The committee met at 8:07 a.m.

[R. Leonard in the chair.]

R. Leonard (Chair): Thank you very much for joining us this morning at the wee hours, on our day that’s sort of off in the morning.

Last time we only really had 15 minutes of a meeting, and I just wanted to take a breath today and say thank you all for being a part of this committee. I think that we have a very crystal-clear focus, and we’re about to understand our mandate on the small-scale meat-processing question in detail this morning.

I want to thank our presenters today. We have James Mack and Gavin Last, and I’ll get them to introduce themselves. They’re going to make a presentation.

Are there any initial comments before we get underway?

J. Tegart (Deputy Chair): Is there a possibility of us considering being finished at about ten to ten? It’s simply because we have another meeting right at ten o’clock. Just a heads-up.

R. Leonard (Chair): Okay, then. Sure. We’ll put that on a flag, and at about quarter to, somebody had better tell me it’s quarter to.

I’ll turn over the floor now to Gavin and James.

Briefing by Ministry of Agriculture

J. Mack: I’m James Mack. I’m the assistant deputy minister at the Ministry of Agriculture and responsible for agriculture science and policy. One of those branches is our food safety and inspection team.

G. Last: Gavin Last. I’m the executive director of the food safety and inspection branch. We have the meat inspection program — which is, obviously, why we’re here today — but deal with seafood inspection as well.

J. Mack: What we’ve done today is prepared what I think is a fairly thorough presentation. As I understand it, this would be your first briefing with the program itself on how things work.

I’ll be very transparent. Our objective is to be useful to you, so that you invite us back as you’re thinking and doing. We’ve been operating this system long enough now. In our view as public servants, it’s a good time to take a look at the operations of this system and to think about ideas for how to change it and improve it. We’re really eager to help you in any way that you need in doing this.

[8:10 a.m.]

I will say, though, it’s a lot of information about slaughtering animals. So I guess I would just ask if you want us to go through a page-turn of the deck to brief you on those elements page by page. Or we can dedicate more of the time to questioning. It’s at your wish.

R. Leonard (Chair): Let’s just go through the deck, and then we’ll take questions.

J. Mack: I’ll have Gavin walk you through the approach, and then as questions come up, we can hail them in.

G. Last: Good morning, everybody. As you see, we have the deck. I’m not sure. I think you have paper copies as well. I’m going to provide some historical context, just background and context, for your work going forward.

We’ll start off with a little bit of historical context. Prior to 2004 in the province, meat inspection was governed by federal and provincial legislation. We had federal facilities under that federal legislation that you see. In the province, we had a meat inspection act and a health act. Under that, there were ten areas that had opted or chosen to be designated for inspection. The Ministry of Agriculture and Lands at the time issued the licences, and there was operational oversight by regional health authorities.

This approach led to some confusion about what standards were applying where. It wasn’t consistent or uniform across the province, and there was a difficulty in assuring that meat was safe everywhere, that there was a consistent standard.

Moving to post-2004, which was when the meat inspection regulation was brought in, under that, we had the B.C. Centre for Disease Control, BCCDC, licensing class A, B and C. The C was a transitional licence that doesn’t exist anymore. They were responsible for the licensing, and the premises were inspected by CFIA under contract.

Then in 2011, the class D and E rural slaughter licences were added to the regulation. In that year also, CFIA gave the province notice that it was going to be withdrawing its service in 2014.

Then in 2012, the responsibility for slaughter was transferred to the Ministry of Agriculture from the Ministry of Health, and processing stayed there with the Ministry of Health.

A quick overview here. That graphic — you’ve probably seen it before — is quite informative. It gives you the whole scale of the different types of slaughter, from, on the left, personal consumption, which isn’t regulated. That’s up to…. If an individual wants to do that for themselves and their family, that’s fine.

On the far right-hand side, we’ve got federal premises that are inspected and licensed by CFIA. Then in the middle area of it are the different types of provincial licences. We’ve got, as I mentioned, the A and B licences. These are mostly small to medium-sized enterprises. Many of them are seasonal.

We currently have 63 of the class A and B licences, and in the program, we have 30 full-time and 17 auxiliary inspectors that are distributed around the province to provide the inspection services that are required by legislation.

Then we also have the class D and E licences that are licensed and audited by the regional health authorities. There are 20 class D and 32 class C. I’ll get into a little more detail about what the differences are in some of the next slides. The program also has an element of compliance and enforcement.

[8:15 a.m.]

Just by way of comparison between the federal facilities and the As, Bs, Ds, and Es, the median size of a facility or an operation at the class A and B size deals with just over 1,000 animals a year. So it’s not huge, when you’re thinking about it in terms of…. That’s chickens, beef, pork.

A larger federal facility, such as one of the Maple Leaf hog plants in the east, will deal with 75,000 to 90,000 animals in a week. They are very, very large. You’ve got the Cargill facility in High River, Alberta, another federal plant, that deals with 4,500 head of cattle a day. By comparison, they are quite an order of magnitude larger than what we’re dealing with here in the province.

By comparison, in 2016, class A and B facilities processed just under 24,000 head of cattle in a year. That’s the whole province in comparison to what they would do in just over a week in one of those larger plants. I just wanted to give that perspective.

This map shows…. It’s a little hard to see, but if you look at it, you’ll see kind of the distribution of the different As, Bs, Ds and Es around the province. We provided a copy of this to you early on. I brought an updated version of it today, paper copies of that, if it would be helpful to you just to show an up-to-date…. The one that we provided was last year’s data.

A little more detail about the class A and B facilities. They can be located anywhere in the province. Applicants will propose the location based on where they perceive there to be a market or a business opportunity. The abattoir association does not have a role in determining the location of those facilities. They come to us. They propose where they want to work. Depending on other required….

