As the food supply continues to become ever more global, a number of the world’s governments are gradually working to make their borders easier to cross, with last week’s System Recognition between the food safety agencies of the U.S. and Canada, the U.S.’s previous arrangement with New Zealand, and FDA’s pending agreement with Australia and Europe, as prime examples. On May 4, FDA, the Canadian Food Inspection Agency (CFIA) and the Department of Health Canada (Health Canada) signed an arrangement recognizing each other’s food safety systems as comparable to each other. This is the second time FDA has recognized a foreign food safety system as comparable, the first being New Zealand in 2012. A similar system recognition process is also underway between FDA and Australia and the European Commission. These systems recognitions essentially establish a framework for regulatory cooperation, both in a country’s acceptance of the foreign facility’s compliance with those country’s regulations as equal to its own, and in such areas as scientific collaboration and outbreak response. The determination to recognize another country’s system is based on a review of its domestic food safety regulatory system to determine if it has legal authorities and tools that provide public health outcomes comparable to those of FDA. To accomplish the U.S./Canadian recognition, the two countries conducted reciprocal food safety Systems Recognition Assessments of the operation and oversight of the food safety system of the other. The assessments reviewed the other’s regulatory foundation, training program, inspection program, program assessment and inspection audit program, food-related illness and outbreaks, compliance and enforcement program, industry and community relations, program resources, international communication and harmonization, and laboratory support. FDA’s assessment was based on Canada’s completion of the International Comparability Assessment Tool (ICAT). FDA sees the systems recognition of CFIA and Health Canada as helping it to be more risk-based in planning the scope and frequency of its inspection activities, including foreign facility inspections, import field exams, and import sampling. The arrangement is also intended to enable the countries to “better align their food safety regulatory systems, reduce unnecessary duplication, enhance information sharing, and to the extent possible, leverage resources so that the agencies can better meet their public health objectives,” said Deputy Commissioner for Foods and Veterinary Medicine Michael Taylor. The CFIA expressed similar sentiments stating on its online consumer information site, “Systems Recognition allows for: more efficient and effective use of resources; collaboration on risk-informed decision-making about activities that may be carried out in each country; and enhanced regulatory cooperation, improved coordination and greater reliance on the other country’s Participant(s) for follow-up and coordination when a Food Safety Concern arises. It may also result in reductions in the type and frequency of verification activities.” What does all this mean to you? With all this, you may be thinking … “That’s great that we’re building bridges across the borders instead of fences, but what does this mean really me to me?” Or more precisely: “What does this really mean for my compliance with FSMA in working with Canadian suppliers?” My response: Probably not a lot. The arrangement does not let anyone off the hook for FSMA compliance. Unless FDA comes out with a statement saying differently, I don’t see this as, in any way, translating to a facility not needing a food safety plan. However, it should mean that if you need a third-party audit for FSMA’s Voluntary Qualified Importer Program (VQIP) or a certification for a high-risk food, then the CFIA inspection will fulfill the requirement. So, while there may not be a lot of compliance impact, there could definitely be some reduction in duplicative inspections. This not only saves time and resources for the industry, it does the same for FDA – meaning fewer FDA inspections for FSMA compliance of foreign facilities in Canada as well as New Zealand – and Australia and Europe once the pending agreement is signed. And with FDA’s ongoing inadequacy of resources for FSMA implementation (as we are still seeing in the lack of guidance documents for the finalized rules), any saving of time and resources for FDA can only be a good thing. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
