Government of Canada
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Evaluation of the National Aquatic Animal Health Program (NAAHP) at the Canadian Food Inspection Agency and the Department of Fisheries and Oceans

Action Plan

June 29, 2010

Table of Contents

Glossary of Acronyms

AAHC
Aquatic Animal Health Committee
AAHD
Aquatic Animal Health Division
APHIS
Animal and Plant Health Inspection Service
CBSA
Canadian Border Services Agency
CCFAM
Canadian Council of Fisheries and Aquaculture Ministers
CFIA
Canadian Food Inspection Agency
DFAIT
Department of Foreign Affair and International Trade
DFO
Department of Fisheries and Oceans
EU
European Union
FHPR
Fish Health Protection Regulations
FPT
Federal Provincial Territorial
FTE
Full time equivalent
HAA
Health of Animals Act
HAR
Health of Animals Regulations
I&T
Introduction and Transfer
IHN
Infectious haematopoietic necrosis
ISA
Infectious salmon anaemia
ISO
International Organization for Standardization
LIMS
Laboratory Information Management System
MOU
Memorandum of Understanding
MSX
Multinucleate Sphere Unknown
NAAHP
National Aquatic Animal Health Program
NAAHLS
National Aquatic Animal Health Laboratory System
NRL
National Reference Laboratories
OIE
World Organization for Animal Health
QA
Quality Assurance
QC
Quality Control
RMAF
Results-based Management and Accountability Framework
RMOC
Resource Management Oversight Committee
VHS
Viral Hemorrhagic Septicemia
WTO
World Trade Organization

Executive Summary

Introduction

The National Aquatic Animal Health Program (NAAHP) was introduced in 2005 in response to concerns about the introduction and spread of aquatic animal diseases, and international market access for Canadian aquatic animal and seafood exports.

The program is co-delivered by the Canadian Food Inspection Agency (CFIA), and Fisheries and Oceans Canada (DFO). Management coordination of the program is governed through a Memorandum of Understanding (MOU) between the CFIA and DFO.

The CFIA provides the overall program lead for NAAHP, and is responsible for disease monitoring and surveillance protocols and control measures for reportable diseases. DFO is responsible for diagnostic research and the provision of scientific advice, and delivery and oversight of the National Aquatic Animal Health Laboratory System (NAAHLS).

Under the terms of agreement for the funding of the program, an evaluation is required at this time. The following are the objectives of the evaluation:

  • Assessment of relevance and performance (effectiveness, economy and efficiency) of the NAAHP; and
  • Provision of recommendations for program improvements.

The evaluation methodologies included close to 50 in-depth telephone or in-person interviews as well as a review of program documents and relevant literature. The study also included a comparative review of the United States, Australia, and British Columbia aquatic animal health programs.

Key Conclusions

Relevance

International agreements and Canadian law require the federal government to lead the delivery of a national aquatic animal health program. As a member of the World Trade Organization (WTO) and the World Organization for Animal Health (OIE), the federal government is responsible for aquatic animal health issues affecting trade. As well, through the Health of Animals Act, the federal government has clear regulatory responsibilities for international trade in animals.

The CFIA is the government agency responsible for regulatory control of all imports and exports of food and animals, and DFO has expertise in aquatic animal science required for a laboratory system for the testing and diagnosis of reportable aquatic animal diseases.

The NAAHP is also consistent with recent federal priorities. The NAAHP will provide safeguards for the $4 billion fishery and aquaculture industry, largely situated in small, coastal and rural communities, complementing the 2009 Federal Budget commitment to small resource-dependent communities. As such, NAAHP is consistent with broad federal priorities and it is relevant for NAAHP to be administered jointly by CFIA and DFO.

Further, Canada is facing an increasing number of trade challenges to both farmed and wild aquatic resource exports, and several countries have placed trade embargoes on certain products (e.g. salmon products to Australia) due to health certification requirements.1 The National Aquatic Animal Health Program (NAAHP) will align Canada with international trade standards and provide a defined national structure with appropriate capacity to address the health of aquatic food animals.

Performance: Effectiveness

The CFIA has had difficulty recruiting scientific personnel with aquatic animal health expertise and there have been delays in amending the Health of Animals Regulations. As a result, the NAAHP has not been implemented as planned, and anticipated timelines for the achievement of program objectives have not been met. This is due to a variety of reasons, including difficulties recruiting scientific personnel with aquatic animal health expertise, and delays amending the Health of Animals Regulations. The CFIA component of the program lapsed a significant portion of its budget over 2005-2007, while the Aquatic Animal Health Division hired staff. Thus, more than 36 percent of the funding allocated to deliver the NAAHP over 2005-2007 was re-profiled to other CFIA priorities during this time.