They have to meet other requirements — local government zoning, that sort of thing — as well. They have no production limits. There’s no upper limit. They could be as big as they want, but typically, as I said, they’re mostly small to medium.

The inspected meat that comes from A and B facilities can be sold anywhere in the province. It’s a traditional inspection model. We have an inspector that must be present in order to ensure animal welfare and food safety.

Again, just to give some context in the level of production, there are four class A plants which are slaughter and processing that account for 83 percent of the production in the province — just four of them. The rest are quite small. In fact, the biggest plant accounts for 60 percent of production. So other than those four plants, we’re talking about A and B facilities that are really in that mom-and-pop kind of range.

In addition to the inspectors, we’ve also got a program veterinarian who provides support to the inspectors. He’s available to them at any time that they’re working, connected to them by cell phone so that they can ask questions and get support directly from him in his professional capacity.

I feel like I’m racing through this a bit. If there are any questions, let me know.

R. Leonard (Chair): That’s okay. Once you get through, we’ll probably have lots of questions. Keep your flow up. It’s good.

G. Last: All right. Thanks.

I wanted to describe the differences between As, Bs, Ds and Es. Why do we even have these classes of D and E facilities with uninspected meat that potentially raises the risk?

[8:20 a.m.]

The goal of them is to support local food production and to provide food security in areas of the province where there’s low population, where we’ve got low animal production levels, where there’s a type of slaughter that’s required but is not available and where an inspected A or B facility is unlikely to locate or be viable because of all of those reasons.

For classes D and E, in order to be licensed, an operator has to undergo what we call SlaughterSafe training, which has animal welfare and food safety aspects. They also have to have a food safety plan. These are usually approved for five years. The licences are up to five years. They can be less, depending on all the factors taken into consideration.

These licences don’t renew automatically. They must reapply when the term expires in order to confirm that the need for the licence still exists.

More specifically, the difference between class Ds and Es…. Class D licences are only available in ten designated regional districts. If you look at a map, it generally runs up the coast and around the north side, where we have all of those factors of lower population and lower animal production.

A class D licence allows only for sale in the regional district where the facility is licensed and also allows for sale of that meat at the farm gate, to farm markets and to retail. The production limit for them is described in terms of animal units. An animal unit is roughly 1,000 pounds, so 25,000 pounds a year, and that’s all species. They’re able to slaughter their own animals or others that they can bring to the facility.

Class E is somewhat different. It’s available anywhere in the province, in those designated areas or non-designated areas. It does require a feasibility study; that is a requirement in the regulation. Sale of the products from an E are also restricted to the regional district where it’s located. They can sell at the farm gate and at farm markets but not to retail — so not to restaurants or a supermarket, as in the case of a D.

The production limit is lower, as well, for an E. It’s up to ten animal units.

D. Routley: Just a quick question. Does retail in class D include restaurants?

G. Last: Yes, it does.

In an E facility, they’re only able to slaughter their own animals. They can’t bring in animals from other operators.

I just wanted to say a little bit more about the feasibility study. It’s one of the pieces that makes the E quite different from Ds. It’s a requirement in the meat inspection regulation that an applicant must submit a feasibility study that has information in it about travel time to class A or B abattoirs that are in the area; also about transportation challenges — whether marine transportation is required or there are seasonal road closures; and the species that they are applying to get licensed for — whether specialty slaughter is an issue, whether that’s certain kinds of special cuts: halal, kosher, organic, those sorts of things.

The availability of custom slaughter at the As and Bs that are in the area. Some As and Bs will only do their own animals. Custom slaughter is where a processor allows for other business, basically, to come to them for slaughter. There are some that have an A or B licence that will only do their own animals and don’t do custom slaughter. If that’s the case, then that speaks towards recommending for the class E to be licensed, and also the conditions around seasonal slaughter in the area as well.

[8:25 a.m.]

Ds and Es are licensed and inspected by the health authorities, so I want to say a few words about their role. We work together. We coordinate the review of the applications between health authorities and the ministry. The ministry’s responsibility is to review the feasibility study and make a recommendation to the appropriate health authority about licensing, which they then consider in making the decision, as the authority to make that decision has been delegated to them. We coordinate.

They deliver the SlaughterSafe training and do on-farm assessment of the proposed facility. As a licensing requirement, they do a prelicensing inspection. They review the entire application package — the application form, their food safety plan and the certificate of SlaughterSafe completion. They then approve and issue the licences and then do site visits and assessments and deal with enforcement issues.

We’ve heard some concerns and complaints in the past. Most of these coming from the smaller producers are that these licensed facilities, the As and Bs, are either too busy to accommodate them or they’re too far away. Transport is an issue for them. It is costly and places stress on the animals.

Also, we’ve heard that government policy prevents those small producers from being able to slaughter their own animals, and some of them just aren’t happy with the way that a custom slaughter service does the job. They want to do it themselves the way that they like it done.

Going back….

R. Singh: Excuse me. I just have one question. When farmers have complaints that licensed facilities are too far away, isn’t there a possibility for the authority to go to their farm and do the inspection? That’s not a possibility?

G. Last: The larger facilities, the As and Bs, have inspectors scheduled to be there during slaughter to have a…. Right now we don’t have the capacity to send inspectors everywhere as they’re needed.

They could be licensed as an A or B facility and then have the inspector go to them. That’s a possibility.

R. Singh: Okay, they have that. That’s what I wanted to know. Thank you.

G. Last: That’s one of the reasons I wanted to make the point that most of those As and Bs are quite small facilities. In some cases, a well-established D or E facility looks and operates very similarly to the smaller As and Bs. There’s not that much of a distinction other than the licensing.

J. Mack: Just because I don’t think we flagged it in the presentation, there are some requirements to becoming a class B — access to hot water, a kill floor that can be cleaned — but we provide the inspection services free of charge. There’s no cost recovery or cost barrier.

