Food safety regimes for sustainability


The challenges for local and sustainable producers and processors




Financing the transition



Canada’s has one of the best food safety systems in the world, especially regarding biological contaminants, and a tremendous amount of resources is devoted to it.  But given the complexity of the food system, the number of food borne diseases and intoxicants (some 200) and the number of actors involved, it is impossible to eliminate food safety problems.  Although there is some evidence that food borne illness have declined in the past 20 years, roughly 4 million Canadians suffer from such illness each year, with roughly 12,000 resulting in hospitalization and over 200 resulting in death.  The economic costs of food borne illnesses are conservatively estimated at $2.8 billion annually (Latuskie and Shelley, 2019). Another indication of the problem is the regular posting of food recalls  on the CFIA web site. Some of the problems are a result of individual lack of knowledge or misjudgements (whether consumers, inspectors, chefs, company employees, farmers), but many are deeply structural and the latter are the focus of this section because some of these structural elements impede the transition to a new food system.  The current food safety regime has been designed around the dominant rules, and consequently, is not necessarily fully equipped to support sustainability.

The food safety system is also complex. It evolved from concerns about adulteration and poor hygiene (for some history, see Berger-Richardson, 2019). Until 2019, the modern food safety system was guided by over a dozen main pieces of legislation[i] (and numerous assorted regulations, regulatory directives and protocols), 3 layers of government carrying out different or overlapping functions in a more or less coordinated fashion[ii], and more than one agency involved  within each layer (although certain ones tend to be central, e.g., the Canadian Food Inspection Agency (CFIA) federally).  Numerous functions are carried out (training and education, pre-market consultations, product approvals and licensing, labeling and advertising, monitoring, inspection, post-market monitoring, recalls, enforcement, policy making, import controls, etc)[iii], with multiple targets within the food chain (e.g., farms, processing plants, warehouses, retail, restaurants, imports and their foreign facilities), and a full range of food and packaging products. Almost 20 years ago, a senior CFIA official told the Canadian Grains Commission that the complexity of the food system has made it more vulnerable. He stated, “when something goes wrong, because of the rapid dissemination and transportation that we have, a very small incident can turn into a major problem in a very short period.” (Rance, 2001:6).

With the passing of the federal Safe Food for Canadians Act (SFCA), there has been some consolidation of commodity regulations that were dispersed across numerous acts, and some harmonization of inspection processes.  Import controls have been strengthened and applied more uniformly across a wider range of goods (Latuskie and Shelley, 2019).  Now the SFCA and the Food and Drugs Act are the two most important pieces of legislation federally.  The SFCA is focused on goods trading across boundaries, both domestic and international. It extends a shift going on for many years in  the relationship between the federal government and the food industry, from one of policing to a partnership model whereby responsibility for meeting requirements is transferred further to farms and firms.  This continues a trend started with partial Hazard Analysis and Critical Control Points (HACCP) adoption, now focused on the development of Preventive Control Plans (PCPs).  All food businesses subject to the Act must have one, though there are some exemptions to having a written plan for small businesses (Berger-Richardson, 2019). Provincial food safety rules focus on goods within the province and food premises, and in theory are co-ordinated with federal approaches, though there are some questions about whether that is always achieved.  In turn, provinces have been offloading more responsibility to municipalities and regional authorities through public health units (Latuskie and Shelley, 2019).  Provincial rules can exceed federal ones as long as they don't impact foods traded across borders (Berger-Richardson, 2019).

It is not clear that these recent changes address well the complexity of the system.  They do create more flexibility, which in turn requires more interpretation. The prescriptive pieces have been moved to reference documents, which also makes it easier to implement changes, but typically moves interpretation outside parliamentary scrutiny, and reinforces it as civil service purview. More interpretation means a range of forces can be brought to bear on decisions, including biases of actors and commercial pressures.  More interpretation requires more interactions, more faith, and more training.  But all this is also generally occurring in an environment of budget contraction, so whether budgets have been suitably adjusted is an ongoing question.

