that it has nothing to do with food safety.
There were other arguments used by people--for instance, that you have to worry about products coming in from foreign markets. Well, that is true, but that's why the Americans come up and audit our system and the CFIA goes down and audits theirs. They similarly rely on the inspectors down in those plants to make sure that, yes, what they've put in the product is what's in the product.
Interestingly enough, before last August in Canada, you were not allowed to import a product that had sodium diacetate as one of its ingredients. That's too bad, because had we been able to import ready-to-eat meat products from the United States with sodium diacetate in them, the products would have been safer than the ones sold in Canada. Finally, we have that approval from Health Canada.
So we couldn't disagree more with the comments some other groups have made about pre-market label approval. There are other challenges with the pre-market label approval process; it has nothing to do with food safety.
Before we move on to the next round, here is a question on the same subject we've been talking about around the table; it concerns provincial standards and coming up with something that works.
I have a good example in my own riding, with the major groceries stores. We know they're part of our competitiveness study, but they've taken an issue here in Ontario, and it's probably the same in other provinces, whereby they will not allow their grocery stores, whether they are part of their chain stores or are independent groceries...because even the independent groceries have to purchase a lot of their stock wholesale through them. They have stipulated that these grocery stores cannot sell provincially inspected beef--and I presume it carries into pork and probably anything else--in the stores.
There's a gentleman in my riding who runs his own independent grocery store. He appeared before this committee a while back. He has a store and he's also a part owner of a provincially inspected slaughter facility. They just won two awards in the last couple of months for quality, but in his own store he's not allowed to sell provincially inspected meat.
Could I hear some of the commodity groups, or even Mr. Laws or Mr. Stein, comment on this? It is an issue. I certainly don't have all the answers and I don't think this committee has, but we're trying to find some, and there are some problems across the country provincially versus federally. I would appreciate having comments on this issue.
There's a lot of debate or maybe not too much debate about whether we have enough inspectors. I think everybody knows we don't have enough at the border. In terms of people's plants and things, the debate between audit verification, and obviously, as a physician, knowing what the lab tests show in terms of swabs and things is an important piece of paper to be looking at. Could the panel sort us out on whether they think there are enough inspectors? What is the role of the audit verification in terms of CFIA?
Then, just to help out the analysts a little bit, maybe in the next round or whatever, if you would tell us what needs to be in the recommendations, it would help our job a lot, because it affects your livelihood.
For Mr. Olson, there is a huge concern about CWD, chronic wasting disease, in the game farms. I want to know whether you feel, in terms of food safety, that some of the elk and some of the other game farms are putting our food system at risk.
:
Thank you very much, Mr. Chair.
My name is Terry Pugh. I'm the executive secretary of the National Farmers Union, based out of Saskatoon. I want to thank you very much for the opportunity to participate here.
A lot of our elected officials are still out seeding, unfortunately. I apologize for not having a written presentation in French. There will be a document. It has been circulated to the clerk and you will get that in a few days.
The NFU welcomes this opportunity to present its views on the issue of food safety to this committee. The NFU is a non-partisan nationwide democratic organization made up of thousands of farm families from across Canada, who produce a wide variety of commodities. Our mandate is to work for policies designed to raise net farm incomes from the marketplace and promote a food system that is built on a foundation of financially viable family farms that produce high-quality, healthy, safe food. We encourage environmentally sensitive practices that protect our precious soil, water, and other natural resources, and we promote social and economic justice for food producers and all citizens.
As family farmers, of course we are committed to a food system that provides safe and healthy food to people in this country and abroad. Food production is more than a business to us. We strive to ensure that the agronomic practices we use are safe and sustainable, and we welcome regulations that are designed to assist us in achieving those objectives. In fact, the vast majority of our members voluntarily exceed regulatory expectations in their efforts to produce safe food. Farmers are prepared, of course, to accept a reasonable cost, but it's important to ensure that costs are not unfairly downloaded to farmers. Food safety costs should be fairly shared by government and private industry as food safety and health is a social concern.