As Gavin mentioned, some of the producers are very small and may only have limited kill days. We will try to be flexible with a producer in a remote area to try to sort of coach them to success if they are interested in a class B or A facility.

[8:30 a.m.]

G. Last: Looking at the concerns and complaints that have been raised coming out of the recent consultation that we completed that was focused on the class D and E operators, some of the issues that we heard just around that process itself…. People were concerned that the Ministry of Agriculture wasn’t objective enough to do that, that it should have been undertaken by a body that was more independent and that it should be open to the general public, which, I think, places the committee in a great place to deal with that concern. Now that the committee is established, the general public will have an opportunity to have their voice heard.

With the A and B facilities, some of the things we’ve heard from them over the years is that there’s often a challenge for them that there’s enough livestock to support their business, that it’s often challenging. Providing custom slaughter services is very costly. It’s much more difficult for them to run as a business, to make that available. Because of things like the lack of scheduling with smaller producers, that’s a challenge — the coordination.

Also, with inconsistent communication with smaller producers that are requiring custom slaughter — about the arrival of the animals, the timing, the pickup. Once the order is done, their cooler space gets filled up if some people aren’t picking things up on time.

They also have, and this is throughout the agriculture sector, the difficulty of finding the skilled labour they need to run their businesses. Staff training and retention are an issue for them, and just the seasonal nature of the business — that there are busy times and downtimes. It makes it challenging, especially to retain labour, in those conditions.

A little bit more about the consultation that we’ve just completed in March. We had started with the approach of focusing on the currently licensed and expired Ds and Es. But then after hearing from people in the sector and hearing from stakeholders who had concerns, we expanded the scope to include those who had applied but had been denied. Those that had been improved for an E on the basis of a feasibility study but then chose not to proceed — we wanted to learn more about that as well.

We also added the recently formed Small-Scale Meat Producers Association at their request. We thought it would be good to hear their input. Also, the B.C. Sheep Federation wanted to be included. And we had a request from one particular regional district, Alberni-Clayoquot. They wanted to provide input as well, so we brought them in.

The other industry stakeholders or industry associations that were involved were the B.C. abattoir association, the Cattlemen’s Association, and all of the regional health authorities that are involved.

We are producing, or about to complete, a what-we-heard report, kind of an objective summary of all of this, and should have that done…. Well, I’ll say very soon. I don’t want to make promises, but it’s quite close to being completed.

Again, I’m going back to that point about concerns that were raised, that the ministry wasn’t the best choice to do this work and that it should be considered more broadly by the public. I think that is a good point at which to turn it over to you to see if you have any questions, as I think this will become…. It’s transferred from this consultation that was targeted on those D and E operators to something of a broader public interest.

R. Leonard (Chair): Thank you very much. That was a very, I think, comprehensive thing and probably engendered a lot of questions. James, do you want to speak first, or shall we take some questions and then move on?

[8:35 a.m.]

J. Mack: We’re here to assist the committee, so I think getting to the questions is the best use of time.

R. Leonard (Chair): Okay. I’ll start to take a speakers list, and we’ll work our way through it. Donna first, then Nick and then Mike.

D. Barnett: Thank you very much for the presentation. I have a lot of questions. As you know, I was very involved in the abattoir situation for quite some time. Of course, now we have lost our abattoir, only due to the fellow retiring.

Quite a few questions have come up in the region. The first one I have is: how come only ten regional districts are engaged? Is that from the ministry only wanting those to be engaged, or is that the regional districts that don’t want to be engaged in class D and E licences?

G. Last: The ten districts that are designated for D licences are set out in the regulation. It’s government that has designated them. They don’t opt for it, as they did prior to 2004. The decision was made on the basis of those factors of population density, livestock production levels and the likelihood of a fully licensed class A or B facility being viable in the area.

D. Barnett: I guess one of the recommendations that could come out of this committee, Chair, would be to reopen that and designate more regional districts, if the public so chose.

R. Leonard (Chair): All right. It’s on the record now.

D. Barnett: Okay. So other questions I have, if I may. The feasibility study to apply for a licence — how detailed does that feasibility study have to be, and what, basically, is the ministry looking for in a feasibility study?

G. Last: The feasibility study is available on our website. If you want, I can make copies and share them with the Clerk for you. It’s relatively comprehensive, I would say. It does require a lot of information, basic information about the applicant. Then it gets into a number of questions about the type of service that they are looking for, whether it’s available in the area already, what’s B.C.’s…. It really looks into what currently exists where they are proposing to place an E facility and why there is a need for that E facility to apply.

J. Mack: As a follow-up, the central purpose of that feasibility study is to apply some due diligence that that class E is going in an area where it’s not creating a competitiveness issue for a licensed abattoir. The business decisions of whether it would be profitable or a good idea — that’s on the entrepreneur. What we’re really looking at is to avoid a situation where you have a licensed facility that’s inspected against standards sitting next to a more permissive licence with a class E. That’s the focus of what’s being asked for: “What are you providing, and are there other services in that region?”

R. Leonard (Chair): Okay. Thanks. One more question. I’ll limit each of you questioners to three so we can get through everybody’s questions, and then we’ll come back to you again at the end.

D. Barnett: It’s my understanding that abattoirs, class A, B facility…. You must be 2½ hours between abattoirs if you wish to apply for a new licence. If there’s one 2½ hours, you can’t have a licence. My concern is we have that situation, but we have people who will not go to this particular abattoir because of issues, da-da-da…. So what is happening in my area is people are getting rid of their 30, 40 head of cattle because they now have no place to take them. How do we address this, when your class A abattoir is not servicing the public as it should?

[8:40 a.m.]

G. Last: I’ll go through the different levels of requirements. The regulation requires a class E applicant to consult with A and B operators that are within 100 kilometres and then provide information about that consultation in their application.

