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OFFS Program Implementation - An Odyssey
Angela Bork
Manager of the On-Farm Food Safety Assurance Program (OFFSAP),
Joint Venture Group
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The úodysseyî of the food safety program, takes us from the consumer,
through the national commodity organization where the program is
built and the CFIA, a respected body for review and recognition,
onward to the provinces, and finally, to the producer. It requires
unrelenting efforts from many parties, both nationally and provincially,
to develop an effective, credible program with a delivery and management
system to match. This document outlines the steps and organizations
involved in bringing together all the components of a food safety
program as well as describing what is involved for the farmer and
how all sectors such as the service industry can assist the farmer
to further their comprehension of the food safety program.
Background
It is well known that new cases of food borne illness and food
recalls occur on a daily basis around the world. Furthermore, research
demonstrates that food borne pathogens obtained from livestock share
the same genetic fingerprints as those found in human food borne
disease cases (Hancock and Dargatz, 1995). As a result, there is
increasing pressure by consumers for a safe food from the farm gate
to the plate. An example of increased consumer awareness is demonstrated
in the following clips taken from an article published in a popular
Ottawa newspaper. This food safety article advocates increased industry
and government responsibility.
úA DIET OF PROPAGANDA ABOUT FOOD POISONINGî
July 18, 2002
In: The Ottawa Citizen.
úStatements such as úThe majority of food-poisoning
incidents occur at home,î distract us from the reality that all
food-borne illnesses come from sources outside our homes. Disease-causing
bacteria move from farms to food processors to packers to grocery
stores and restaurants, and then on to our homes.î
úInsufficient attempts to kill E. coli and
other bacteria, by farmers and the food-processing industry, cause
its spread not only to meats, but to fruits and vegetables grown
in soil fertilized with contaminated manure. So the City of Ottawa
should consider a new headline for its future ads, something like,
úThe majority of dangerous food-borne bacteria originate on the
farm and with food processing companies, not in your homes! Why
should consumers have to bring them home in their groceries?î
î
With increasing pressure from society, there is a concern that
the retailers and marketers, such as Safeway, IGA, Wendy's, Burger
King, etc. would develop individual programs that farmers would
have to implement on their farms. This initiative would create tremendous
logistical problems particularly in tracking the complex flow of
products in time and space as they move from gate to plate. Furthermore,
producers would have to implement as many programs as retailers
they supply. Conversely, however, if industry does not take the
initiative to implement their own food safety program, there is
the danger that it will be done for them; making it only a matter
of time before consumer risk is managed by external regulators.
As a result of increasing consumer pressures, the Canadian On-Farm
Food Safety (COFFS) program was envisioned and put into place. This
route allows industry to market our products through a single channel
while ensuring a program that is achievable for all producers.
Currently there are seventeen commodity groups within Canada that
are actively working out the technical and administrative details
of their food safety programs. Canada is leading the implementation
of on-farm programs with food safety as a priority. Canada's On-Farm
Food Safety programs are based on the principles of HACCP (Hazard
Analysis Critical Control Point). HACCP was originally developed
by the Pillsbury Company in 1959 as a system used to produce food
that was safe enough to send into space. The Codex Alimentarius
Commission (CAC), an international food standardization committee,
endorsed HACCP as the best process control system available.
CAC was formed by the World Health Organization (WHO) and United
Nations Food and Agriculture Organization (FAO) to develop international
food standards to protect consumer health and facilitate fair trade.
In essence, HACCP is a preventative program. It develops intervention
procedures so that rather than reacting to a problem, they are prevented
from occurring. It identifies the interconnectedness of various
standard production practices within a given process, such as poultry
production, and implements good production practices for everything
from chick placement to shipment. The next step is to identify production
practices susceptible to contamination, and the critical control
points (CCP) where effective corrective action can be taken to prevent
contamination. In doing so, the program recognizes the fact that
food safety is ultimately achieved only by maintaining the integrity
of each and every step in the production, processing, and distribution
of food products. The program manages, monitors and records all
CCPs to ensure the production process is under control and that
the safest product possible is produced.