Farmers, of course, are one link in the food chain. Products of our labour and our land are destined to pass through many hands before they end up on consumers' dinner tables. The potential for problems, therefore, in the food system increases with each step along that journey. The trend toward large-scale highly centralized processing and distribution of foodstuffs over long distances has accelerated the probability that when food-borne contamination is not detected at its source, the results are disastrous and widespread. Of course, the tragic listeriosis outbreak, which occurred in 2008 as a result of unsafe processing facilities at the Maple Leaf plant in Toronto, profoundly shook the trust Canadians had, until that time, in their food system.
The NFU is a strong advocate of regulatory measures that put protection of the public at the top of the priority list. The NFU is strongly opposed to self-policing by food processing companies. Our policy, which is fairly long-standing, says food must be adequately tested, regulated, and inspected. These critical tasks must be performed by a sufficient number of adequately funded, independent, publicly paid inspectors.
At the most recent NFU national convention, which was held last November, a resolution was passed that called on the NFU to lobby the federal Department of Agriculture and Agri-Food and the CFIA, requesting first that plant inspection and testing be carried out by qualified CFIA inspectors and that the original number of paid government inspectors at meat packing and processing plants be also reinstated.
The Canadian public, of course, does not want industry to police itself. The poll conducted recently by Nanos, which was released on May 20, showed that 70% of Canadians believe Ottawa should invest more resources and be more hands-on in policing the safety of food. I think this tells us Canadians believe that the CFIA, in fact, should be the agency responsible for ensuring food safety and that the Government of Canada is where the buck stops. It's not necessarily the industry. We acknowledge the fact that the industry did take steps to move on the contamination when it was discovered. But really the buck doesn't stop with industry; it stops with the regulator.
The collapse, of course, of the financial system showed what the consequences of deregulation are. The financial system collapse, of course, devastated the economies of most of the world and destroyed the faith of many people in the so-called benefits of the free market and deregulation.
So the listeriosis tragedy fundamentally shattered the notion that food processing companies will always put the interests of their customers ahead of their bottom line. The process of deregulating Canada's food inspection and moving to a system of self-policing by food processing companies has clearly placed consumers at risk. Over the years there has been a gradual handing off of food safety oversight to the processing companies themselves, and the role and authority of the inspectors employed by the CFIA have been reduced dramatically. The testimony by Bob Kingston, I think, pointed that out very well.
The CFIA has had its budget cut over the years, and public food inspectors have seen their workload increase. Last year we saw the move to deregulate provincial meat inspection at slaughterhouses in Manitoba, Saskatchewan, and B.C. Before 2008, of course, federally registered meat establishments were required to comply with an annual mandatory full systems audit conducted by the CFIA. However, we've seen that a shortage of inspectors at the CFIA qualified to conduct these audits meant that this did not happen as often as required.
The Harper government further changed that in April 2008 by moving to the compliance verification system. As we heard from Bob Kingston's testimony, the compliance verification system itself would work in theory, but we do need resources behind that at the CFIA in order to make that actually happen properly. What has happened, of course, is that the compliance verification system has shifted the CFIA inspector's role increasingly off the plant floor and toward auditing paperwork. The Maple Leaf plant was not subject to a full systems audit for at least a year prior to the outbreak. I think that does speak to the importance of these audits.
We have over 800 federally inspected meat plants across Canada and only 1,100 fully qualified processed food inspectors and 230 meat hygiene vets currently on staff. So CFIA inspectors are stretched to the point where it's impossible for them to adequately monitor the facilities that they're responsible for. We've heard before that the inspector at that plant in Toronto was responsible for seven facilities at the time of the outbreak. This really points out that there are problems in trying to ensure that the system actually works as planned, or as it's supposed to. The union has shown that the staffing levels are well below the minimum levels required to properly conduct those meat inspections. There is, in fact, a critical shortage of those inspectors.