As a matter of policy, in the feasibility study, we focus on A and B facilities that are within two hours’ travel time. That’s determined by looking at the actual roadway, the distance, what a reasonable rate of travel is. Then if it’s within two hours’ travel time, generally we won’t recommend, but there are a lot of other factors that are taken into consideration such as: if there is an A or a B that’s within two hours’ travel time, if they are unwilling to provide custom slaughter service, then they can provide a letter to the E applicant, which will then be taken into consideration. If they can’t get those slaughter services, then that is clearly something that would speak in favour of an approval.

N. Simons: Thank you very much, Gavin. This consultation that was undertaken by the Ministry of Agriculture in March — that seems kind of recent. I’m wondering: do you see the potential for duplication, or do you see ways that we can look at things, maybe, in a different way or solicit responses from different people? I’m just curious to make sure that we’re being productive.

J. Mack: First off, our minister, as we went through the transition and briefed her on how our system works — I guess this follows up on MLA Barnett’s question — had directed us to come back to her with ideas. Are there ways where we can have credibility with animal welfare and food safety but provide the flexibility around providing those services and helping with that capacity in all the different regions of B.C.?

Our team had done some work on that. Before moving forward, we wanted to talk to the industry and other key stakeholders to test out some of those assumptions, which we’ve done. I think one thing that will help avoid duplication is that we want to complete that “what we heard” report, and we would volunteer to send that to you. Also, if you wanted a brief, in person or in writing, on that, we’d be happy to provide that to you.

As Gavin had mentioned in the presentation, one of the things that happened through that process was these two pieces of feedback. One was that because the ministry administers the system, there were questions about whether we would be taking an impartial enough view — which, I think, is a key mandate of this select committee, with broad representation: to kind of have a fresh look. The second one was that this issue was important enough that it shouldn’t just be focused on those directly involved in the system and that there should be a bit of a public face to it.

Our view is that our preparatory work dovetails well into your job. I think to avoid the duplication that you mentioned, I would just encourage you to lean on us to give you that information. Our sense is that this will be good input for you in your deliberations.

R. Leonard (Chair): Given that we are going to be going on the road come Monday, I don’t know that we’re going to get your report in time. It may come out midstream. Do you have any sense…? We’ll be done on the 13th of June, our travel — touring and talking with the public.

J. Mack: We’ll just double-check on timelines. We’ll definitely give it to you so that it’s useful prior to you finishing your report. Exactly when we can give it around your consultations, I’ll need to follow up with a bit of a plan for you.

R. Leonard (Chair): All right. Thank you.

[8:45 a.m.]

N. Simons: A brief follow-up. Have there been any major problems or concerns in your ministry about the system as it has existed since 2011? Have there been illnesses or inappropriate slaughtering, or have there been slaughter facilities that have been shut down because of a lack of…? What does the enforcement picture look like?

J. Mack: I’ll start at the top level, and then I’ll ask Gavin to speak a bit about the kinds of issues that we’ve found.

I think at a high level — back to my introductory remarks, it’s a good time to take a look at this — when the system was started, a lot of it was about trying to find more of an outcome-based approach. As Gavin mentioned, the system has moved from the Canadian Food Inspection Agency to the provincial health authorities and now, largely, the Ministry of Agriculture. I think a lot of that transition was around trying to provide a service that protects British Columbians, that maintains the credibility of the industry but that actually serves industry well — so as not to give up your regulatory hat but to be outcome-based.

On the ground, you’ll see our managers, when people come in, actually trying to coach them into having a licensed facility, because we believe that that’s a better product than sort of an out-of-sight, out-of-mind slaughter approach. But as a policy issue, we are always double-checking on whether that balance is right.

We have had groups that have asked for a class D because they have a compelling case about the limits within their region or what we would view as a subregion. We’ve looked at that, and we’ve kind of asked ourselves the question: “Can we provide more service and capacity in these areas but not lose the outcomes around animal welfare and food safety, knowing that a high-profile incident will hurt the entire industry?” That’s the policy prize, and I think that timing is good.

We do regularly have on-the-ground incidents, and I’ll ask Gavin to give some examples of the types of issues we face around illegal slaughter and others.

G. Last: Unlawful slaughter we address on a complaint basis. We do some investigation, but we have, obviously, a limited capacity to be following up all over such a large area. But on a complaint basis, we’ll hear, occasionally, of something that’s going on that’s not properly licensed. There’s a lot more, I’d say, anecdote and rumour out there. I think that is something where, if we had the resources, we would be fully engaged in following up on. We know it’s out there to some degree; how much is very hard to pin down.

From a food safety and animal welfare perspective, I would say the program has been, since the province took over, quite successful. We haven’t had anything in the way of an outbreak. I take that as a good sign that we’re doing something right, but as James has said, it’s a good time to look at it now and see what we might do in the interests of continuous improvement and to make sure that we’re getting that right balance between the needs of the public and the needs of those producers in areas where it’s a real challenge to develop a fully inspected facility.

M. Morris: A couple of questions. I’m just curious as to why we have restrictions, in the first place, on distance. Why don’t we just let the market kind of dictate where these are located? I’m just wondering where that comes from.

[8:50 a.m.]

Is there a health requirement with respect to the two-hour distance? Why is it there? I think if we lifted that restriction, we would probably see a lot more of these facilities around.

J. Mack: Well, I think that, first off, if there’s a strong market in a region, the market can allow for as many class A and B licences in that area as they want. In a case where you have multiple abattoirs setting up and they’re all following by the same rules, we’ll provide the inspection services to all of them, and it’s their job to figure out the business elements.

The only area where we get cautious is when we’re allowing more permissive rules for one person as opposed to another. It’s only when we look at these class E licences where we want to check and make sure we’re not putting an inspected regulated requirement on one business and then allowing lots of these uninspected systems around them.