The program has had less difficulty expending its funds since 2007, although a sizable amount of its original allocation continues to be transferred to other initiatives.

While DFO has also experienced some delays, they are much less severe. The NAAHLS and National Reference Laboratories are now operational and a number of diagnostic tests for priority disease have been validated. Several of DFO’s initiatives that have been delayed are due to the need for CFIA to clarify requirements and expectations.

As a result, limited progress has been achieved with respect to the activities and outputs outlined in the program’s logic model. Consequently, there has been limited progress made toward immediate, intermediate, and ultimate program outcomes. Nevertheless, there is no evidence to suggest that outputs and outcomes will not be achieved, albeit much later than originally anticipated. Therefore, while the program’s implementation plan is behind schedule, the program’s logic is sound.

Performance: Efficiency and Economy

Since the NAAHP is not yet fully implemented, there is limited ability to conclude that the most appropriate and efficient means are used to achieve outputs and outcomes. Nevertheless, given the necessary role of the CFIA and DFO in the design and delivery of the program and international commitments, there is no evidence that an alternative program approach would be more efficient.

The provinces, territories and industry have existing capabilities and infrastructure appropriate for supporting some of the program’s surveillance and disease diagnosis requirements. However, the extent to which collaboration with stakeholders will be possible has yet to be determined. Use of existing provincial, territorial, and industry capacity could reduce costs to the federal government

Finally, secondary research suggests that public spending on animal health management programs such as NAAHP provide a return on investment, and are a cost-effective way to prevent and control animal disease.

Performance: Performance Measurement Strategy

The NAAHP has not developed a program-level performance measurement strategy, and there is no evidence that the CFIA is collecting data against the performance indicators identified in the program’s Results-based Management and Accountability Framework (RMAF).

DFO has incorporated some key NAAHP outputs and outcomes, including diagnostic tools for disease identification, diagnostic laboratories, scientific research conducted and increased knowledge of aquatic animal diseases of concern to Canada in a sub-activity level Performance Measurement Framework for Sustainable Fisheries and Aquaculture. The DFO Laboratory Information Management System (LIMS) is expected to meet all of DFO’s operational and management requirements for information about disease testing and diagnosis.

Recommendations:

  1. A joint CFIA-DFO communications strategy should be developed for NAAHP to improve communications with the provinces and territories, industry and other stakeholders, and enhancements should be made to the program’s website to ensure that it is current and comprehensive.
  2. The program should make use of the CFIA's assessment of the surveillance and monitoring capacity of the provinces, territories and industry, and DFO should evaluate the diagnostic laboratory capacity of provinces, territories and other third party laboratories. Options for the future role of these groups as possible partners in the NAAHP should be jointly investigated by the CFIA and DFO.
  3. A performance measurement strategy should be developed for the NAAHP that is linked to the program’s Results-based Management Accountability Framework. Further in-depth examination of the extent to which NAAHP is achieving expected outcomes in the form of an evaluation should be undertaken in 2012 after the NAAHP is fully operational.

1.0 Introduction

The National Aquatic Animal Health Program (NAAHP) is a regulatory program for aquatic animal disease that is co-delivered by the Canadian Food Inspection Agency (CFIA) and Fisheries and Oceans Canada (DFO). Management coordination of the program is governed through a Memorandum of Understanding (MOU) between the CFIA and DFO.

The CFIA provides the overall program lead for the NAAHP and is responsible for disease monitoring and surveillance protocols and control measures for reportable diseases. DFO is responsible for diagnostic research and the provision of scientific advice, and delivery and oversight of the National Aquatic Animal Health Laboratory System (NAAHLS).

Under the terms of agreement for the funding of the program, an evaluation is required at this time. The following are the objectives of the evaluation:

  • assess relevance and performance (effectiveness, economy and efficiency) of the NAAHP; and
  • provide recommendations for program improvements.

The original evaluation requirements were identified in the Results-based Management and Accountability Framework (RMAF) for the NAAHP, which was developed in 2006. The Treasury Board Policy on Evaluation was recently revised (effective April 1, 2009), and the evaluation issues examined in this study were adjusted in light of the new policy requirements.

This evaluation covers the period from 2005, when the funding for the NAAHP was approved, to March 2010. The focus of the evaluation is on the implementation of the program, and the extent to which progress has been made in developing and delivering the program.