I think it would be a grave error to continue with the policy of industry self-policing. The reality is that it's necessary to increase the staffing levels and authority of CFIA inspectors to ensure compliance by private companies with those safety rules. In order to verify that companies like Maple Leaf are not cutting corners at the expense of Canadian consumers, the CFIA does need inspectors on the plant floor doing visual inspections of conditions that may lead to contamination and physically confirming that all the safety protocols and requirements are being respected. Under the current system of simply having CFIA inspectors rely on documents, that tells them, of course, that the company knows how to complete paperwork, but it doesn't really do an adequate job.
We've seen this process of deregulation also pop up in other areas that directly affect farmers. For example, in the Canadian Grain Commission we've seen grain inspections being shifted over to the private sector. We've seen the gradual cutbacks at the Canadian Grain Commission. We've actually seen the same process happen with the CFIA, where every year the amount of money that's set aside for the Canadian Grain Commission to properly inspect is always cut back, just like it is at the CFIA. That directly impacts on farmers, because it increases the potential liability for those farmers if there is contamination of grain in the bulk handling system.
We've also seen, just recently, that situation...the CGC, of course, is aggravated by another recent move to further reduce farmers' access to on-site inspection services. Earlier this spring it was announced that the CGC service centres in Brandon, Moose Jaw, and Melville, which all offered on-site inspections, will be closed. So this is a very important aspect of the food system as well.
We've also seen changes to the seed variety registration system that give increased decision-making power to seed and chemical companies, which basically control the genes that are going into many of the genetically modified seed varieties that are coming on the market. The system would allow them to put those varieties into the market a lot faster, without the same sort of testing and the same sort of insurance that the seed varieties would be equal to or better than existing varieties that are out there.
In conclusion, we really believe that the deregulation of the food inspection system jeopardizes the health and safety of consumers in Canada and abroad. We recommend the recommendations put forward by the food safety first campaign to hire additional inspectors, to put in a moratorium on industry self-policing policies, and to remove the obstacles preventing CFIA inspectors and veterinarians from taking immediate action on shop floors when they see violations at the processing plants. And we really think we should restore the system of public audit reports that was cancelled under pressure from the meat industry.
Thank you very much for that.
:
I'd like to thank the committee for the opportunity to give testimony.
I represent FAIR, which stands for the Federal Accountability Initiative for Reform. FAIR is Canada's first public interest organization created to protect whistle-blowers, by which I mean employees who speak out to protect the public interest when they see wrongdoing. FAIR has been doing valuable work in this field for the past 11 years.
I'm going to cover two closely related topics in my remarks. The first is that I want to comment on the nature of the management systems upon which the industry and, ultimately, the public are increasingly dependent for ensuring food safety. I'll also comment on the vital role that whistle-blowers play in protecting the public when these systems fail and on the challenge of protecting these people.
I'll start with the food industry. As we have heard in this testimony over the past several weeks, the food industry is changing rapidly, from a host of modest family farms to a few industrialized producers operating on a huge scale. Just like transporting people in ever larger passenger planes, this creates economies of scale. It's very efficient while it works, but when it goes wrong, the result can be catastrophic, with many lives lost.
We've also heard a great deal about management systems being implemented in industry as a safeguard. I want to comment on that, because before I took on my current role, I spent my career in industry as an executive and a management consultant working in management systems. I've been working in this field since the mid-eighties, which is before the food industry began to become interested in this subject.
I've written a couple of books on the subject that have been translated and distributed on four continents, so I feel comfortable in making some observations about management systems. I'd like to tell you that obviously without these systems and the techniques they embody, it would not be possible today to build a reliable automobile or to safeguard the blood supply or to launch man into space. It's no accident that HACCP, which we've heard so much about, had its origins in NASA.