I don’t know if that answered your question. If I flipped it around, the reverse worry is that if you created a business on an expectation that producers would be coming to you because of these requirements and then we allowed a lot of these class Es in that region, it creates a competitiveness issue for that entrepreneur.

M. Morris: It’s something I’d want to hear from the public when we’re making our rounds. It is a concern if…. This two-hour travel restriction, I guess, to me poses a problem. I look at the area I come from, the central interior of the province. I’ve got family members that have been involved in meat cutting and whatnot over the years — in big abattoirs, federally inspected abattoirs, as well as the class As and Bs and Es.

I have to work my mind around why these restrictions are in there in the first place. I haven’t had a real good look at the act and the regulations yet.

The other question I have, which is big up in the interior of the province, is on wild meat. Would that fall under any of those different classes? I know there are a number of entrepreneurs out there that have mobile abattoirs. During the hunting season, they’ll go around and cut meat in different places here. I’m just wondering how that can fit into the kind of structure that we look at.

G. Last: It’s not a slaughter issue because the game meat is already dead. It’s a processing matter. Many of the butcher shops that are licensed as food premises, which the Ministry of Health deals with, are able to provide those services as long as it’s for personal consumption. There really aren’t….

The processing side of it is fully available for game meat, yeah.

R. Leonard (Chair): Those answer your questions? Okay.

A. Olsen: I guess my question is…. Just back to Donna’s questions around — well, it’s kind of on some of these — the regional districts. Perhaps you can give a little bit more clarity to me and maybe to my colleagues here — they might be getting it; I’m not — around the decision to limit to the regional districts.

The assumption that I’m making, and maybe you can correct me here if I’m wrong, is that there are a bunch of complaints that were highlighted here by the A-B. So to limit it to the coast, the north and around might be in order to provide space for the A-B licences? Is that right — to limit it to the ten regional districts?

I guess I’d just like to explore a little bit further about limiting it.

G. Last: Yeah, those areas are…. Initially, when the meat inspection registration came in with the A and B licences, there were no Ds and Es available. I’d kind of turn it and say that in those areas, it’s less likely because of population and low animal production.

[8:55 a.m.]

Frankly, the challenges of providing an inspector to fly up to Atlin for somebody to slaughter one cow is challenging — to make that compromise in the level of food safety and animal welfare to allow for uninspected slaughter in those areas, where, as a practicality, it’s quite difficult to require an A or a B licence.

The choices about where those boundaries were drawn, when they were designated in regulation, were based at a high level on those principles, as I said, of population and production. As MLA Barnett has said, that’s perhaps a question that can be explored further about where you might look at other opportunities for those types of facilities.

J. Mack: Just to say, again, the responsibility came over to the Ministry of Agriculture in 2012, so just over five years now. Those class D regions are set out in regulation.

We’ve really had one persistent request, which is from the regional district of Central Kootenay. They’ve asked for their…. Again, the way that the regulation considers it, they would be a subregion to what we’ve typically looked at. It’s a government choice around whether to add a new region to regulation.

We’ve also more recently had the regional district around Port Alberni make a similar request. We have the ability to add regions in the regulation. That decision-making would consider competitiveness issues.

We have, just to flag, many examples of people who have looked at trying to get a class D or a class E region established, and when we’ve talked them through what the requirements are, they’ve actually opted to just make the investment necessary and do a class B. We have tried to coach people into a licensed facility with an inspection service and those standards, and in some cases, people have gone that way.

It is an option for us to look at adding more regions or even a different, as we’ve said earlier, balance between what the requirements are around food safety and animal welfare — sort of a credibility test against this flexibility and economic test.

G. Last: I just wanted to add to that an example, from just this week, of an application for an E facility that was also complicated by flooding in the area there. In discussion with the applicant, after raising their level of awareness about the difference between Ds, As and Bs, their conclusion was that they were going to revise their application and submit an A application.

That happens quite frequently. There is a common perception — and I would even go so far as to say, a misperception — that an A or a B is a big proposal. It’s a large facility. It’s a large undertaking. Often, when we spend some time with a proponent to make it clear about what the differences and the distinctions are, they’ll see clearly that what they want is easily achievable as an A or a B licence. The idea that “I’m just a small producer; I only need a D or an E, and I don’t need one of those big As or Bs” isn’t, in fact, accurate.

R. Leonard (Chair): Adam, do you have one more question?

A. Olsen: Yeah. In passing, you said: “If we had the resources” — maybe this was Gavin — “to be able to do this.” Could you give an analysis? I believe it’s inspection that you were talking about. Can you give us a basic analysis of where you’re at in terms of resourcing?

[9:00 a.m.]

Maybe this is a question that comes up after, but as we’re looking at this, how under-resourced is this part of the ministry? Perhaps it’s not something that…. James has got a smile on his face.

To me, I think that it’s an important thing to look at. If the ministry is moving towards wanting people to have their meat inspected for the safety of British Columbians…. You know, there’s going to be give-and-take in all of this.

Were having the conversation right now, so now might be a good time to have that as part of the discussion.

J. Mack: I’ll just clarify the resource question. One is that if an industry wants to slaughter, we provide the service. There’s a lot of work to try to provide that service efficiently, so we have full-time inspectors, but we also have auxiliary inspectors who can help out with the seasonal fluctuations.

Just to be clear, as a ministry, there’s no scenario where an industry says, “I want to start a plant,” and we say: “Well, we don’t have the budget for inspectors.” The ministry makes that happen. I would say that when the program was transferred from Health, which was before either of us were on that, there was a lot of thought in that transfer of responsibilities and resources to make sure that this could happen.

The resource constraint is really our level of ambition around compliance and enforcement. In terms of having an inspector on site at the slaughter facility, the ministry’s view is that we will provide that. It’s a requirement for us to do it. Where we talk strategically about resources and level of effort is really around unlawful slaughter and how much we do in that area.

