Sunday, May 12, 2013

Meat Regulations Gone Wild

A few weeks ago, I received notice that OMAF (Ontario Ministry of Agriculture) was requesting feedback on some proposed changes to the Meat Regulations.  OMAF was putting on a road show where they were going to present the issues, and seek feedback from stakeholders and the public in general.

I couldn't believe my eyes.  I read the email again.  I immediately checked the OMAF website.  Sure enough, it was true.  They were even coming to hold a public meeting near me, just 300 km one-way for me to drive.  I figured it would be worth the $400 travel cost to meet these OMAF people face-to-face and hear what they had to say.  I immediately reserved myself a seat at the Sudbury meeting on May 7th, 2013 at 3:00 PM.

The Meat Regulations is one of the thorns sticking into my side as a Small Flocker.  Small Flocker's aren't the only ones.  Sustain Ontario has well documented other small businesses who have been closed, or made less profitable, or less competitive by regulations gone wild.  For example, read about Forsyth Farms and the $10,000 worth of meat pies that were thrown out because they were being sold wholesale instead of farm gate.  It isn't just an Ontario issue.  Governments across Canada, and around the world have regulation gone wild, same or worse than Ontario.

For example, I've heard that the EU has 35 different regulations that must be followed by any farmer who dares grow a carrot and try to sell it to a consumer.  Obviously, the EU feels growing carrots are often related to terrorism, and needs to be carefully controlled and monitored by the government.

I figured that none of the local media would know anything about this meeting, and it might be useful to have them there.  I tried to inform the local radio stations and newspapers about this meeting.   I tried to explain to the press why this meeting was important.

I attended the May 7th meeting in Sudbury.  Note that I am writing this Blog posting on May 12th.  After attending the Meat Regulation meeting, I thought I'd better calm down for 5 days, and gain some perspective before writing.  It would be better to write what I think and know, rather than what I felt.

I arrived 1.5 hrs early for the meeting, hoping to get some private two-way conversations with the OMAF people.  As I sat in the parking lot, I used my cell phone to re-call all of the local media and encourage them to come.   As I left a message on another voice mail about the OMAF meeting, I noticed a white mini-van enter the parking lot, with the Ontario insignia on the door; it was them.  I returned my attention to my phone message.  It seemed that I had started too late, and they were too busy with other priorities, so none of the press came.  Therefore, I may be one of the only places where you can get a first-hand account about these public meetings.

Inside at the meeting, OMAF has representatives from the whole chain of command.  I lost count of the OMAF people after 12.  There were so many OMAF people there, I wondered if they had left somebody behind to answer the phones while everybody else was at their roadshow.

I had a number of really good conversations with the OMAF people before the official meeting start.  I felt good about how they listened, then posed possible issues that might arise, to which I responded.

For the official meeting, OMAF started by explaining that the Meat Regulations had been in place since 2005, and a number of issues had been raised over the years.  OMAF felt there was a need to clarify and simplify the regulations.  OMAF also felt that the regulations had gone further than what is now seen as necessary, forcing too many businesses and products to become ensnared by the Meat Regulations.  They had a first draft for the proposed new regs, but still had some outstanding issues to be resolved, and wanted feedback before they went any further.

OMAF currently has 134 slaughter plants, and 350 stand-alone meat plants who are licensed in Ontario.  They would have had many, many more if OMAF had followed their crazy Meat Regs. to the letter of the law.  When they realized their mistake, the Minister set a new policy where OMAF decided that they wouldn't enforce that part of the regs, and wouldn't issue a license.  If they hadn't back tracked,  OMAF would have crushed the Ontario economy and the meat industry even worse than they do today.  I assume it wasn't easy for OMAF to partially admit its mistakes, so my thanks to OMAF for taking this difficult but necessary step for the good of Ontario.

As a representative for Small Flockers, I was ready to share my advice with them.  After 1.5 years of waiting,suffering their constant denial that any problems existed, and their stonewalling, OMAF was interested in making it better. Better late than never, I guess.  I took a sip of water and a deep breath to calm myself.

For some reason, OMAF felt a need to differentiate between meat products and food products.  To my understanding, both of these could be equally unsafe, regardless how much meat they contained.  OMAF wanted to retain responsibility for any products that contained 25% or more meat.  I asked why.

OMAF explained that they checked the US food database, and most products that they considered to be meat products had more than 25% meat, but most foods (ie. non-meat products were lass than that.  For example, most lasagna trays were 18% meat, so they would be under Health Dept. inspection, not OMAF.

So I asked OMAF, "What about somebody who wants to make a corned beef on rye sandwich, you know the really good ones with the corn beef piled high in the middle.  With two thin pieces of rye bread, I bet that would be more than 25% meat.  Are you telling me that OMAF wants you to have a Stand Alone Meat Plant License to make corned beef sandwiches that are sold in vending trucks, vending machines, and corner stores?  OMAF listened, acknowledged my comment, and wrote it down.  I may have just saved some poor schmuck from having his sandwich shop destroyed by the weight of government regulations.  This issue didn't help Small Flockers, but we all have to work together on this one.  Hopefully, our turn will soon come, and somebody else will step up to support Small Flockers too.

I also said that whether it's 25% or 18% or 95% meat, its seems somewhat arbitrary.  The main hazard is between farm and food.  If meat wants to cross the frontier between farm and food, that is where OMAF and the Meat Regulations need to focus their efforts.  Once farm meat is judged OK to be used as food, then whether it's meat or mayonnaise, it's all food.  All foods need to be handled properly, but the % meat in the food is a useless distinction.  OMAF scribbled some some in their binders.

