Senate Committee — POFO — Brief — ss-3_follow-up_cfia_e

POFO / Brief / ss-3_follow-up_cfia_e

Senate Committees

Follow-up Responses to Questions from CFIA’s Participation at the Senate Standing Committee on Fisheries and Oceans (POFO) on October 27, 2022 1. What type of seal products does the CFIA see typically exported, and to where are they exported? The Canadian Food Inspection Agency (CFIA) works with the Safe Food for Canadians Act/Regulations (SFCA/R), which deal with the requirements for, and licensing of, persons who produce food destined for export or inter-provincial trade.

Seal food products, which typically consist of bulk seal oil (200 litre drums, pasteurized), are traditionally exported to Norway and Hong Kong. Seal meat (raw/bulk/cut up) has historically been exported to South Korea and Hong Kong. In the past, a significant amount of seal penis (bulk frozen), referred to as “seal organs”, has been exported as food from Newfoundland to Hong Kong and Japan. 2.

A) Are there any Inuit-owned facilities that are certified to process seal meat for export, and where are they located? The CFIA does not collect data on race or visible minorities when providing Safe Food for Canadians (SFC) licenses. Indigenous peoples have historically worked hand-in-hand with local processors. It is important to note that Indigenous peoples normally provide their harvested seal input material to SFCR licensed facilities that they do not own. Furthermore, any establishment may process and export seal meat as long as they develop and implement a Preventive Control Plan (PCP) that contains the required controls identified by

section of the SFCR.

Section requires that the processor must develop and implement written and validated controls to verify that the processing and food products processed meet all regulatory requirements of the SFCR. This includes the identification and implementation of controls to ensure the safety of these products, and that they meet the requirements of the importing country. 2.

B) Also, is the CFIA aware of issues preventing the export of seal products by Inuit to the EU? The EU advised the CFIA (the competent authority), that it has banned the import of seal food products. This information has been posted on the CFIA external website and available in the link below: European Union (EU) - Export requirements for fish and seafood - Canadian Food Inspection Agency (canada.ca) The EU appears to have made some provision for the export from Canada of seal food products harvested by Inuit and other Indigenous communities as part of their subsistence activities.

Engagement with the EU for the specific requirements would be needed for the export of seal products as food from Inuit and other Indigenous communities. Regardless of the EU import requirements, the SFCR requires that any person who conducts a “prescribed activity”, including processing, packaging, and labelling, upon a food product intended for export must possess a license issued under the authority of the SFCR. Also, the EU has established the TRACES NT certification system, which issues export certificates for product exported to EU Member States.

The exporter enters information into the TRACES NT system for CFIA to review. If the product meets the certification requirements the inspector issues the certification “electronically” using TRACES NT. CFIA has taken a decision that all export certificates for product exported to the EU will be issued through TRACES NT. The EU develops the export certificates and enters the templates into TRACES NT for foreign countries to complete in order to verify that the product in question is certified by the CFIA inspection official (inspector). 3.

Are there any examples the CFIA can provide of seal processing facilities that have been inspected but are failing to comply with CFIA-enforced regulations or codes? Yes. Export certificates have been refused to processors who did not possess the required SFCR license, or who did not adhere to the Code of Practice requirements established in the import requirements of the importing country. There have also been labelling issues and issues related to violative levels of environmental contaminants.

All issues were resolved through the implementation of corrective actions, which were deemed to be acceptable by CFIA inspectors. 4. How recently was the Code of practice for the harvest, transport, processing, and export of seal products intended for human consumption created? How recently has it been amended, if at all? The Code of Practice for the Harvest, Transport, Processing, and Export of Seal Products Intended for Human Consumption - Exporting food, plants, or animals - Canadian Food Inspection Agency (canada.ca) (COP) was created in 2014.

It provides guidance to seal harvesters and federal seal meat processors to control potential food safety hazards through- out the supply chain from harvest to final packaging and exporting. The COP requires some minor updates to account for the new legislative framework, namely the SFCA/R, as it currently references the Fish Inspection Act and Regulations, which were repealed with the coming into force of the SFCA/R. 5. Were the marine mammal regulations prepared in collaboration with DFO? Is there any difference between the CFIA’s code of practice and marine mammal regulations?

The Marine Mammal Regulations (MMR) were put in place by Fisheries and Oceans Canada (DFO) under authority of the Fisheries Act. Fisheries and Oceans Canada manages Canada’s fisheries and safeguards its waters. DFO’s work is supported by the Fisheries Act, which provides broad powers to the Minister of Fisheries, Oceans and the Canadian Coast Guard for the proper management and control of commercial, Aboriginal and recreational fisheries, as well as aquaculture operations.

The MMR prohibits the disturbance of whales and other marine mammals, and regulates fishing for marine mammals in Canada and in Canadian fisheries waters and fishing for marine mammals from Canadian fishing vessels in the Antarctic, for example humane harvesting and fishing licences. Whereas CFIA’s Code of Practice (COP) is intended to establish recommended food safety controls pertaining to the entire chain of events from harvest to final packaging of this product for domestic consumption or export. 6. Are there CFIA requirements for the storage of meat products on vessels? How does that

section of the code of practice relate to requirements from other sets of regulations from other departments as they affect other Canadian fisheries? Do they differ? Under the SFCR “meat products” do not include seal meat. Instead, seal meat falls under the definition of "fish" which includes "shellfish, crustaceans and other marine animals, and any of their parts, products and by-products." The harvest of seals and the carcass handling practices conducted by seal harvesters are not licensable activities under the SFCR and therefore do not require an SFC licence or PCP.

However, if the harvesters store their seal meat on a vessel prior to providing it to an SFC licence holder for further processing, harvesters are required to handle the seal carcass in a manner that prevents contamination, damage or spoilage, as they would for fish products handled on a vessel. It is the responsibility of the food business accepting the seal carcass for further processing (i.e. the SFC licence holder) to ensure it was handled in a manner that preserves its safety and quality. This aspect is captured within their PCP.

CFIA and DFO collaborated closely on the development of the COP (along with academia and the seal industry), and it reflects DFO’s responsibilities relating to the humane harvesting of seals under the MMR. 7. In the last 6-8 years, have there been concerns raised with the CFIA in relation to any seal products processed in Canada for export? As indicated previously, there have been instances where exporters were not complying with SFCR requirements. Inspectors responded to these issues, as appropriate, and corrective actions were implemented by the exporter in all instances.

This includes failure to implement COP requirements, one label issue and one issue of the exporter not possessing a valid SFC license. The issues encountered would be consistent with normal regulatory oversight matters. 8. In what form is seal meat typically exported (e.g. frozen, dried, etc.)? Seal meat is typically exported frozen. Seal organs were exported frozen with a small amount dried as part of processing.

Document details

Collection	Senate Committees
Citation	POFO / Brief / ss-3_follow-up_cfia_e
Type	committee
Volume / chapter	441 / Brief / ss-3_follow-up_cfia_e
Language	en
Format	pdf
Source	COMM_SEN
Identifier	eaac8d5ff06357c20ea47b733d2b0bafd1992a2e

Source file is stored in the law ingest library (pdf).