As our food system evolves into a vast industrial complex, it won't be possible to have a safe food supply without very expert and diligent implementation of these systems. However, these systems, as effective as they are when they are working well, are fragile. This is a key point, because they require considerable expertise to implement and absolutely consistent support from management, from the CEO right down.
The moment that the technical expertise is compromised or the management support weakens, then the system begins to degrade and will likely soon fail. All it takes for our food supply, then, to be poisoned is for one company in financial difficulty to start cutting corners, or for one manager, perhaps on a night shift somewhere, to overlook a problem rather than stopping the production line to fix it. We're only one bad actor or one incompetent decision-maker away from a catastrophe.
This is not an empty claim. The U.S.A. recently suffered a devastating salmonella outbreak, one of many outbreaks they've had. This particular one sickened an estimated 19,000 people in 43 states. It contributed to nine deaths and triggered the largest food recall in U.S. history and, indeed, an international food recall. All of this was caused by one family-owned peanut plant in Georgia. That's right.
About half of those who fell ill were children, so you begin to see how vulnerable we are. That's why it's absolutely essential, in my opinion, that we have mechanisms in place to inform us when things are going wrong, before disaster strikes.
I'll turn to whistle-blower legislation. The typical whistle-blower is not someone who rushes off on some kind of crusade or to find problems and publicize them. They are typically ordinary employees doing their jobs conscientiously who find themselves in a situation where they see some wrongdoing going on or have come into possession of some information that is embarrassing to their employer or their bosses. Then they put themselves at risk by trying to bring that to management's attention.
The whistle-blower is someone who puts his or her career at risk in trying to protect us. It's not someone who is acting irresponsibly. I think it's just plain common sense that if everyone in the food industry—in government and the private sector—could speak out freely if they saw matters of concern, then we'd be a lot safer than we are today. There is compelling statistical evidence from other sectors suggesting that whistle-blowing is potentially the most effective way we have for exposing problems and wrongdoing.
Some of you might be thinking, well, shouldn't people come forward anyway? Why do they need protection? But I'd like to emphasize that the typical experience of someone who tries to draw attention to concerns their bosses don't want to hear about is that they suffer vicious and calculated reprisals--attempts to isolate them, to make their colleagues frightened to speak to them, and to humiliate them. This abuse and bullying typically goes on until the employee can't take it anymore. At some point their doctor will say to them, “You can't go to work any more because it's killing you.” At that point, the organization has succeeded in ridding them from the workplace and silencing them.
It goes further than that, because employers will very often make every attempt to prevent the whistle-blower from being employable. So they not only lose their immediate job, but also their career. One U.S. expert remarked that the typical fate of a nuclear engineer who blows the whistle is to end up selling computers at RadioShack—and that's certainly my observation too.
The consequences for these people and their families are enormous: loss of livelihood, loss of their careers, loss of their homes, and very often the loss of their families. And they typically end up with post-traumatic stress symptoms, including nightmares, flashbacks, chronic depression—and regrettably, some are driven to commit suicide.
You might think this type of behaviour would be expected from a firm whose profits are threatened, but surely not from government employers. As Canadians, we've been raised to trust our government, but you'd be entirely wrong to do that. I want to give you just one or two examples.
The founder of this organization, FAIR, is Joanna Gualtieri, who blew the whistle on waste and extravagance in Foreign Affairs in the early nineties and was harassed out of her job. She sued her bosses for harassment, and that lawsuit is now in its eleventh year. You could ask, how could it possibly take so long? Well, government lawyers, paid by us, have dreamed up more than 10,500 questions to put to her and have subjected her to more than 30 days of pretrial examination, when the norm is one day.
This is not an unusual example. You've also heard of Shiv Chopra and the Health Canada whistle-blowers who lost their jobs after testifying to the Senate. The Senate was unable to protect them, and they've had to take legal action to try to regain their jobs. Their hearings have been going on for close to five years now.
