To: Gavin Downing
Food Safety Policy Branch. OMAF
While reading the Proposed Food Safety Program for Fish and Fish
Products released by the Food Safety Policy Branch,
OMA&F this last week of April, I was a dismayed somewhat
to see that a stakeholder meeting was to be held 10 days
hence. Is this quickness indicitive of the agencies resolve to finalize
some pressing matters that just came to light. I think not.
You don't have to be the pervbial rocket scientist to determine that
this is the bussiest part of the year is for those in the private
sector involved with fresh fish. Not to mention the due date of first
quarter paper work forced upon on the private sector by various
government agencies. So why right now? I ask. I'm sure, many of
us can come up with some very explicit reasons. It is unfortunate that
the timing of the reply for this paper that has been in the works for
many months appears to be a prevelant and prevailing lack of
(if not contempt) afforded to those in the private sector.
The document appears to be broad in it's approach (pobably as it should
be). However, it is also vague in that it does not include
definitions. The definitions which would help one understand (and
complete) the discussion feedback form; At
present the disscssion document appears to include privately owned fish
in private ponds on private land; yet fails to mention how any proposed
laws might affect the thousands of people seved by fish camps and
charter fishing services: fish raised by the crown or anyone else that
is in possession of an unhealthy fish (whatever that definition may be)
whether it be raised by the crown or the private sector.
Clearly it will take some time to catch up with the thinking that has
already gone into this document; hopefully the stakeholder
information meetings will shed some insight into the
forethought and ramifications of any new direction being proposed.
I think it imperative that we all work together in a cohesive fashion
to avoid another fiasco like happened when the Canadian Food
Inspection Agency decided to apply 'the' science-based,
risk management approach to the red meat industry in which a
very large mumber of well run privately owned rural arbitors were put
out of business not because of food safety but because the governement
deemed to put them out of business to satisfy their own agenda. Sorry
to be so syninical but this and the more recent "sussui"
and "flying squirl" incidents seems to confirms ones worest fears
about the responsible credibility of that agency.
In closing, I'd like to thank the people at OMAFf for their due
dilegence and their ability to regonize the existing food safety
record (mentioned several times in the discussion paper)
of the fish industry. I wonder if todays government officials
have any concept of how and why this enviable food safety record has
evolved over the years; for the most part - without the need of
government intervention. That is a worthwhile topic for another day.
Hedley's Trout Farm