G. Last: I was, I think, for the most part, referring more conceptually to the challenges of the geography of the province and being able to cover the entire province not only with inspection, which we’re prepared to do and will make happen when we get those applications, but also, as James has said, with the compliance and enforcement and investigation. That’s been an aspect of the meat inspection program that’s been…. I would say we’re growing our awareness of the needs and doing our best with the resources that we have right now. Again, the level of ambition is the…. Where do we want to go with it? That could be, really, the question.

J. Tegart (Deputy Chair): Thank you for the presentation. I am totally a newbie to abattoirs, so my questions may be pretty simplistic. I think it would be helpful to the committee, at some point, to get a briefing on the application process, because often it is interpretive, depending on where you are and who you are in the process. I’m sure we’re going to hear a lot of concerns about people’s interpretation of the application process. So it would be helpful to me to either get something in writing or to have a briefing around what an application process looks like.

I’ve heard concerns in regards to the regulations and distance and all those kinds of things. It would be helpful for me to know the actual reality of the process.

The other thing is the report, What We Heard. I would like this committee to consider asking the Chair to request from the ministry that report as soon as possible. I feel we are now going out next Monday, and there was a consultation done, and people are going to say: “Well, didn’t you read the report? I already gave my input.” We’re going to look pretty stupid or uninformed. Ag just went through a process, right? We’re going to be saying: “Well, we don’t have the report yet.” “Well, I’m not going to give you more input, because I already did mine.”

It would be extremely helpful for us to have that as soon as possible so that we can take the information from that report as we listen to the input.

The other thing I was wondering was if there was an annual report through Ag that talked about some of the challenges around abattoirs and some of the concerns that the ministry has seen through the inspections.

[9:05 a.m.]

I’m not a farmer, but I haven’t seen a lot of information around the amount of inspections, the issues that have come from that — whether we’re over-inspecting, under-inspecting, those kinds of things. That information would be helpful to me. So thank you.

No question, quite obviously, but lots of information, perhaps, that you could provide us with.

R. Leonard (Chair): I will definitely follow up with the ministry on getting that report as soon as possible for us, in whatever form we can.

Is there anything you’d like to say in response to Jackie’s comments, particularly around the issues of the challenges in inspections?

J. Mack: One is that we’ll undertake to get that What We Heard report to you as soon as possible.

On the application process, we can definitely follow up in writing and make sure that you’ve got the actual application form as well as our assessment. I don’t know, Gavin, if there’s some information we could give on this?

G. Last: Yes. On application process, there are obviously different types of licences, different processes. The health authorities have their own processes for the D licences and for the Es as well. We can summarize all of that and put it together easily.

In terms of an annual report, the program in the ministry’s hands has been running successfully for a few years. It’s something that I would like to do as an annual report, but we’re putting into place an electronic system that’s going to be providing the data to….

I want to. This is aspirational — to do an annual report that captures that data and tells a story about what we’re doing. We do that for the seafood program, which has been running under the ministry for many, many years, and eventually want to take the meat inspection program to the same place.

The stats are gathered and available through our ministry’s statistical reporting but wouldn’t be quite what I think that you’re looking for in terms of more of a narrative of the story about how the program is doing.

R. Leonard (Chair): Thank you very much. I see recommendations starting to burble up.

I’ll turn the floor over to Doug now.

D. Routley: The first question I have is…. I’ll briefly state that I can see how someone who had made an investment in an A or B facility this large would be very much undermined if there was a proliferation of unlicensed or more loosely regulated facilities around them, particularly when, as I understand it, there are no restrictions on ownership.

You could have a situation where a person could own multiple D facilities. Is that possible? I’m wondering. Along that line…. I can see why the restriction is there. I support the idea that an investment shouldn’t be undermined when we have insisted on them meeting a certain standard.

On the ownership side of D facilities, or even A and B facilities, are there any co-ops operating that control facilities?

G. Last: There is one, and it is on one of the islands.

D. Routley: Gabriola, I think.

A. Olsen: Saltspring.

G. Last: Saltspring — that’s the one.

D. Routley: Along that line, as well, a lot of the emphasis has been on two-hour travel. A producer on Gabriola, for example, has to send his product on two ferries, basically, to get the processing done. Even though it’s not a two-hour distance, the costs…. The obstacle in that case is cost, and time, but not travel time perhaps.

If you could address that. And one more after that.

G. Last: Marine travel is definitely one of the factors that’s taken into consideration. In fact, it’s actually mentioned in the regulation.

[9:10 a.m.]

D. Routley: The third question would be around the consistency of inspections. We’ve all heard the stories. I know of one producer…. It’s more than anecdotal, because I witnessed this happen, or the consequences of it. An inspector came in and said: “You’ve got a two-inch drain; you need a four-inch drain.” So he put in a four-inch drain. Another inspector came later in the process and said: “You need a two-inch drain.” So he went two times to excavate the floor of the facility to change the plumbing.

I’m just wondering how we are doing on consistency.

G. Last: The province has established a more outcome-based approach, which does leave the possibility of that type of situation. In terms of the structures and the buildings, we have a code of practice that, again, is more outcome-based and has that potential.

I don’t want to use the word “audit.” We do annual reviews with each inspector, more focused on the actual inspection of slaughter, to ensure that’s consistent, in order to achieve that consistency. Those types of issues, obviously, where you get conflicting direction from an inspector — we want to avoid and do everything we can to ensure it doesn’t happen.

We have pretty strong relationships with the…. That is necessary when inspectors are working side by side in the facilities with the operators and their staff. We encourage good working relationships, and I would hope that an operator who’s faced with a situation like that would raise it to a regional supervisor or to my attention, when it’s clear that you’ve got two different inspectors that are telling them different stories.