In Canada, we're latecomers to whistle-blower protection. The Public Servants Disclosure Protection Act came into force in 2007, and it was claimed to offer ironclad protection to whistle-blowers and to be the Mount Everest of whistle-blower legislation around the world. Unfortunately, those claims seem quite ridiculous today. We have a Public Sector Integrity Commissioner, who is an agent of Parliament, with a substantial staff and a budget of $6.5 million, and after two years of operation her office has not found a single example of wrongdoing in the entire federal public service. So our view is that whistle-blowers in Canada are not in any way protected, and there's not even the pretence of protection for them in the private sector.
I'm going to leave you with one very simple message, which is based on two decades of experience I've had with management systems and from what I've learned about whistle-blowing in the past five years or so. If you don't remember anything else, then please remember this. In my opinion, unless we create effective whistle-blower protection for the people working in the food industry, from the public servants who make policy and oversee the industry to the managers and workers on the production lines, Canadians will continue to die needlessly because of avoidable failures within the food supply.
I'm not claiming this is a comprehensive solution. Obviously there are many things that have to be done. But I'm saying it's a very important component that can provide a safety net when everything else goes wrong.
Thank you.
:
Thank you, Mr. Chairman.
Thank you for your testimony.
Mr. Hutton, it's interesting to have the views of an expert from an organization that protects those who make disclosures. The events that occurred before the listeriosis crisis revealed the deficiencies in the Canadian food safety system. I would refer you to the case of Luc Pomerleau, an employee of the Canadian Food Inspection Agency. On his computer, at his work station, he discovered a government plan to cut the agency's operating budget by 5% and increasingly rely on the industry to inspect foods. There was a whole series of similar measures.
We cannot even accuse Mr. Pomerleau of public disclosure, because he did not reveal the plan publicly. He told his union that there were to be cuts, and possible job losses. It was quite understandable for him to pass on the information to the appropriate people. He did not hack into the computer system to find the plan, nor did he break into a safe—words we have heard used here—to get the document. Yet, he was dismissed by the Canadian Food Inspection Agency for having done no more than his duty. Obviously, Canadians ended up hearing about what happened. It's fortunate that this plan, which was a secret at the time, no longer is.
I would like to know your views, since you work in the industry. Can we consider Mr. Pomerleau a whistle-blower? In this day and age, how can we still dismiss an employee because he notified his union he had discovered a certain document?
Thanks to the clerk for providing the information that revived the dead donkey that delivered the documents from CFIA that I was talking about last week. I guess I was mistaken; the donkey didn't die after all. It made its way here, three legs or not.
Mr. Hutton, I have a question about the systems based on this. I had asked a question of Mr. Cameron Prince, who's a vice-president at CFIA, about whether he would provide me documentation about the compliance verification system. He said yes, he could and he would, and they did late last week. Part of that was asking whether the compliance verification system tasks had been done, of which there are five, according to their list.
According to this, it says that in regard to CVS tasks delivered April 2008 to January 2009--and I know you don't have the documentation in front of you, so let me just quote it to you, sections 1, 2, 3, and 5--there were 135,457 tasks delivered, and 134,764 tasks planned. They had actually delivered more than 100%.
But for section 4, which is the system design and reassessment, which was a new assessment, it says to see the explanatory note, which read:
Section 4 verification tasks are associated with periodic, comprehensive assessments of the company quality systems by a specialized team of food safety specialists once very two years. CFIA does not have complete data for section 4 tasks at this point, because they were to be completed over a two-year period ending March 31, 2010.
So if I do the arithmetic, I know they wouldn't have started to do it until March of last year. They can't give you a temporary report. They are saying, “Well, it's a two-year period, and I can't do it until the end.”
Does that seem logical to you, that when you have a system that was in crisis last year--clearly, they had a serious outbreak and they had 22 deaths—somehow the system couldn't be made such that you could say, “Here's what we see at this point based on what we know to date, albeit incomplete”, and not have at least some sort of information driven out of that one task?