The development of the On-Farm Food Safety (OFFS) program took
place at a national level and was developed by producers for producers.
Originally, the government did not want to be involved; however
to give credibility to the program there is unanimous ministerial
agreement for On-Farm Food Safety Recognition by the Canadian Food
Inspection Agency (CFIA). In no other country has the government
moved to officially recognize the OFFS program. This recognition
by the CFIA provides an opportunity for industry to demonstrate
that our program meets or exceeds international standards.
An important point is that any amendments recommended by the CFIA
are voted upon by the national board of directors, and therefore,
producers have the last word!
The Players
The development of the food safety program involves a complex
inter-relationship between various organizations. Summarized below
are the organizations involved and the connections between them.
Each organization has a defined role within the food safety program
which is described within a management manual; in addition audits
will ensure consistency is maintained across the country. An explanation
of the various roles is described below:
Canadian Food Inspection Agency (CFIA )
As previously mentioned, the CFIA upon a request from a national
commodity organization will åRecognize' the Canadian On-Farm Food
Safety (COFFS) program.
Canadian Federation of Agriculture - COFFS Working Group
This group includes representatives from each national commodity
group. They are responsible for developing a common Canadian approach
for delivery of the on-farm food safety program as well as setting
the criteria required to maintain international credibility.
National Commodity Organization
The national board is responsible for developing a food safety
program specific to their commodity. This ensures that only one
national program is developed per commodity.
The Canadian On-Farm Food Safety (COFFS) manual is the actual
OFFS program that the producer implements on-farm. It outlines
the Good Production Practices and the HACCP based critical control
points.
The national board also develops a management manual that outlines
the responsibilities and operational parameters of the national
program. It describes such aspects as the certification process,
organizational structure, individuals and associated responsibilities
etc.
Provincial Commodity Organization
The provincial boards are responsible for the implementation of
the program on the farm. In Alberta, three of the feather boards,
namely the Alberta Turkey Producers, Alberta Hatching Egg Producers
and Alberta Chicken Producers formed an organization called the
úJoint Venture Groupî (JVG). The purpose of this organization
is to assist producers to set up and implement the OFFS program
within their individual operations.
The provincial board also develops a management manual that
outlines the responsibilities and operational parameters for provincial
implementation of the national program. The manual outlines the
process for an internal audit (yearly) as well as the database
used to track producer audit information.
Provincial Compliance Audit
The provincial compliance audit involves a third party audit of
the provincial delivery organization (i.e. the Joint Venture Group
or individual boards) to ensure that the implementation of the
On-Farm Food Safety program is being appropriately administered,
delivered and validated. This audit is conducted by an independent
company that has been contracted by the national board. It involves
a review of the management manual and the assessment of the knowledge
and auditing skills of the on-farm auditors.
On-Farm Auditor
The auditor is appointed by the provincial commodity organization
(i.e. the board).
Producers often pose questions regarding the qualifications of
the auditor: who they are, what is their background, etc. The on-farm
auditor must meet specific criteria to qualify as an accredited
auditor. They must successfully complete a national auditor training
course that is based on ISO and HACCP audit principles and methodologies.
As well, they must demonstrate an understanding of the specific
recognized On-Farm Food Safety Program and have knowledge of the
agricultural practices in question for the commodity being audited.
In Alberta, we have specifically requested úlivestock experienceî
as a necessary qualification so that there is a realistic/practical
approach to the audit.
Auditors must be free from any conflict of interest so that they
act in an impartial or non-discriminatory manner. Examples of conflict
include: direct or indirect ownership or other financial interest
in a production unit; directly provide, or belong to a business
or organization which provides, goods and/or services to the production
unit being audited; have any immediate family relationship with
the ownership or management of the production unit being audited.
