List of all recommendations

In the order they appear throughout the report

Chapter 5 - What led to the outbreak

Chapter 5 - To enhance food safety awareness of meat processors including but not limited to federally registered ones:

1. The CEO and senior management of all meat processors should accept oversight responsibility for ensuring that food safety is fully embedded in every level of their business.
2. The CEO and senior management of all meat processors should ensure effective design and actively promote all aspects of food safety consistent with their Food Safety Plan.
3. Food safety plans should be regularly updated to ensure on-going attention to pathogen control.
4. All meat processors should ensure that new and existing equipment is and remains appropriate for the intended use.
5. Sanitation methods should be validated and implemented by meat processors in consultation with the equipment manufacturer, with a particular focus on the intended use and the products being processed on each piece of equipment.
6. To ensure active and transparent communications, all federally registered meat processors should disclose any threat to food safety occurring in their premises to the Canadian Food Inspection Agency inspectors in a timely manner. Meat processors should not wait for requests for information from the CFIA inspectors and should, in the interests of food safety, ensure that inspectors have all information they require.

Chapter 5 - To consolidate the Canadian Food Inspection Agency's inspection responsiveness

7. To accurately determine the demand on its inspection resources and the number of required inspectors, the Canadian Food Inspection Agency should retain third-party experts to conduct a resources audit. The experts should also recommend required changes and implementation strategies. The audit should include analysis as to how many plants an inspector should be responsible for and the appropriateness of rotation of inspectors.
8. The Canadian Food Inspection Agency should ensure that inspectors receive timely education and training specific to each function which they perform. This should be based on an assessment of the additional training required to address gaps in the knowledge and abilities of inspection staff. Inspectors should regularly receive a mandatory program on current trends in science and technology in the processing of food, including compliance and verification processes.
9. The Canadian Food Inspection Agency should equip its inspectors with modern technology (e.g. e-note pad) to increase their efficiency.
10. The Canadian Food Inspection Agency should amend its meat inspection system (CVS) to ensure:
    1. the appropriate human resources are available to respond to workload requirements;
    2. comprehensive training based on required competencies and skills;
    3. timely delivery of on-going training;
    4. supervision of inspection staff structured to encourage enterprise and accountability.

Chapter 5 - To improve the Listeria Policy

11. Health Canada should complete the revision of its 2004 Listeria Policy, by no later than March 2010, and ensure that:
    1. the Policy outlines clearly and concisely the expected results for all identified food products where Listeria is a potential threat to human health, consistent with international standards;
    2. risk categories of ready-to-eat product are retained, although they should be more clearly defined;
    3. post-processing measures that control Listeria monocytogenes are considered when determining product risk categories; and,
    4. it focuses only on the safety of foods (i.e. should be a food safety standard) and not on providing risk management direction to the food industry or the Canadian Food Inspection Agency.

Chapter 5 - To provide more responsive solutions to improve food safety

12. Health Canada should review its approval processes and fast track, where appropriate, new food additives and technologies that have the potential to contribute to food safety giving particular attention to those that have been scientifically validated in other jurisdictions (provinces or countries).

Chapter 5 - To improve sanitation of food processing equipment

13. Manufacturers of food processing equipment should ensure that their specifications and instructions to users specifically emphasize the necessity to control the risk of pathogens, including Listeria monocytogenes.
14. In addition, manufacturers of food processing equipment should accept responsibility for the foreseeable impact of the design and operation of their equipment on food safety. The design and operation of, and recommended sanitation methods for all food processing equipment should:
    1. enable thorough cleaning and disinfection;
    2. allow for efficient and complete disassembly and reassembly when required;
    3. eliminate to the fullest extent possible all areas likely to harbour pathogens, including Listeria monocytogenes;
    4. wherever possible, use material that is scientifically validated to limit pathogen growth or survival; and
    5. be peer-reviewed (applicable only for the recommended sanitation methods).