I don’t want to say that that’s just going to happen because we have outcome-based approaches, but we want to keep an eye on it to ensure that it doesn’t, because obviously it’s incredibly unproductive.

J. Mack: Just to really stress that message. If you are hearing from producers…. Two things. One is that some of the stories do predate…. We heard a lot of those stories from when the Canadian Food Inspection Agency was running the program. So one is to check the date of the issue.

This is one that Gavin’s management team works a lot on. There are superintendents for each region. It’s an expectation that they have good relationships with those industries. It will happen, where you get a different approach from one inspector to another, and it’s their job to be that double-check.

I would just encourage you…. Often, when this comes to the minister’s attention or mine, we get Gavin personally to sort through that. If you pick up on those, please forward them to us, because we have that objective of providing a consistent service.

D. Routley: Just as a follow-up. It probably does predate the transition from the CFIA.

I used to build houses, and we had similar things happen sometimes with electrical inspection or building inspection, where there were conflicting instructions and directions. It’s unfair to characterize all the inspectors by the problems that we hear anecdotally from people or we experience ourselves. I do believe that they are mostly there to facilitate people thriving, as you suggest.

But where we do find those kinds of situations, if you do find them, how are they dealt with? Is there a process for people to appeal this sort of thing, where we could diffuse those kinds of dynamics that can develop between inspectors and the people being inspected?

[9:15 a.m.]

G. Last: Absolutely. I wouldn’t call it a formal process, but as a team, the supervision and management is, as we’ve already said, very attuned to the need for strong working relationships so that we’re getting this information and able to address it in a timely and effective way so that it doesn’t get in the way of us doing our jobs and them doing their jobs.

R. Leonard (Chair): Ian, you haven’t asked any questions, before I go on to any repeat questioners.

I. Paton: What I see is probably a very simplified view of some of the issues. We have a very large province with not that many head of livestock. The issue we have is a geographical area that’s so massive, yet the class As and Bs are trying to make a living, trying to get as many animals as they can in the course of a week to make it profitable to run their business. If they see all these little Ds and Es cropping up around, they’re obviously taking away some livestock that would go to an A and B that have probably paid more.

Correct me if I’m wrong. Are they paying more for A and B licences than Ds and Es and more capital costs of putting together an A and B facility?

G. Last: There’s no cost for the actual licence. There’s no licence fee; there’s no charge for that. There’s no cost; we’re not charging for inspection for As and Bs. It’s the cost of building the facility that you’re describing. There’s a tremendous range, obviously. I would say that at the bottom end of the range, for a smaller A or a B, you’re going to have overlap with the cost of a D or an E facility. There’s not a lot of difference in terms of the cost.

I. Paton: Okay. Can you describe, then, the cost or the infrastructure of the facility for A and B versus D and E as far as the square footage of, say, the kill floor, walk-in coolers, all those different things that would separate those four licences?

G. Last: The size isn’t prescribed. We have outcome-based regulations and a code of practice that describes the requirement in terms of how it must be done in a way that allows for proper animal handling, that allows for proper treatment of the animals, that animal welfare is enabled, and that food safety outcomes are supported. We’ll go as far as saying that there must be hard surfaces that are capable of being washed, but it does not say that it has to be this size by this size or drain sizes, that sort of thing. It’s all outcome-based.

The code of practice for As and Bs is something that we’ve recently revisited and revised and updated. That’s available as the best available knowledge to guide licensing decisions but also for proponents to look at and determine the requirements that they need to meet. We have a draft code of practice for the Ds and Es, the rural facilities, but it’s never been finalized. It’s used as guidance, I understand, by one health authority in particular. That’s a question that was part of the D-E consultation: do we need to have a mandatory code of practice to support decisions about the construction of D and E facilities?

I. Paton: Thank you. Again, another question. It must be rather difficult with your inspectors all over the province. What are they doing during the week when they’re not inspecting an abattoir?

[9:20 a.m.]

As we can tell, there are some of these abattoirs, even As and Bs, that are only doing, you know, three steers on a Tuesday, and then they might do eight lambs on a Friday. These guys have to travel. What are your inspectors doing in between going to inspect at slaughterhouses?

Then I guess the other question is: your provincial health inspectors that are doing the Ds and Es — what’s their routine as well? Do they have to be at the facility at the time of kill, for Ds and Es?

G. Last: I’ll address the question about As and Bs first. The scheduling of our inspectors at A and B facilities is very complex. As James mentioned earlier, we have not only full-time inspectors, but we also have what we call auxiliary inspectors who are called in on an as-and-when-needed basis. So they’re only on the clock when they’re actually working.

We’re obviously trying to be as efficient as possible in the scheduling. There is a lot of travel. There is a lot of time on the road, and this can be a real challenge at certain times of the year.

There is some time with the full-time employees at slower times of the year, but we try to limit the number of full-time employees to avoid that where we can. There is a bit of downtime, and they do work in the office on other projects when they don’t have something scheduled. Does that answer your question as far as they’re concerned?

I. Paton: Yep.

G. Last: With the D and E facilities…. The regional health authorities’ inspectors are called environmental health officers, and they have a wide range of responsibilities for inspection. They’re looking at everything from restaurants to hotels to swimming pools, anything that’s permitted or licensed. The decisions about what their priority for inspection on any given day is made at the local level.

They are not required…. I’ve got to be absolutely clear on this. They are not present for slaughter, ever. That is the key difference between the As and Bs and the Ds and Es. There is no inspector standing there watching the slaughter in the Ds and Es. That’s why the product that comes from those facilities has to be labeled as “not government inspected.”