To retain auditor status, an auditor must demonstrate continued
proficiency in audit and HACCP principles in the specific OFFS program(s)
and perform a minimum number of on-farm audits annually. The national
boards will maintain a list of auditors who are able to conduct
audits for specific commodities. This registry will also be used
to ensure that the auditors have taken the commodity specific training
which is facilitated through the national board.
The Recognition Process
Recognition of the food safety program by the CFIA involves a
two-step process. The first recognition step is for technical
soundness. úTechnical reviewî means the documented OFFS program
is reviewed to ensure each element is technically acceptable. The
review team verifies that the program has properly identified the
hazards by using HACCP principles, properly selected good production
practices and critical control points to control hazards, and set
appropriate limits and monitoring procedures that are supported
by appropriate record keeping.
The second recognition step is of the program's administrative
effectiveness. Once the provinces have undergone the third party
audit by an accredited, independent company selected by the National
Board, the CFIA reviews the audit report and grants this recognition
on the basis on the report.
The úSafe, Safer, Safestî manual, which is the food safety manual
developed by Chicken Farmers of Canada (CFC), was the first program
to undergo the technical review process by the CFIA. In June of
2002, CFC and CFIA signed a memorandum of understanding, outlining
the roles and responsibilities for each party as they work towards
the common goal of improving food safety and quality. Full recognition
for this program is achieved once the administrative effectiveness
has undergone review by the CFIA.
Role of the Joint Venture Group (JVG) and Producer Feedback
As outlined earlier, the on-farm food safety program involves
implementing good production practices, controlling and monitoring
critical points and finally, proving that due diligence is practiced
through documentation. To assist producers, the Joint Venture Group
(JVG) holds workshops that explain how to implement the program
on-farm. Following the workshop, many producers discover that their
production practices are often already in line with HACCP guidelines.
In general, the good production practices include:
Biosecurity
-
Control Access Zone around the barns to minimize traffic.
The further any vehicles are parked from the barns the greater
will be the dilution effect.
-
Visitor logbook that includes date (time in/out), name, phone
number, last stop and signature.
-
Change area for coveralls, boots, hair covering and hand washing.
Designated clean/dirty zones.
-
Pest Control Program. Discourage pests (rodents, wild birds
and insects) by keeping area around barns neat and free of debris,
draining water away from barns and managing manure and mortalities
appropriately. Setting up traps and bait stations.
Feed Management
-
Feed from HACCP recognized mill or acquire supplier letter
from mill.
-
Collect a feed sample from each load delivered and more frequently
near the end of the cycle if producer has used medicated feed
and has a single bin system.
-
Do not accept leftover feed from other producers.
Cleaning and Disinfection
Water Management
For the most part producers are already undertaking good production
practices, and the biggest challenge is setting up the paperwork.
The on-farm food safety program is about úwriting what you doî,
údoing what you writeî and úestablishing accountability through
record keepingî. Through documentation a potential hazard can be
identified early and corrective actions can be taken to prevent
contamination from occurring. Record keeping also provides a means
of traceability; proper documentation can quickly trace the source
of the problem and lead to its control as soon as possible. Documentation
is the producer's proof to consumers that due diligence is being
practiced -it shows that good production practices are followed.
Following the workshop, the JVG books a one-on-one appointment
with the producer to go through the documentation. The JVG writes
and types the standard operating procedures (a written document
describing the good production practice) for the producer ensuring
that all requirements of the program are met. In terms of record
keeping, many of the producers are already maintaining records,
for example they record daily mortalities, water consumption, and
maintain a feed inventory by filing invoices/tags etc. How the record
keeping is accomplished for the food safety program is left up to
the producer; since every operation is different the records can
be adapted to best suit their needs. Some producers maintain a daily
log on operational activities and this serves as one of the best
ways to document. Moreover, the JVG offers to personalize individual
producer's records by combining records they already maintain with
those required for the food safety program (facility preparation
checklist, chemical and medication usage, chick quality information,
loading summary).
Another notable point regarding the food safety program is that
the producer maintains flexibility in managing their operation.