Chapter 5 - To enhance the effectiveness and timeliness of the Canadian Food Inspection Agency's food safety requirements

15. The Canadian Food Inspection Agency, in conjunction with and in conformity to the proposed revisions to Health Canada's Listeria Policy, should strengthen its February 2009 Listeria controls found in the Meat Hygiene Manual of Procedures to focus on control measures for Listeria in ready-to-eat meat products, in addition to the current environmental and product testing:
    1. to ensure that any required testing is a verification step to confirm the effectiveness of the company's Listeria control program and not a control program in itself;
    2. by differentiating the testing requirements to reflect the risk associated with each product (i.e. more testing for high risk products and less for low risk ones);
    3. by requiring the testing of non-food contact surfaces in the processing environment;
    4. by establishing 'hold and test' product control requirements following positive test results for Listeria on food contact surfaces as follows:
       1. several tests for Listeria on food contact surfaces should be conducted immediately on and around the area where positive results were found to determine:
          • if there is persistent contamination, or
          • if the previous positives have already been dealt with using standard sanitation procedures;
       2. if the follow-up tests are positive, then testing for Listeria monocytogenes must occur in products from the production line of concern¹. During this testing phase, all products produced on that line and day (i.e. between two complete sanitation shifts) should be withheld from the marketplace until the results are known;
    5. by further defining expectations of trend analysis to identify weaknesses in the company's control programs (including its HACCP plan) by determining if a pattern of contamination is emerging.
16. The Canadian Food Inspection Agency should revise its monitoring programs (M-200 and M-205 plans), by tailoring the sampling frequencies to each plant based on risk factors including compliance history, product risks and target market (i.e. higher sampling frequency in some plants, lower in others.)
17. The Canadian Food Inspection Agency should review and update existing food safety programs, regulations and directives to best reflect current food safety practices.
18. The Canadian Food Inspection Agency should update its Food Safety Enhancement Program Manual to require food processors to include all standard operating procedures and good manufacturing practices in their food safety plan.
19. The Canadian Food Inspection Agency should ensure that the Meat Hygiene Manual of Procedures is updated whenever there is a significant change to the practices imposed on industry.
20. The Canadian Food Inspection Agency should formally communicate its expectation that registered meat processors will bring all information with potential consequences for food safety to the attention of their assigned inspector in a timely manner.

Chapter 5 - To protect vulnerable populations

21. Organizations providing housing and/or food services to seniors and other vulnerable groups, including long-term care homes and hospitals, should be encouraged to adopt food safety practices aimed at vulnerable populations, including those most vulnerable to listeriosis (such as the practices set out in the British Columbia Guideline for Food Services or in guidelines issued by the other provinces and territories.)

Chapter 5 - To improve surveillance

22. The federal, provincial and territorial governments should continue to use and support surveillance and monitoring systems, such as Canadian Integrated Outbreak Surveillance Centre (CIOSC), and consider the development of next generation systems (e.g. Panorama).

Chapter 7 - How well did the federal government and its food safety partners respond to the outbreak

Chapter 7 - To improve national foodborne emergency leadership

23. The Public Health Agency of Canada, with the support of the Canadian Food Inspection Agency and Health Canada, should assume the leading role in coordinating the federal government's response to a national foodborne emergency.

