U.S.-Canadian Food Safety: Opportunities for Sharing Information and
Coordinating Inspections (Letter Report, 11/22/94, GAO/RCED-95-45).

The United States and Canada are long-standing trading partners, and
both import large amounts of food from other countries. The two
countries have also established similar systems to guarantee the safety
of imported foods.  Recent international trade agreements, such as the
General Agreement on Tariffs and Trade and the North American Free Trade
Agreement, are smoothing the way for increased trade in foods.  GAO and
Canada's Office of the Auditor General undertook a concurrent review to
examine how the United States and Canada share information on and
coordinate activities for shipments of unsafe foods and foreign
food-processing plants.  The Canadian report, entitled Federal
Management of the Food Safety System: Concurrent Review of Third-Country
Food Imports, accompanies this report.  The joint survey concludes that
although Canadian and U.S. agencies share information about food safety
on an informal and ad hoc basis, a more comprehensive system for sharing
information about food shipments and inspection of foreign food
processing facilities would help both countries better target food
safety resources.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-95-45
     TITLE:  U.S.-Canadian Food Safety: Opportunities for Sharing 
             Information and Coordinating Inspections
      DATE:  11/22/94
   SUBJECT:  International cooperation
             International agreements
             Agricultural products
             Agricultural policies
             Food inspection
             Customs administration
             Contaminated foods
             Import regulation
             Regulatory agencies
             Information dissemination operations
IDENTIFIER:  North American Free Trade Agreement
             NAFTA
             Canada
             
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Cover
================================================================ COVER


Report to the Congress

November 1994

U.S.-CANADIAN FOOD SAFETY -
OPPORTUNITIES FOR SHARING
INFORMATION AND COORDINATING
INSPECTIONS

GAO/RCED-95-45

U.S.-Canadian Food Safety


Abbreviations
=============================================================== ABBREV

  FDA - Food and Drug Administration
  FSIS - Food Safety and Inspection Service
  GAO - General Accounting Office
  NAFTA - North American Free Trade Agreement
  OAG - Canadian Office of the Auditor General

Letter
=============================================================== LETTER


B-259012

November 22, 1994

To the President of the Senate and the
Speaker of the House of Representatives

The United States and Canada are long-standing trading partners, and
both import substantial amounts of food from other countries.  The
two countries have also set up similar systems to ensure the safety
of imported foods.  Recent international trade agreements, such as
the General Agreement on Tariffs and Trade and the North American
Free Trade Agreement, are smoothing the way for increased trade in
foods and providing opportunities for the United States and Canada to
work cooperatively to ensure the safety of imported foods and make
better use of each country's limited inspection resources. 

GAO and Canada's Office of the Auditor General (OAG) undertook
concurrent reviews to (1) examine how the United States and Canada
share information on and coordinate activities for shipments of
unsafe foods and foreign food-processing plants and (2) determine
whether opportunities exist to make better use of limited resources
and thereby increase the likelihood that unsafe imported foods would
be stopped from entering the United States and Canada.  The GAO and
OAG teams performed the work concurrently, concentrating on their
respective country's food safety systems and collaborating where
appropriate, and are issuing separate reports.  The OAG report,
entitled Federal Management of the Food Safety System:  Concurrent
Review of Third-Country Food Imports, accompanies this report. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

U.S.  and Canadian food safety officials share information through
agency-to-agency exchanges and cross-border contacts at ports of
entry.  These efforts, which are generally informal and ad hoc,
include some routine exchanges and focus primarily on (1) shipments
of potentially unsafe foods, (2) food shipments refused entry by one
country that may be rerouted to the other, and (3) inspections of
foreign food-processing plants. 

Opportunities exist to develop a more comprehensive system for
sharing information about shipments of unsafe foods and inspections
of foreign food-processing plants and for coordinating these
inspections.  These improvements would enable the two nations to
better target their limited inspection resources. 


   BACKGROUND
------------------------------------------------------------ Letter :2

The United States imports substantial amounts of food.  In 1993, the
value of food imports from countries other than Canada amounted to
about $21 billion.\1 Similarly, the value of Canadian food imports
from countries other than the United States totaled about $3.2
billion.  The United States and Canada are concerned about imported
foods since these foods are produced and processed under unknown
conditions. 

