Thank you very much. It's a pleasure to be with you this evening.

I'm pleased to provide comments on behalf of the Canadian Meat Council, which is the voice of Canada's federally inspected meat industry, representing the entire value chain of red meat production and distribution in Canada, including all beef and pork sold internationally. We are the largest component of Canada's food-processing sector, with annual sales surpassing $32 billion, exports of $9.5 billion and a workforce of almost 70,000 people nationwide.

We applaud the spirit and intent of Bill C-5 as it pertains to the removal of interprovincial trade barriers. However, Bill C-5 purports to recognize provincially inspected meat-processing facilities as equivalent to federally inspected facilities, when they are not. We are concerned that the legislation in its current form would harm the meat-processing sector by limiting market access, affecting consumer confidence and, more broadly, introducing greater food risk safety and exposing the federal government to liability.

We recommend that the regulations intended to accompany this framework either exclude red meat interprovincial trade or ensure that provincially inspected facilities meet equivalent food safety standards as federally licensed establishments.

To provide a little bit of context, I would like to briefly describe Canada's meat inspection system. It's not something everyone knows. There are two levels of inspection.

The first is the provincial inspection. Provincially licensed abattoirs can only sell meat within a province. Provincially inspected facilities tend to be smaller and often serve local areas or specialty markets. Provincially inspected meat only accounts for 5% of Canada's red meat supply. Every province has different legislation, and inspection oversight varies from province to province.

By contrast, only facilities that are federally licensed can export meat to other provinces and countries. Federally licensed facilities process 95% of the total volume, meaning that most of the meat processed in Canada can be traded interprovincially right now. Federal facilities are usually larger, designed for higher volumes, but there are also small and medium-sized federal facilities that supply local product.

Just to reiterate, the lion's share of meat processed in Canada currently is traded interprovincially. While Bill C-5 purports to unlock the last 5%, we have concerns with the proposed wording of proposed section 8, which deems provincial requirements as equivalent to federal requirements.

The first and chief area of concern is food safety. A 2022 report commissioned by the Canadian Agri-Food Policy Institute found sharp variances between provincial and federal standards and inspections. In 2017, the World Organization for Animal Health evaluated Canada's inspection system and also noted the same variability. Pathogens such as E. coli, salmonella and listeria have different levels of protection in provincial plants, which is a major risk to consumers.

The federal government could expose itself and the industry to legal liability in the event of a food safety incident traced to a provincially inspected facility that doesn't have the same level of food safety standards. The legal implications of deemed equivalency would increase liability for government and industry.

In addition, there's also the control of foreign animal disease within provincial plants, which varies and could contribute to the spread of foreign animal disease or to a public health risk for consumption of products coming from sick animals.

The second risk that I want to mention is to our international trade relationships.

Canada's federal food inspection system is based on international standards, and it is among the top five inspection systems in the world. This is one of the key reasons why Canadian products are highly sought after. The federal inspection system was developed and has been evolving within the context of the international trading system, while the provincial system has not needed to.

There are many instances of this. By way of illustration, I will describe just one example. Countries that wish to import Canadian red meat will come to Canada and audit pre-selected facilities, thereby recognizing the whole of Canada as approved. This is called systems-wide approval. We jeopardize the systems approval model by deeming provincial inspection systems as equivalent to federal.

The federal government, particularly the federal regulating body—the Canadian Food Inspection Agency—is aware of the risks facing industry in a multi-tiered inspection regime. It has worked with CMC and other stakeholders to remove interprovincial trade barriers without elevating the concerns of food safety, international relationships and sector-wide competitiveness.

In conclusion, we support the spirit and intent of Bill C-5, which is to increase trade within Canada and to make goods and services more accessible to Canadians, and we reiterate that, for red meat, we have interprovincial trade for 95% of the supply. If the federal government wishes to go further, this must be done in a way that recognizes the integrity of Canada's federally inspected meat-processing system to protect Canadians and enhance the sector overall. A regulatory approach that ensures provincial establishments meet federal standards would be most practical for provinces that already have near-federal standards or inspections.