The program simply identifies certain hazards that need to be managed,
and allows the producer to address them. For example, one of the
risks is that medicated feed from a starter or grower ration appears
in the feed pans in the last week of the grow-out, as a result of
feed hang-up. To reduce or eliminate this hazard, we have seen several
different management techniques by producers:
-
Producer hauls their own feed. The feed bin is emptied of
medicated feed before adding non-medicated feed.
-
Producer does not use any medicated feed or they only use
medications that have zero withdrawal.
-
Producer has a compartmentalized bin. Finisher feed is kept
within a separate compartment.
-
Producer has 2 feed bins for each barn. The non-medicated
feed is delivered into the empty second bin.
All of these management practices function as preventative measures
to meet the HACCP principles and emphasizes that there are numerous
solutions to an identified risk.
The Challenges
The greatest challenge encountered in the delivery of this program,
is overcoming the initial apprehension that producers have towards
it. The earlier comment that most producers are using good production
practices indicates that the program is not as unrealistic as some
producers may think. Furthermore, there is a lack of understanding
and communication between producers and consumers. It is important
for producers to recognize their role in providing high quality,
safe food, which enhances the health and wellness of the consuming
public. Ultimately, the live animals that producers work with on
a daily basis become the food that consumers depend on.
The food concerns of today are very different from that of 50-60
years ago. In the past, we were concerned with food shortages. Today,
consumers are concerned about where their food comes from, how it
was produced, and if it contains any contaminants. In any successful
business consumer concerns are a top priority. Today quality assurance
programs such as ISO and HACCP, are expected by the consuming public
and consequently implemented within virtually every business.
Once the producer attends a workshop, the practices that producers
often have the most difficulty implementing or adjusting to, include:
-
Putting in place and following a biosecurity program. Producers
are not aware of the resiliency and pathogenicity of disease
agents and the potential for economic loss.
-
Managing leftover feed in a manner consistent with OFFS protocols.
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Acquiring information on medication withdrawal times.
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Understanding the relevance of record keeping.
The greatest assistance the service industry can provide producers
is to help them understand the significance of the On-Farm Food
Safety program and the shared responsibility they have in producing
a safe product. There are times that the producer requires clarification
of specific program components and a referral by service personnel
to the Joint Venture Group would greatly enhance our outreach. There
also typically exists a close working relationship between the agricultural
service industry and the producer. Clarifying and reinforcing the
role of the JVG will help producers implement the On-Farm Food Safety
program.
The ultimate goal is that all food products sold in Canada be
from sources following a documented food safety program. Prevention
of contaminants can only be achieved if all sequential, interdependent
steps of the food-chain are involved in surveillance and combat
programs (WHO, 1988). This includes producers, hatcheries, processors,
retailers and distributors as well as feed mills and their suppliers
- even grain farmers.
On August 6, 2002, the Honourable Lyle Vanclief, Minister of Agriculture
and Agri-Food Canada, announced that Chicken Farmers of Canada (CFC)
had successfully completed the technical review of its On-Farm Food
Safety Program, Safe, Safer, Safest. This announcement emphasized
the importance of the food safety program. Within this press release
it also stated that the CFC board of directors moved that the program
become mandatory once the audit and certification processes are
in place in each province. The reality is that the food safety program
is here to stay. All of us, including producers, processors, hatcheries,
feed industry, bird catchers and suppliers, have a role to play
in ensuring that food safety becomes a way of life, thereby simultaneously
protecting consumer safety and the associated agri-food industry.
References:
CFIA and CFC Press Release. Ottawa. August 6, 2002. Chicken Farmers
of Canada Set to Implement On-Farm Food Safety Program .
Hancock D. and Dargatz D. HACCP Symposium 1995. Implementation
of HACCP on the Farm.
Ottawa Citizen. July 18, 2002. A Diet of Propaganda About Food
Poisoning.
Pierson M. HACCP Symposium. 1995. An Overview of Hazard Analysis
Critical Control Points (HACCP) and its Application to Animal Production
Food Safety.
WHO. Technical Report No. 774. 1988.
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