2.0 Profile

Standards for aquatic animal disease control, aquatic animal health and trade in aquatic animals are set by the World Organization for Animal Health (OIE), in support of the World Trade Organization (WTO) Agreement on the Application of Sanitary and Phytosanitary Measures. Canada, as a member of both organizations, must have measures in place that address these standards.

The NAAHP was announced in 2005 to respond to export trade challenges from other countries based on disease outbreaks, required regulatory controls to respond to disease and proper health certification of both farmed and wild harvested fisheries. The program consists of measures to prevent, control and/or eradicate aquatic animal diseases of concern in fish, molluscs, crustaceans and their carcasses.

The objectives of the NAAHP are the following:

  • ensuring secure seafood production and trade of aquatic animals that meet international standards;
  • protecting Canadian wild and farmed aquatic resources from serious infectious diseases; and
  • ensuring access to international markets on an ongoing basis.

The NAAHP derives its legislative authority from the Health of Animals Act (HAA), and is modelled after the terrestrial animal health program. Specifically, the NAAHP will provide similar disease coverage to aquatic animals to those that are currently in place for terrestrials under the HAA. Early studies concluded that the HAA was the best existing legislation for an aquatic animal health management program.2 Amendments will be made to regulations under the HAA to provide protection for wild and farmed aquatic animals against serious infectious diseases.

The program is co-delivered by the CFIA and DFO. The CFIA is the lead federal agency under the authority of the Health of Animals Act (HAA), and DFO is responsible for diagnostic research and the provision of scientific advice, and delivery and oversight of the National Aquatic Animal Health Laboratory System (NAAHLS). The CFIA is responsible for overall program development, required changes to the HAA legislative and regulatory framework, export health certification, import controls, domestic disease control, surveillance, and risk assessment.

Stakeholders and intermediaries include CFIA, DFO, and other federal government departments and agencies, provincial and territorial governments, Aboriginal communities, wild fishery, bait fishery, recreational fishery and aquaculture industries, as well as scientific and academic communities. Beneficiaries include Canadians at large, and more specifically First Nations, fishers, seafood producers, processors, distributors, retailers, exporters and importers as well as the aquarium industry.

The overall cost of implementing and delivering the NAAHP for the five-year period from 2005 to 2010 was set at $67,030,000. The CFIA’s share is $35,610,000, and DFO’s share is $31,420,000.

  • The CFIA received new funding of $32,130,000 for the five-year period, and $7,510,000 ongoing funding annually thereafter. The CFIA was required to provide $1,160,000 per year from existing resources beginning in year three to cover a reduction in new funding.
  • DFO received new funding of $26,920,000 for the first five years, and $3,980,000 in ongoing annual funding thereafter. DFO was also required to provide $1,500,000 per year from existing resources beginning in year three to cover a reduction in new funding.

NAAHP objectives are linked to the CFIA strategic outcomes of “…a safe and sustainable plant and animal resource base” and “consumer protection and market access based on the application of science and standards”3. The NAAHP also contributes to achieving the DFO strategic outcome of “…sustainable fisheries and aquaculture”4.

The CFIA Aquatic Animal Health Division (AAHD) is housed within the Animal Health Directorate. The director is responsible for overall management and coordination of the program within CFIA.

A CFIA-DFO interdepartmental steering committee provides strategic direction, planning, resource allocation, and monitoring of the program. An external advisory committee, the Aquatic Animal Health Committee (AAHC), with representatives from various stakeholder communities, provides advice on operational issues related to program design and implementation.

A federal, provincial, territorial advisory committee (CCFAM-CFIA FPT) composed of representatives of all provinces and territories responsible for fisheries and aquaculture provides advice related to CFIA programs impacting fisheries and aquaculture, including the NAAHP.

The CFIA has an executive-director level horizontal steering committee to manage NAAHP resource allocations within the Animal Health Directorate and a senior-manager level Resource Management Oversight Committee (RMOC) responsible for managing resources at the agency level. DFO has a parallel Departmental Management Committee responsible for DFO resource issues.

3.0 Scope of the Evaluation

This a joint evaluation conducted by the CFIA’s Evaluation Directorate on behalf of the Agency, and the Department of Fisheries and Oceans. The MOU requires that CFIA and DFO conduct regular reviews and evaluations of their NAAHP responsibilities, but may choose to partner or participate in the other’s evaluation upon invitation if timing and resources permit.