Private law also has a significant role in the food safety system, with significant levels of civil litigation (see Latuskie and Shelley, 2019).  The difficulty is that most private law remedies are very expensive to resolve, for the courts and for the combatants, so they are not viable strategies for most actors in the system.

Food-related hazards result from different  phenomena and the policy system, either explicitly or implicitly, treats them differently. MacRae and Alden (2002) identified five categories of food safety hazards:
1. microbial and chemical food safety hazards of long standing that the system has been designed to counter (e.g. Salmonella and Listeria, some heavy metals);
2. emerging pathogens, some of which are invasive species (see Goal 5 Wildlife Protection), resulting from the implicit design of a globally traded food and agricultural system, particularly intensive livestock operations, and year round access to what were in Canada seasonal foods;
3. hazards associated with technologies (and their by-products) viewed as beneficial for the dominant approaches to food production and distribution, including pesticides, heavy metals, growth promotants, antibiotics, fertilizers, and genetically engineered organisms (see other sections of Goal 4);
4. hazards associated with technologies introduced to solve earlier generations of food safety and quality problems, including additives and irradiation; and,
5. hazards associated with new approaches to food as health delivery agents, functional foods and edible vaccines.

Categories 2-5 are significant indicators of design flaws in the food system itself (see for detailed examples, MacRae and Alden, 2002). Laying a food safety regime on top of fundamental design failures will significantly reduce problems.  The designs themselves must be altered to reduce the generation of hazards.  But the food policy system is not willing to address these flaws, so effectively the food safety system, on many levels, is throwing money away on approaches with no chance of success.  These efforts can have some mitigating effects but are always playing catch-up.  This entire site is about fixing those design flaws.

The new technologies

Game farms and CWD Game farms regulated provincially separate from other animal production systems, e.g., Saskatchewan’s The Diseases of Domestic Game Farm Animals Regulations, D-30 Reg. 1 and Alberta’s Fur Farm Act, R.S.A. 2000 c.F-30, British Columbia’s Game Farm Regulation, B.C. Reg. 227/94 at s.5. BC Fur Farms regulations.  Humans may be susceptible to CWD more so than cattle because it is present in muscle tissue putting hunters at possible risk.Sabine Gilch Calgary Faculty of Vet Science.

Real question about whether most game farms should be phased out because of hazards for wild populations and the possibility of zoonoses.  Especially farms for hunters and also if more exotics are going to high end restaurants.

Charlebois et al International scan

BC now has three license categories for meat: Farmgate is entry level, 5000 lbs meat processed on farm / year, on-farm sales or farmers markets within 50 km.  Farmgate plus 25000 lbs/yr, sold at farm gate, farmers markets, retail outlets and restaurants throughout province. Abbatoir license for full slaughter facilities. need more butchering and cut and wrap facilities. Bezan, M. 2021. Big BC meat licensing change.  WP Aug. 12, p. 36 BC lost provincially licenced abatooirs, from over 300 down to 13 after 2007. NFU report.

Kathleen Gibson, Abra Brynne GBH consulting (do search of Documents)

Miewald, C., A. Ostry, and S. Hodgson. 2013a. Food safety at the small scale: The case of meat inspection regulations in British Columbia's rural and remote communities. Journal of Rural Studies 32: 93–102. doi:10.1016/j.jrurstud.2013.04.010.
Miewald, C., S. Hodgson, and A. Ostry. 2013b. Tracing the unintended consequences of food safety regulations for community food security and sustainability: Small-scale meat processing in British Columbia. Local Environment: 1–19.