Chapter 7 - To improve national foodborne emergency preparedness

24. In preparedness for national foodborne emergencies, the federal, provincial and territorial governments should:
    1. complete the revision of the Foodborne Illness Outbreak Response Protocol (FIORP) currently underway, at the earliest opportunity; and
    2. enhance the FIORP, by developing and ratifying a Foodborne Illness Emergency Plan building on the experience of the Canadian Pandemic Influenza Plan, to:
       1. designate the Public Health Agency of Canada as the lead Agency taking leadership at both the national (multi-provincial/territorial) and the federal (multi-departmental);
       2. use a common incident command structure;
       3. define the roles and responsibilities of each of the organizations involved clearly and concisely, in plain, unambiguous language, including surge capacity;
       4. increase the use and timing of health advisories and precautionary warnings, where reasonable and probable grounds exist, to advise consumers to suspend consumption of suspected foods while tests to confirm the precise source are pending, taking into account
          • suspected illnesses and deaths,
          • geographic distribution, and
          • test results of opened or unopened food samples.
       5. create a ready-to-implement crisis communications plan to ensure that all Canadians are kept informed in a timely and detailed manner (including pre-arranged media spots, pre-developed material, and the like); and
       6. share all information, including epidemiological data, needed to identify the emergency taking into account privacy and data confidentiality issues;
    3. include in the FIORP periodic mock exercises to validate that the protocol and its Emergency Plan are fully understood by federal, provincial, territorial and local governments as well as by the food processing and distribution industry and is in a state of readiness.
25. The authority of the federal Minister of Health to protect the health of all Canadians under section 30.1 of the Food and Drugs Act, and subsections 4(1) and (2) of the Department of Health Act should be used in a national foodborne emergency, whenever warranted.
26. Where human deaths or serious illnesses have occurred, the Canadian Food Inspection Agency should promptly disclose the results of its investigation of the implicated plant and the corrective actions taken, to the public and food safety partners.
27. The federal government should establish an independent post-event review process made up of a pre-identified team of experts not involved in the emergency. Following all future national foodborne emergencies, this team should conduct an in-depth review and report to the government. The report should be made public.

Chapter 7 - To better manage national foodborne emergencies

28. In the event of a national foodborne emergency, an incident command structure should be activated under the leadership of the Public Health Agency of Canada with the direct participation of the Canadian Food Inspection Agency and Health Canada.

Chapter 7 - To clarify the 'weight of evidence' needed to recall food products

29. Health Canada, the Canadian Food Inspection Agency and the Public Health Agency of Canada should review, update and publish the criteria for proceeding with a food recall to ensure that the weight of evidence takes into account epidemiological information, including suspected illnesses and deaths, geographic distribution, and food sample test results whether packages are opened or unopened.
30. The Canadian Food Inspection Agency should encourage federally regulated meat processors to move beyond the minimum existing requirement for accessibility of distribution records to include electronic access in non-proprietary and unlocked formats to assist in potential product recalls.
31. The Canadian Food Inspection Agency should establish a formal protocol to ensure that timely and consistent information is provided to staff of the provincial/territorial or local public health organizations who are asked by the Agency to help it complete post-recall verification activities.
32. In providing information related to a given product recall to the distribution industry, including grocers, the Canadian Food Inspection Agency should use a standardized form (as suggested by the Canadian Council of Grocery Distributors).

Chapter 7 - To enhance the responsiveness of laboratories to national foodborne emergencies

33. Given that laboratories across Canada are not networked, the federal, provincial and territorial governments should proceed to establish a nationally integrated network (i.e. network of networks) among the following:
    1. human disease labs (where this has not yet occurred),
    2. food labs,
    3. animal labs, and
    4. all of the above.
34. This network of federal, provincial, territorial, local and private laboratories should be integrated to ensure:
    1. rapid tests, analysis and reporting of test results into monitoring and surveillance systems, on a priority basis; and,
    2. the identification of back-up capacity to support regional and local gaps and surge capacity needs during a national foodborne emergency.
35. Federal, provincial and territorial governments should review laboratory procedures and methodologies to develop consistent practices in testing for foodborne diseases, against predetermined benchmarks and giving priority to the following:
    1. cross-coding human samples and corresponding food samples in order to accelerate the linkage of test results;
    2. agreeing to protocols designed to accelerate the process for accrediting public (by the federal government) and private (by the provinces) laboratories for Listeria monocytogenes DNA fingerprinting;
    3. standardizing methodologies for the collection and retention of food samples, including the requirement that all Listeria monocytogenes positive food isolates be forwarded to a designated lab for DNA fingerprinting;
    4. developing and delivering the necessary training required to ensure that laboratories have built-in human resources redundancy;
    5. ensuring that positive Listeria monocytogenes isolates are held for at least six (6) months to facilitate the comparison of data and to accelerate the identification of potential outbreaks, and
    6. researching and applying novel and emerging lab technologies.
36. Federal, provincial and territorial governments and their research funding agencies should initiate and support further research into:
    1. testing for, and control of, Listeria monocytogenes;
    2. improved traceability technology and methodology; and
    3. novel and emerging laboratory technologies.