The evaluation assessed the CFIA’s and DFO’s activities in support of the NAAHP as they are outlined in the Treasury Board Submission.

4.0 Methodology

The evaluation involved 47 in-depth interviews with representatives from the CFIA (18 interviews), DFO (15 interviews) and stakeholder groups (14 interviews), including members of the National Aquatic Animal Health Committee. In addition, the evaluation included the review and analysis of a wide range of the CFIA and DFO internal files, documents and data and other relevant reports5 and an examination of the aquatic animal health programs in British Columbia (BC), the United States (U.S.), and Australia.

As per the April 2009 Treasury Board Policy on Evaluation, the issues examined pertain to the program’s relevance (that is, continued need for program, alignment with government priorities, alignment with federal roles and responsibilities) and performance or effectiveness (that is, achievement of expected outcomes); efficiency (that is, demonstration of efficiency); and economy (demonstration of economy). In addition, the adequacy of the NAAHP’s performance measurement system was examined as a performance-related issue.

Multiple lines of evidence were used to address all issues and questions, to provide credible findings on which to base conclusions and recommendations. A more detailed description of the evaluation issues and methodologies is found in Annex B.

5.0 Relevance

Key Findings:

The NAAHP is well aligned with the overall mission of the CFIA, which is “safeguarding food, animals and plants, which enhances the health and well-being of Canada’s people, environment and economy”6. The NAAHP also contributes to the DFO mandate to “develop and implement policies and programs in support of Canada’s scientific, ecological, social and economic interests in oceans and fresh waters”7 and the DFO Strategic Outcome of sustainable fisheries and aquaculture.

The federal role is required because the legislative authority for the NAAHP is provided by the Health of Animals Act, and the CFIA is responsible for its enforcement. Additionally, Canada is a signatory to the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement) of the World Trade Organization (WTO) and the scientific standards set for aquatic animal health management (the International Aquatic Animal Health Code or ‘the code’) by the World Organization for Animal Health (OIE). Canada’s current finfish health regulations, the Fish Health Protection Regulations - (FHPR), are inadequate for the purposes of an aquatic animal health program (the FHPR only cover salmonids), but also do not meet many of the standards for aquatic health protection established by the Aquatic Animal Health Code. This leaves Canada vulnerable to uncontrolled import products that have a risk of carrying diseases of concern.8

The 2005 Federal Budget formalized the Government of Canada’s commitment to the NAAHP by providing funds to DFO and the CFIA to “…protect aquatic animals from the harmful effects of diseases and to maintain the seafood industry’s competitiveness in international markets.”9 Further, the program is linked to the 2009 Budget commitment in support of small resource-dependent communities.10 By protecting the competitiveness of Canadian seafood exports and encouraging investment in seafood production, the NAAHP will provide safeguards for the $4 billion fishery and aquaculture industry which is primarily situated in small, coastal and rural communities.

The program addresses industry needs for access to external markets for aquatic animal and seafood products. Increasingly stringent international standards are driving seafood importing nations to require Canada to certify the health or disease status of live aquatic animals and their products. Currently, Canada cannot prove that exports of farmed and wild aquatic animals are free from diseases of concern, putting the Canadian aquaculture and seafood industries at risk of market closures in other countries.11 Until the regulatory amendments are finalized and the NAAHP is operational, Canada cannot meet international standards, and has limited ability to prevent the import of live fish and seafood products of concern.

The NAAHP also supports the maintenance of fisheries and seafood production related employment in many of Canada’s small communities. According to DFO statistics, approximately 90 percent of the 80,000 jobs associated with wild fisheries, aquaculture and seafood processing are in rural, coastal or remote communities located on the Atlantic and Pacific coasts.12 Several DFO interviewees also noted the importance of wild fisheries and aquaculture to the success and survival of Canada’s coastal communities. Many of these communities rely on these fisheries for employment and income. Loss of market access could have a devastating impact on communities that are dependent on the fisheries and aquaculture industry.

The NAAHP is also needed to control the spread of regulated diseases within Canada that result in economic losses. The current list of proposed diseases to be covered by the program includes both OIE required as well as additional diseases of potential concern to Canada. The diseases chosen for control cause a high rate of mortality in aquatic populations or put surviving populations at risk of poor reproduction and decreasing quality.13 The program received advice from DFO, provincial governments, and industry stakeholders on the development of the lists for aquatic animals. Some examples of these diseases are included in Table 1 below.