Each country has several federal agencies that regulate and monitor
the safety of imported foods.  In the United States, the Department
of Health and Human Services' Food and Drug Administration (FDA) is
the federal agency responsible for overseeing the safety of most
domestic and imported food products, including fish and seafood.  The
U.S.  Department of Agriculture's Food Safety and Inspection Service
(FSIS) is responsible for ensuring the safety of domestic and
imported meat and poultry products.\2

In general, Health Canada establishes the standards for food safety
and has overall responsibility for ensuring that all food sold in
Canada meets federal health and safety standards.  Health Canada
shares responsibility for inspections with Agriculture and Agri-Food
Canada, which is responsible for inspecting meat, poultry, fruits,
vegetables, dairy products, and eggs, and with Fisheries and Oceans
Canada, which is responsible for inspecting fish and seafood. 

The two countries' systems and standards for ensuring the safety of
imported foods are similar.  For meat and poultry, both FSIS and
Agriculture and Agri-Food Canada certify that foreign countries'
processing and inspection systems are equivalent to the respective
U.S.  and Canadian domestic systems, then supplement that
certification with inspections of foreign plants and spot checks of
imports.\3

For other foods, the two countries generally exercise control by
selectively inspecting imports as they enter the country, although
FDA and Fisheries and Oceans Canada inspect some foreign plants as
well. 

The United States and Canada each inspect a limited amount of
imported foods.  The countries determine which foods to inspect on
the basis of factors such as experience with the products and
producers and their resources.  In the United States, FSIS samples
and examines about 15 percent of the meat and poultry imported from
countries other than Canada.  FDA samples and analyzes, on average,
less than 2 percent of all other imported foods; inspection rates are
higher for high-risk foods, such as seafood and low-acid canned
foods, and those with a significant history of violations.  In
Canada, Agriculture and Agri-Food Canada inspects about 20 percent of
the imported meat and poultry and lesser amounts of other foods. 
Fisheries and Oceans Canada inspects, on average, about 17 percent of
the imported seafood.  In both countries, foods that do not pass
inspection may be conditioned, destroyed, or reexported at the
discretion of the importer with one exception--meat rejected by
Canada cannot be conditioned.\4 Some imported products, such as those
with a history of violations, are detained automatically when they
enter either the United States or Canada; inspectors must
specifically determine that these foods comply with applicable
standards.  Other products are inspected according to a sampling plan
determined by such factors as the risk of contamination. 

Recent international events are smoothing the way for increased trade
in foods.  Under the General Agreement on Tariffs and Trade, the
world's nations are moving toward equivalent food safety standards
that are expected to facilitate trade and thus increase food imports
into the United States and Canada.  Furthermore, the North American
Free Trade Agreement (NAFTA) promises to lessen customs restrictions
on trade between the United States and Canada, making it easier for
foods imported into one country to pass into the other.  Finally,
U.S.  and Canadian efforts under the Canada-United States Free Trade
Agreement and NAFTA are helping harmonize the two countries' food
safety standards, making it easier for the two countries to share
information and to rely on each other's food safety information. 


--------------------
\1 Canada supplies much of the food imported into the United States. 
In 1993, 16 percent of U.S.  food imports originated in Canada. 

\2 For further explanation of the U.S.  domestic food safety system,
see Food Safety and Quality:  Who Does What in the Federal Government
(GAO/RCED-91-19B, Dec.  21, 1990). 

\3 In response to the 1988 Canada-United States Free Trade Agreement
and because the two countries' domestic meat and poultry inspection
systems were deemed equivalent, the United States and Canada agreed
that they would no longer inspect each other's meat and poultry
plants.  Instead, they rely primarily on each other's reviews of
domestic plants and a system of spot checks at the border to ensure
continued compliance with each other's standards. 

\4 GAO reported in 1992 that FDA's records showed a long-standing
problem of importers distributing some adulterated foods: 
Pesticides:  Adulterated Foods Are Reaching U.S.  Grocery Shelves
(GAO/RCED-92-205, Sept.  24, 1992). 