R. Leonard (Chair): One more question. All right.

I. Paton: When I was shipping cattle from my own farm, I would ship to, in the old days, J & L meats in Cloverdale or AGM meats, also in Cloverdale, which both had kill floors. I was also around when the outbreak of mad cow came around. Maybe you could explain to the group the tracking system, because that’s got to be a very important part of what everybody’s doing — the ear-tag tracking system. So they know exactly where every animal came from, when it’s processed. If there is any sort of a health outbreak, you can track that animal to exactly what farm it came from.

G. Last: We only have ten to noon? I’d be happy to come back and provide a full briefing on the traceability system. As you say, it’s comprehensive and complex. But there is, for cattle…. There are different systems for different animals, and traceability is a big part of the work that we do in relation to food safety. It is quite a comprehensive system.

R. Leonard (Chair): If I can just follow up on that in terms of the class Ds and Es. Does the issue of traceability, the rules around that, apply as well?

G. Last: They do, again, for the tagging system for cattle and the traceability systems in place for pork. They are required to keep records, the Ds and Es. The regulation requires that they keep a record of where the animal came from and details around that.

I. Paton: A question for you, Madam Chair. On this trip that we’re going to take, starting on Monday, do we have feedback as to how many people have registered for these meetings? Because frankly….

R. Leonard (Chair): We’ll speak to that at the next….

I. Paton: I would think it’s the busiest time of the year for farm folk, and to be flying into towns where there’s only one person that’s signed up to meet with us would….

[9:25 a.m.]

R. Leonard (Chair): We’ll be speaking regarding the tour in the next session, in camera.

I have two follow-up questions from Nick and Adam. Then after that, I will say thank you very, very much for attending, and we will definitely be following up on some of these things. You’ll be hearing from us again.

N. Simons: We’re talking a lot about cattle, and I’m just wondering if there’s a breakdown of what type of slaughter we do in the province and if we always measure it by head or if we measure it by weight or volume or what have you. Just to see the breakdown between pork and cattle, etcetera. I think, just to clarify for Ian, that’s the second agenda item that we’re going to talk about, not next session. We’re going to talk about….

R. Leonard (Chair): Next item. Next section, I said.

G. Last: We can provide the statistics on production. We’ll put that together for you.

R. Leonard (Chair): Thank you very much. We’ll probably have to provide you with a list of what it was that you were asked for.

D. Barnett: Why, after five years, do they have to reapply for class D and E? What is the rationale for making them reapply?

G. Last: Particularly for the E, it’s a matter of another — if a licensed A or B facility opens up in proximity. If we make a recommendation to a health authority to approve an E licence, and they’re established, it’s on the basis that they’re not within that range of an A or B facility and that the slaughter services that they require are not available to them. If during that time, an A or B facility is approved that can provide that slaughter service with that higher standard of food safety and animal welfare, then the need for the E is no longer there.

D. Barnett: Thank you very much for that. That certainly answers a few questions of some very angry E licensees.

J. Tegart (Deputy Chair): Just a follow-up to that. If I’m a small business owner in Ashcroft and I have to consult with Wal-Mart as to whether I can continue my business, I have an issue with that. I think that is probably something we’re going to discuss quite a bit, because if I’ve got an established E-licensed facility and my neighbour decides to open up an A and put me out of business, I’m going to be pretty angry.

We need to have that discussion. I’ve certainly heard from some people in regards to: “I’ve established my business. I’ve got my clientele. I provide a service. I’ve done it well for five years. In comes Wal-Mart, and I’m out of business.”

I think it’s one of those issues that we’re going to hear about. I’m sure you’ve probably heard about it in your consultation.

R. Leonard (Chair): Do you want to respond to that? Or is that just more of a statement?

G. Last: All I would add is that we make it very clear that there is no expectation of renewal of a licence. We don’t renew licences. It’s a reapplication, and the conditions are new. Nobody should ever go into becoming a D or an E operator with the expectation that they’ll be allowed to, under the current regulatory scheme, continue in perpetuity.

R. Leonard (Chair): I appreciate that. I have one…. Oh. Go ahead.

G. Last: It’s also always available to them to apply for an A or a B licence themselves, which I’ve said. I hope I’ve stressed…. If they’re successful, and they’ve been running smoothly for that amount of time, it probably isn’t a great leap for them.

[9:30 a.m.]

R. Leonard (Chair): Thank you very much. I actually have a question, but it is 9:30. I’ll ask it, but I won’t expect an answer. We haven’t talked about the mobile abattoirs and where they fit into the whole scheme of things. We’ll save that for next time.

Again, thank you very much. If you’d like to have any closing remarks before we break for five minutes….

J. Mack: My closing, I guess, would just be on next steps. We have a series of information that we’ll send back to you, and I will undertake to get you our report on what we heard, with an intent to getting it to you timely, given that you’re on the road on Monday.

I believe the only outstanding issue there would just be to talk to our minister around the nature of that. Our intent is that it would be a public report, so I think we can provide it to you. The question will be around whether that’s for your information or ready for being a public record. It will be a public record, but we need to apply that due diligence.

I thank you for your time, and I would just say again: please don’t hesitate to reach out to us for information. We’ve got a lot of staff who really love this topic, and we’re eager to see what you come up with. So please use us to get information, to double-check things. If you do hear about concerns from our stakeholders, please direct them to us so that we can resolve them.

Thank you for your time.

R. Leonard (Chair): Thank you very much.

We’ll recess for five minutes now.

The committee recessed from 9:31 a.m. to 9:37 a.m.

[R. Leonard in the chair.]

R. Leonard (Chair): All right. Can I have a motion to go in camera?

A. Olsen: So moved.

Motion approved.

The committee continued in camera from 9:37 a.m. to 9:53 a.m.

[R. Leonard in the chair.]

D. Barnett: I move we adjourn.

R. Leonard (Chair): Now we’re adjourned. Thank you very much, everybody. Have a great day.

The committee adjourned at 9:53 a.m.