Chapter 8 - How well were communications handled

Chapter 8 - To enhance communications during a national foodborne emergency

37. The Public Health Agency of Canada should assume the lead role (non-ministerial) in communicating to the public for a national foodborne emergency.
38. The Canadian Food Inspection Agency and the Public Health Agency of Canada should enhance their public profile to increase awareness of their mandates.
39. The principles of risk communications should drive the federal communications strategy and activities. Therefore, the Health Canada/Public Health Agency of Canada Risk Communications Framework should be implemented and become the principal reference point and standard for federal government communication to the public on foodborne emergencies, such as listeriosis.
40. Communications staff should be aware of developing trends in communication and ensure the capability exists to use the best vehicles available to reach key audiences as quickly as possible.
    
    A 'one-stop' website capability should be developed in order to provide easier public access to crucial information. Accountability for its maintenance should be clearly identified.
41. A series of communication measures that will contribute to an acceptable level of preparedness should be identified and put into place.
    
    These would include simulation training, contingency planning to ensure availability of key resources and ready access to outside suppliers. The measures should also include the preparation of certain communications material in advance, such as basic information on listeriosis and other foodborne illnesses for at-risk populations and health providers.
    It would also include the development of a communications strategy, based on solid marketing research and analysis, and a related implementation plan. The strategy should identify the target audiences, their information requirements, and how and by whom they are best reached.

Chapter 8 - To increase consumer awareness

42. To protect vulnerable populations, including the immuno-compromised, older people and pregnant women, Health Canada should promote consumer education into the risks associated with Listeria. This could include targeted measures, such as precautionary labelling. This should be accomplished in collaboration with the Public Health Agency of Canada and in conjunction with provincial and territorial health partners.

Chapter 10 - How well were communications handled

Chapter 10 - To modernize the federal regulatory framework on food safety

43. To simplify and modernize federal legislation and regulations which significantly affect food safety, the Government of Canada should mandate a lead agency to conduct a comprehensive review and recommend improvements in a timely manner, taking into account the amendments or additions required to enforce, where applicable, the recommendations included in this report (e.g. the requirement to disclose any threat to food safety as covered by recommendations 6 and 20).

Chapter 10 - To enhance the governance of food safety in Canada

44. As soon as possible, the Canadian Food Inspection Agency, supported by independent experts, should initiate a comprehensive review of
    1. its organizational structure;
    2. the current delegation of responsibility and lines of accountability within the Agency; and
    3. its decision-making processes.
45. Concurrent with the review, the federal government should consider replacing the current requirement for an Advisory Board with a Board of Management which, subject to powers to be retained by the Minister including all decisions related to policy, legislative, regulatory and emergency matters, should oversee the organization and operational management of the Agency, and advise the Minister on policy matters.
    
    At a minimum, the federal government should consider the immediate appointment of the Advisory Board established under subsection 10 (1) of the Canadian Food Inspection Agency Act. The Board should be specifically directed to advise the Minister on issues relevant to the vision, accountability, mandate, and public perception of the Agency and risk management.
46. The federal government should endorse the need for continuity and vision at the Canadian Food Inspection Agency by making efforts to ensure, wherever practical, that the 5-year mandate given to the President under section 5 of the Canadian Food Inspection Agency Act is fulfilled.
47. As a regulatory agency, the Canadian Food Inspection Agency should create a formal and transparent consultation strategy which will define its required engagement with stakeholders.
48. To ensure timely and consistent enforcement practices across the country, the Canadian Food Inspection Agency should review the interpretation and application of its rules and enabling legislation.

