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 consideration (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.

David Hedley
Hedley's Trout Farm