OMAF mentioned that they wanted to reduce the number of people forced to have a meat plant license.  That's when the fireworks started.  Ken Hayden, in a neighbouring town to me, mentioned that OMAFRA told him in 2005 that his butcher shop would need a new Stand-Alone Meat Plant License.  Ken sold his house so that he could invest the $70,000 into modifications to his butcher shop so he could stay in business under the new Meat Regulations in 2005.  Here he is 7 years later, and OMAF is planning on changing the rules again, allowing anybody to directly compete against him, but their spared from having to make the same investment as what Ken was forced to make back in 2005.  That means Ken is at a cost disadvantage, and will be for some time into the future.  Was OMAF going to compensate him?  Three or fore OMAF people looked at each other, then they all turned to face Ken, and simultaneously said, "No".  Ken got upset, but he controlled himself very well.  No shots were fired.

A lady hooked into the meeting by conference call mentioned that when the new regs came out in 2005, many others closed their businesses, as they didn't have the money or the desire to invest it into their business.  She was one of the few who went forward, made the investment, and got the meat plant license.  She wanted to know if OMAF was going to compensate her.  "No", said OMAF.  There was silence on the other end of the phone line.

OMAF explained that making hamburger was seen by them as Class I (Low Risk), but making sausages was Class II (High Risk).  I couldn't let that one go by.  I asked OMAF on what basis they had decided what was high risk or low risk.  OMAF explained that smoking, and sausages, and marinating, and other similar special processes were considered as higher risk.  Ken, the butcher said he felt that anybody doing these special processes needed a meat plant license, just like him.  I said there are Red Seal Chefs who have studied for at least 4 years, who can chef anywhere in the world with their training, that these chefs would be prevented from making sausages or marinating in their restaurant or similar food establishment then selling some of their finest wares to customers to take home with them, or selling them wholesale?  It isn't just butchers and stand-alone meat plants who have the necessary skills and process areas to make safe foods, I said.  If it's safe to serve this as food in a restaurant, it's likely safe for you to buy it and take it home with you.  Look at the number of people poisoned by plain old hamburger, but you call it a low risk Class I process.  I question your risk assessments, I said.  OMAF scribbled some more into their binder.

OMAF mentioned that when they were developing their regulations, they considered the probability of occurrence, and severity of the impact on the public from the various risks.  I spoke up that those two factors are very important, but their is an equally important factor that also must be considered:   Detectability.  Some problems are easily spotted before the trap has been sprung, or can be seen as soon as they occur.  People can then respond readily to these risks.  However, there are some risks that cannot be easily seen until it's too late.  That is the reason I believe, OMAF needs to consider all three factors in their risk assessments.  I mentioned that all three of these were industry standard in FMEA (Failure Mode Effect Analysis) Risk Assessments.  OMAF took lots of notes.

At the end, I asked to come up to the front so I could make some additional comments to the whole group, as well as those on the conference call, so that OMAF wouldn't have  to repeat and paraphrase what I had said for the benefit of those on the remote link.  I told the group that 7.5% of Canadians can't afford the food they need for their families, that food bank usage is up 40% in the last 5 years, and that we are charged 3 times more for chicken in Canada than our American neighbours to the South.  Some of that can be blamed on the crazy Meat Regulations.  I said that Canada is in last place for exporting chicken by the OECD countries, our major trading partners and equivalents.  Canada has just 1.42% of that chicken export market.  We could produce 5 times as much chicken as we produce today if we had just 50% market share of these 7 OECD nations.  That could be done, but Ontario's current Meat Regulations are holding us back.  Currently, Ontario can't feed itself for chicken, for we have to import 35.6 million kg. of chicken each year, in part from Ontario's crazy regulations.

I suggested that Ontario's meat plants need to focus on feeding the people of Ontario, so that the Federal meat plants can focus on exporting Canadian food to feed the world.  To do that, Ontario's Meat Regulation needs to be significantly adjusted now so as to better prepare for this necessary future.

I told OMAF that Justice Haines had warned them about all of these problems and more.  OMAF had taken Justice Haines' advice in some areas, but ignored it in others.  Where OMAF ignored the advice, we suffer the consequences today.  For example, I said Justice Haines recommended OMAF to develop Food Safety Objectives.  I have asked to receive a copy of them.  As far as I know, they still don't exist, 8 years later.  To me, that isn't acceptable.  OMAF needs to do better.

The meeting went on and on, but I won't bore you with all the details.  In the end, I was impressed with the willingness of all the OMAF people to listen to their stakeholders.  I was impressed with the experience and skills of all the OMAF personnel who came to the meeting.  I thanked all OMAF people publicly for taking the time out of their busy days, and making the effort to drive all the way from Toronto to listen to our concerns at this Northern Ontario outpost.

I'm 59 this year.   This is probably the last, best hope of getting this Meat Regulation squared away during my lifetime.  I'm aiming to make it so.  We have until June 3, 2013 to put our comments forward.  You can see OMAF's Meat Regulation proposals here.

You can sign the Small Flocker petition here

You can call your MPP and tell them what you think.

I'm trying to make it better.  Small Flockers need your help.  We can't do it without public support.  Will you set aside your personal priorities for 5 minutes to help yourself, help your neighbours, help everybody in Canada get better, more efffective regulations for their meat supply?

Please say yes.

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