   CURRENT APPROACH FOR SHARING
   INFORMATION
------------------------------------------------------------ Letter :3

Recognizing the value of sharing information about imported foods,
the United States and Canada have, over time, developed an ad hoc
system for communicating selected information about unsafe food
imports.  Agency-to-agency arrangements have been established between
(1) FSIS and Agriculture and Agri-Food Canada for meat and poultry
products, (2) FDA and Fisheries and Oceans Canada for fish and
seafood products, and (3) FDA and Health Canada for all other food
products.  In addition, some officials communicate with one another
at the regional level.  For example, FDA officials in Blaine,
Washington, work closely with officials of Fisheries and Oceans
Canada, located about 40 miles away in Vancouver, Canada.  Table 1
describes selected regional and agency-to-agency arrangements for
sharing information on potentially unsafe imports, foods rejected as
unsafe, and inspections of foreign plants. 



                                     Table 1
                     
                        Selected Arrangements for Sharing
                      Information on the Safety of Imported
                       Foods Between the United States and
                                      Canada

Type of information
exchanged and
agencies involved    Arrangement
-------------------  -----------------------------------------------------------
Potentially unsafe products being shipped to North America
--------------------------------------------------------------------------------
FDA and Health       FDA headquarters provides Health Canada headquarters with
Canada               real-time, electronic "import alerts" on products to be
                     detained automatically at the port of entry and with
                     operational guidance and bulletins concerning import
                     operations.

                     FDA headquarters provides Health Canada headquarters with
                     monthly summary information on products, producers, and
                     countries shipping products to the United States that do
                     not comply with U.S. rules and regulations.

                     FDA and Health Canada headquarters provide each other with
                     information on all food products recalled.

FDA and Fisheries    Fisheries and Oceans Canada's Pacific Region can read FDA's
and Oceans Canada    import alerts electronically by dialing into the FDA
                     Pacific Region's computer system.


Shipments refused entry by one country that may be reroute the other country
--------------------------------------------------------------------------------
FSIS and             FSIS and Agriculture and Agri-Food Canada's inspectors in
Agriculture and      regions notify one another--via fax through headquarters--
Agri-Food Canada     of rejected shipments being shipped to or through the other
                     country.

FDA and Fisheries    FDA's Northeast Region and Fisheries and Oceans Canada's
and Oceans Canada    Central and Arctic Region notify each other--by fax,
                     telephone, or letter--of rejected shipments of unsafe foods
                     rerouted to the other country.

                     FDA's Seattle District and Fisheries and Oceans Canada
                     officials in British Columbia notify each other--by fax or
                     telephone--of rejected shipments of unsafe foods rerouted
                     to the other country.

FDA and Health       Some FDA and Health Canada regional officials occasionally
Canada               notify each other--by fax, letter, or telephone--of
                     rejected shipments rerouted to the other country.


Inspections of foreign plants
--------------------------------------------------------------------------------
FSIS and             FSIS makes available to Agriculture and Agri-Food Canada
Agriculture and      its annual list of foreign meat-processing plants certified
Agri-Food Canada     to ship to the United States.

FDA and Agriculture  In February 1994, FDA agreed with Agriculture and Agri-
and Agri-Food        Food Canada, Fisheries and Oceans Canada, and Health Canada
Canada, Fisheries    to exchange data on inspections of foreign plants. FDA
and Oceans Canada,   provided the Canadian agencies with the names of the
and Health Canada    foreign food-processing plants inspected and the inspection
                     results. The Canadian agencies agreed to provide similar
                     information to FDA but have not yet done so.
--------------------------------------------------------------------------------

   OPPORTUNITIES FOR ENHANCING THE
   SAFETY OF IMPORTED FOODS
------------------------------------------------------------ Letter :4

Opportunities exist for improving the current U.S.-Canada
information-sharing system in two areas:  (1) shipments of unsafe
foods refused at one country's port of entry and (2) inspections of
foreign food-processing plants.  In addition, although each country
inspects some foreign plants that export to it, the two countries do
not maximize the use of limited resources by coordinating inspections
of plants that export to both countries. 