Curtis thesis

- in BC, contraction of abattoirs and on-farm slaughter a result of BSE  in 2004.  Used to be a more diverse set of abattoirs.  Resulted in mostly elimination of on-farm meat sales

- "In 2021, the Class D and E licensing system was transitioned to what are now called ‘Farmgate’ or ‘Farmgate Plus’ licenses. Now available across the entire province, a Farmgate License allows for an annual production of up to 5 animal units (5,000 lbs, live weight; ~2270 kgs) while a Farmgate Plus License allows for a maximum of 25 animal units (25,000 lbs, live weight; ~11,340 kgs) (Government of B.C., 2022). These licenses are defined by the Government of B.C. as “an entry-level license intended for low volume producers interested in slaughtering their own animals on farm” (Government of B.C., 2022). Any meat sold by a farmer holding such a license can only be sold within the province. .... applicants complete ‘SlaughterRight training’ (administered by the Ministry of Agriculture and Food), a food safety plan, and a humane slaughter plan (Government of B.C., 2022). ....Insurance costs for farmers who hold slaughter licenses are rising and some report being told their insurance will be outright cancelled because they hold a slaughter license. Small-scale producers are still required to sell slaughtered animals in halves or wholes."

- "The BSE scare of 2003 had its origins in large-scale industrial agriculture, not small-scale farms. In 2020, the Small-Scale Meat Producers Association submitted a Freedom of Information (FOI) request to obtain a Ministry 2009 Risk Assessment on slaughter practices. They had been unable to acquire the report from either the Ministry of Agriculture or the Ministry of Health. When the FOI process was complete, the report confirmed that “In fact, the risk appears to be lower in small-scale on-farm slaughter than in large-scale facilities” and that there was no “…inherently increased risk associated with the meat produced through these methods [small-scale] of slaughter” (SSMPA, 2021)."

Stuart, D. 2008. The illusion of control: industrialized agriculture, nature, and food safety. Agriculture and Human Values 25: 177–181. doi:10.1007/s10460-008-9130-4

Bird flu as indicator of too many poultry on the landscape

Due to Covid pressures, AB allowing consumers to buy live animals directly from farms for on-farm slaughter. One organic farmer in the Peace had to make 14 hour round trip to nearest small abattoir for chicken slaughter. But plant closed. On-farm slaughter Operation License of the Meat Inspection Regulations. Slaughter done by producer or anyone they authorize. Slaughter can't be in a building and only for the consumption of the consumer, can't be resold.  No inspection, limits on how many per year per consumer. Ferguson, D. 2020. New Alta slaughter rules welcomed. WP Dec. 10, p. 57.

Laforge, J. M. L., Anderson, C. R., & McLachlan, S. M. (2016). Governments, grassroots, and the struggle for local food systems: containing, coopting, contesting and collaborating. Agriculture and Human Values.  Farmers report:

  • HACCP guidance way too complex for SMEs
  • poorly defined regulations, inconsistent interpretations of regulations, and the hostile culture of most regulatory enforcement.


See Judge et al 2022 and Robin et al. 2021 for problems with food safety rules and wild game.  Although there are provisions for wild game being processed in a provincial facility in Ontario, the stringency of the rules effectively means no one really wants to do it because of the costs of separating wild post-mortem and domestic ante-mortem processing systems.  Complete shutdown and cleaning, very expensive and time consuming.  NWT interested in the Class D licencing system used in BC.


[i] The main relevant federal ones were: Food and Drugs Act, Canadian Food Inspection Agency Act (Bill C-60), Canadian Agricultural Products Act, Feeds Act, Fish Inspection Act, Seeds Act, Consumer Packaging and Labelling Act, Plant Protection Act, Plant Breeders Act, Health of Animals Act, Meat Inspection Act, Hazardous Products Act, and the Pest Control Products Act.  The provinces and territories also have food safety legislation that covers food products that are not registered in the federal system, and provides for oversight of food related facilities that are not generally involved in inter-provincial trade (e.g., slaughtering plants that aren’t involved in intra provincial or international trade) or serve local markets (e.g., restaurants, food retail stores).  However, increasingly the provinces are amending their slaughtering rules to conform with federal ones, even for provincial plants that don’t seel meat across borders.

[ii] A  federal - provincial - territorial framework for working on food safety was put in place in 1996.  And new programmes have been introduced since the Agricultural Policy Framework was adopted in 2003.

[iii] For an overview, see the CFIA web site,