Weighing the risks in your perishables supply chain-a knowledgeable forwarder can help

By Julia Kuzeljevich, Public Affairs Manager, CIFFA

Canada’s Food Inspection agency has just wrapped public consultation on the proposed Safe Food for Canadians Regulations.

The consultation, which closed April 21, was an opportunity for all Canadians to have their say on the proposed regulations. The CFIA is now in the process of reviewing over 1,300 submissions to finalize the regulations and prepare for implementation, a process that’s expected to take several months.

Final publication in the Canada Gazette, Part II is anticipated in Spring 2018.

In early May CIFFA Executive Director Ruth Snowden spoke at the SIAL Canada Food and Beverage trade show at Toronto’s Enercare Centre. SIAL is key to the Canadian agri-food industry, and acts as entryway to the US and international markets.

Snowden participated in a panel discussion about the perishable supply chain, along with Keith Mussar, Vice President of Regulatory Affairs for the Canadian Association of Importers and Exporters, and David Clark, Senior Director, Industry Relations at GS1 Canada.

The Safe Food for Canadians Act is expected to bring tremendous change over the next 12-18 months with the government streamlining its compliance requirements, regulatory and consolidation amendments under the Act. Three pillars will govern safe food policy: licensing, preventative controls and traceability. Having protocols in place for recall and traceability will become mandatory.

This traceability will be of paramount importance in the supply chain especially where it brings visibility and transparency to all aspects of transportation.

The perishables supply chain is growing by leaps and bounds. There are so many risks for product damage: a good logistics service provider knows the breaks in the chain: with perishables sometimes it’s not obvious that there has been physical damage to the product.

Ground handling in air cargo can be an issue, as is the impact of the reduction in freighter capacity. On the marine side, there are the effects of heave and yaw to consider; in rail, shunting of trains. Weather, port changes, the availability of plugs at terminals, and delays because of regulatory requirements like container inspections all add pressure to the perishables supply chain.

The grocery landscape is ever-evolving. We have more access to content of varying types than ever before. But accuracy is paramount and mislabeled products make companies lose consumers in the long run. GS1 identifiers can capture extensive information, noted GS1’s David Clark. With increased regulation to come we need to effectively communicate recalls on common platforms, especially in instances requiring immediate traceability of the product.

In 2018 the regulatory framework will change under The Safe Foods for Canadians Act, which will come into effect over the next 12-18 months.

The new regulations will focus around three pillars: licensing, new food safety control requirements, and regulating business procedures that ensure the safety of food. These procedures must also be in place around packaging. There will also be increased attention around product recall and traceability, which will eventually be mandatory.

What are the implications for trade? If you’re a US company exporting products to Canada, and you’re a non-resident importer, you will be able to hold a license to import product if that product originates in the US.

If you’re a non-resident importer who imports from a third country you will not be eligible to hold a license and you’ll be required to change your supply chain if you want to continue to access the Canadian market, with some exceptions for agri-food, and manufactured food additives.

The new regulations will see a world where evidence must be provided that business decisions and protocols meet the regulations.

Regulations don’t however take the place of Government of Canada inspections.

The US also going through food safety modernization-they have distinctly different requirements but are aiming for the same outcome.

The key elements of the proposed regulations are based on international food safety best practices, so for example having preventive controls and traceability systems in place helps to protect your customers and your reputation. Due diligence across the chain will go a long way, as will having a logistics service provider who knows the ins and outs of perishables transportation.