While the current ad hoc system alerts each country to some problems
with unsafe imported foods detected by the other, it does not ensure
that all relevant information is exchanged.  Neither the United
States nor Canada informs the other country of refused shipments
being returned to the country of origin, even though those shipments
could be rerouted once they leave port.  Furthermore, the two
countries do not always notify each other about shipments rejected at
their respective borders that are then sent directly to the other
country.  For example, in 1993 the Canadian government notified U.S. 
officials about rejected shipments in 25 of 37 instances.\5 Similar
information on U.S.  notifications to Canada was not available
because the U.S.  agencies do not consistently document this
information.  The United States is even less systematic in notifying
Canada of such refused shipments, in part because FDA officials,
unlike their Canadian counterparts, usually do not know where the
shipments are going until they have left the country.  The U.S. 
Customs Service, which is responsible for ensuring that rejected
shipments of food leave the United States, generally does not notify
FDA until after the shipments have left. 

Even when U.S.  officials are notified of problem shipments, their
follow-up is sporadic.  For example, for the 25 rejected shipments
that Canadian officials reported to the United States in 1993, the
United States traced 11 shipments and part of another, while 13
shipments and part of another remained unaccounted for.  FSIS was
responsible for eight of the unaccounted-for shipments.  FSIS either
did not track or did not document its tracking of these shipments. 
FDA, which was responsible for the remaining unaccounted-for
shipments, could not track them because it either could not identify
the port of entry or had no record of the Canadian notification. 
Officials from FDA and FSIS cited scarce resources as their reason
for not putting more emphasis on tracking each rejected shipment. 
For details on Canada's tracking of shipments rejected by the United
States, see the accompanying OAG report. 

The United States and Canada have an opportunity to build on each
other's information about foreign food-processing plants that ship
products to North America.  Although both countries inspect these
plants, they share little information on the results of those
inspections or recurring problems with the plants.  For
meat-processing plants, where most U.S.  foreign inspections occur,
the only inspection information shared is FSIS' required annual list
of plants that have been certified and decertified.  Agriculture and
Agri-Food Canada receives a copy of this published list.  However,
neither FSIS nor Agriculture and Agri-Food Canada asks for or
provides the results of its inspections to its counterpart agency. 
For foreign seafood-processing plants, FDA and Fisheries and Oceans
Canada began, in February 1994, to discuss sharing the results of
their inspections annually.  To date, FDA has provided a list of the
foreign plants it has inspected and the results to Fisheries and
Oceans Canada.  A more routine exchange of information would enable
both countries to learn where duplication is occurring or coverage is
lacking and help them identify problem plants for future inspections. 

Additional information about each country's experiences in inspecting
foreign plants could, in turn, enable the United States and Canada to
maximize scarce inspection resources by coordinating such
inspections.  For example, between 1991 and 1993, FSIS and
Agriculture and Agri-Food Canada inspected the same meat and poultry
plants 103 times--6 percent of the United States' annual inspections
and 76 percent of Canada's inspections.  During the same period, FDA
and Fisheries and Oceans Canada inspected five of the same
tuna-processing plants--3 percent of FDA's inspections of low-acid
canned food plants and 33 percent of Fisheries and Oceans Canada's
inspections.\6

At the same time, many foreign food-processing plants were not
inspected by either country.  For example, in 1991, 1992, and 1993,
neither FSIS nor Agriculture and Agri-Food Canada inspected 300 (on
average) of the 750 foreign meat-processing plants certified to
export to the United States.  For the same period, neither country
inspected over 35,000 of the estimated 36,000 processing plants that
export seafood or low-acid canned food to the United States. 

The disparity between the way the United States covers
meat-processing plants and other food-production plants in foreign
countries occurs largely because of the way U.S.  laws divide
responsibility and resources for inspecting such plants between FSIS
and FDA.\7 For example, FSIS, which oversees approximately 750
foreign plants certified to export to the United States,\8 spent $2.5
million to inspect foreign plants in fiscal year 1993.  FDA, which
spent about $300,000 to inspect foreign plants in the same period, is
responsible for the safety of all other imported foods, including
high-risk foods, from over 36,000 foreign plants. 

U.S.  and Canadian officials acknowledge the need to avoid
duplicating effort and to enhance coverage by sharing inspection
results.  According to officials from both governments, the two
nations would have to establish that their foreign inspection systems
were comparable before they could fully depend on the results of each
other's foreign inspections.  The domestic inspection programs for
meat and poultry in both countries are considered to be equivalent. 
Therefore, U.S.  agency officials believe that the two countries'
systems for inspecting all foods are probably similar enough so that
the United States and Canada could use each other's inspection
results when planning upcoming inspections in order to target their
resources more efficiently and effectively. 