Chapter 10 - To enhance proactiveness of the Canadian Food Inspection Agency

49. The three main lines of business of the Canadian Food Inspection Agency, food safety, animal health, and plant health should be assisted by permanent expert advisory committees to guide their evolution.

Chapter 10 - To ensure prompt response to food safety situations

50. The Office of Food Safety and Recall should report directly to the office of the President of the Canadian Food Inspection Agency.
51. The Canadian Food Inspection Agency should ensure that the Office of Food Safety and Recall has dedicated resources to undertake all the CFIA activities concerning recalls. The Office of Food Safety and Recall should be identified as the CFIA's primary point of contact with Health Canada during a national foodborne emergency.

Chapter 10 - To enhance the federal governance of public health

52. As soon as possible, the Public Health Agency of Canada, supported by independent experts, should initiate a comprehensive review of its structure and operational procedures with the objective of ensuring a more responsive and flexible organization to support national readiness for public health threats.
53. Concurrent with the review, the federal government should consider permanently assigning day-to-day operational management responsibilities of the PHAC to an associate deputy head (i.e. a Chief Operating Officer equivalent to a second-in-command) to allow the Chief Public Health Officer to focus on his executive duties and responsibilities as the lead health professional of the Government of Canada in relation to public health and to ensure continuity of management.
    
    At a minimum the day-to-day operational management responsibilities of the Chief Public Health Officer of the Public Health Agency of Canada during a national foodborne emergency, should be temporarily assigned to an acting deputy head for the PHAC until the end of the emergency.

Chapter 10 - To improve how federal organizations collaborate on food safety

54. The Clerk of the Privy Council should appoint an independent expert to chair a special committee of the deputy ministers responsible for Health Canada, the Public Health Agency of Canada, and the Canadian Food Inspection Agency. The chair should report to the Clerk directly. This committee should provide recommendations to improve the ways the organizations work together in their roles in food safety. It should also oversee the development of our proposal to simplify and modernize federal legislation and regulations.
    
    The first tasks of this committee should be to reduce overlaps and address gaps among the organizations, improve communication and the sharing of information, resolve existing issues preventing harmonization of roles, and provide a report on these matters within six months.

Chapter 10 - To improve how the federal, provincial and territorial organizations collaborate on food safety

55. Considering the serious implications of foodborne illnesses, governments should create a distinct federal, provincial and territorial committee reporting regularly to the federal Minister of Health. The Minister should share the progress of this committee with his provincial and territorial ministerial counterparts regularly.
    
    This committee should enable national preparedness for foodborne outbreaks. One of its first tasks should be to develop and implement programs alerting vulnerable populations to the risks of listeriosis and identifying recommended sanitation and prevention practices.
    
    The committee should be composed of officials from the Health and Agriculture Ministries across Canada, the Canadian Food Inspection Agency, and the Public Health Agency of Canada.

Chapter 10 - To demonstrate the Government of Canada's commitment to food safety

56. In setting its agenda for the fall of 2009, the government should be mindful that due to globalization and increased Canada-wide production and distribution of food, food safety will require increased attention. Although Canada is already a leader in food safety practices and systems, the government should clearly and emphatically commit to the safety of food as one of its top priorities.
57. Following its receipt and review of this report, the government should commit to reporting back to Canadians, within two years, on the implementation of the recommendations contained in this report together with an assessment of their impact on improving Canada's food inspection and food safety emergency response systems.

¹The testing requirements (e.g. number of tests) should be based on an authoritative source such as the International Commission on Microbiological Specifications for Food and should be consistent with the Health Canada's Listeria Policy