--------------------
\5 The total of 37 instances of rejected shipments that were then
sent to the United States was calculated using notifications reported
by the Canadian Auditor General's staff and FDA. 

\6 Canada inspects far fewer plants--for example, it inspected 16
meat and 4 seafood plants in 1993, compared with U.S.  inspections of
576 meat and 52 low-acid canned food plants during the same period. 

\7 In general, food products under FSIS' regulatory jurisdiction must
be inspected and approved as meeting federal standards before being
marketed.  Food products under FDA's jurisdiction, however, may be
marketed without the agency's prior approval.  Thus, by law, meat-
and poultry-processing plants are inspected much more
frequently--thereby garnering more inspection resources-- than other
types of food-processing plants. 

\8 This figure does not include inspections of Canadian plants, which
are generally covered under a separate bilateral agreement. 


   CONCLUSIONS
------------------------------------------------------------ Letter :5

As the border between the United States and Canada becomes more open,
the two countries are becoming increasingly aware of the value of
cooperating fully to ensure that unsafe food does not enter either
country and of making better use of each country's limited resources. 
Agencies and some agency officials have taken actions on their own to
establish informal cross-border arrangements to share information
about unsafe imported foods.  We believe these efforts are
commendable.  By notifying each other about rejected shipments and
making each other aware of which processing plants have passed or
failed inspection, the United States and Canada could build on the
current system and better ensure that unsafe food does not enter
either country.  Furthermore, inspection coverage of foreign
food-processing plants could be more comprehensive if the two
countries coordinated inspections. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :6

To better ensure the safety of imported foods and to make better use
of limited resources, we recommend that the Secretaries of
Agriculture and of Health and Human Services take the lead in
developing, in concert with their Canadian counterparts and to the
extent necessary with the U.S.  Customs Service, a more comprehensive
system for sharing crucial information on and coordinating activities
for unsafe imported foods.  As part of this comprehensive system, the
agencies should consider coordinating U.S.  and Canadian inspections
of foreign food-processing plants. 

While developing a comprehensive bilateral system will take some
time, there are shorter-term steps that U.S.  agencies could take to
tighten control over unsafe food that has been rejected by one
country and routed to the other.  Specifically, we recommend that the
Secretaries of Agriculture and of Health and Human Services direct
that FSIS and FDA ensure that available information on rejected
shipments being sent to Canada is transmitted to the Canadian
government and that information from the Canadian government on such
shipments being sent to the United States is consistently followed
up. 


   AGENCY COMMENTS AND OUR
   RESPONSE
------------------------------------------------------------ Letter :7

We discussed a draft of this report with FSIS' Director, Review and
Assessment Programs, and FDA's Director, Division of Import
Operations Policy.  They generally agreed with the information we
presented, and we incorporated their suggestions where appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :8

In developing information for this report, we spoke with and obtained
documentation from FDA and FSIS officials at headquarters and at
selected regional and port sites in the states of Washington,
California, and New York.  We provided relevant parts of this
information to our counterpart OAG team.  In turn, we received from
the OAG team information from officials at Agriculture and Agri-Food
Canada, Fisheries and Oceans Canada, and Health Canada in
headquarters and corresponding regional locations. 

We conducted our review between November 1993 and October 1994 in
accordance with generally accepted government auditing standards. 


---------------------------------------------------------- Letter :8.1

We are sending copies of this report to appropriate congressional
committees; interested Members of Congress; the Canadian Parliament;
the Secretaries of Agriculture and Health and Human Services; the
Commissioner, Food and Drug Administration; the Acting Administrator,
Food Safety and Inspection Service; and other interested parties.  We
will also make copies available to others on request. 

Charles A.  Bowsher
Comptroller General
of the United States


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I

FOOD AND AGRICULTURE ISSUE AREA

Robert A.  Robinson, Associate Director
Edward M.  Zadjura, Assistant Director
Karla J.  Springer, Project Leader
Keith W.  Oleson, Adviser
Marci D.  Kramer, Evaluator
Donya Fernandez, Evaluator
Carol Herrnstadt Shulman, Communications Analyst