Table 1: Sample of Disease Listing
Reportable and Immediately Notifiable Diseases (Non-OIE diseases) OIE Annually Reportable Diseases
abalone viral mortality (abalone mortality virus) aber disease (Marteilia refringens)
bacterial kidney disease (Renibacterium salmoninarum) bonamiosis (Bonamia exitiosa)
brown ring disease (Vibrio tapetis) bonamiosis (Bonamia ostreae)
ceratomyxosis (Ceratomyxa shasta) crayfish plague (Aphanomyces astaci)
channel catfish virus disease (channel catfish virus) dermo disease (Perkinsus marinus)
Denman Island disease (Mikrocytos mackini) epizootic ulcerative syndrome (Aphanomyces invadans)
enteric red mouth disease (Yersinia ruckeri) gyrodactylosis (Gyrodactylus salaris)
enteric septicaemia of catfish (Edwardsiella ictaluri) infectious haematopoietic necrosis
furunculosis (Aeromonas salmonicida) infectious hypodermal and haematopoietic necrosis
hepatopancreatic parvovirus disease (hepatopancreatic parvovirus) infectious myonecrosis (infectious myonecrosis virus)
marteiliodiosis (Marteiliodes chungmuensis) perkinsosis (Perkinsus olseni)
mikrocytosis (Mikrocytos roughleyi) taura syndrome (Taura syndrome virus)
Mourilyan virus disease (Mourilyan virus) viral haemorrhagic septicaemia (viral haemorrhagic septicaemia virus)
MSX disease (Haplosporidium nelsoni) white spot disease (white spot syndrome virus)
necrotizing hepatopancreatitis white tail disease (white tail virus)

Conclusions:

  • The NAAHP is consistent with the federal government’s commitment to resource-dependent communities and the protection of Canada’s aquatic resources. The program is well aligned with the mandates, objectives, and capabilities of CFIA and DFO.
  • The NAAHP addresses industry needs for market access as, without a program such as NAAHP, Canada’s aquatic animal and seafood products exports, valued in recent years at over $4 billion annually, are at risk from emerging international regulations on disease transmission that require certification that products are free of serious diseases.
  • International agreements and Canadian law require the federal government to lead the delivery of a national aquatic animal health program. As a member of the WTO and the OIE, the federal government is responsible for aquatic animal health issues affecting trade. As well, through the Health of Animals Act, the CFIA acts on behalf of the federal government in meeting regulatory responsibilities for international trade in animals.

Recommendation:

None.

6.0 Performance

6.1 Effectiveness

Key Findings:

Largely due to difficulties in recruiting experienced staff, the implementation of the NAAHP by the CFIA has suffered extensive delays. As a result, many of the expected outputs are still under development or have yet to occur. Table 2 below, provides an overview of the status of both the CFIA and DFO outputs as they are identified in the program logic model.14

Table 2 – Achievement of NAAHP outputs
CFIA Outputs Status
Establish priorities started and on-going
Strategic plan started and on-going
Establish committees started and on-going
Establish needs complete
Establish expectations complete
Establish standards complete
Database complete
Policies and procedures complete
Planning complete
Manuals complete
Risk analysis complete
Sampling complete
Inspection and certification complete
Revision to regulations complete
Communication strategy complete
Awareness programs complete
Staff training complete
Standards complete
Negotiations complete
Bilateral/trilateral committees complete
Policy complete
Ministerial declarations X

 

DFO Outputs Status
Laboratory system complete
LIMS complete
Research complete
Technology development complete
Sampling complete
Amendment/creation of new regulations complete
Staff training programs complete
Technical advice complete
Regulatory repeal complete
Scientific research complete
Standards X

Legend:

started and on-going = complete

complete = started and on-going

X = has not begun

The CFIA component of the program lapsed a significant portion of its budget over 2005-2007 while the Aquatic Animal Health Division staffed up. Thus, over 36 percent of the funding allocated to deliver the NAAHP over 2005-2007 was re-profiled to other CFIA priorities during this time15.

Table 3: Comparison Between Year-End Allocations to NAAHP and Funds Expended by CFIA16
Year (A) TB Allocation (000’s) (B) Year-End Allocation (000’s) (C) Expenditures (000’s) % Lapsed ( C-B)/(B) *100 % of TB Allocation Expended on NAAHP (A-C/A*100) - 100  % Transferred to Other Priorities (A-B)/(A)*100 
2005-2006 $6,930 $6,778 $1,284 81% 19% 2%
2006-2007 $6,150 $2,816 $2,505 11% 41% 54%
2007-2008 $6,350 $3,931 $3,130 20% 49% 38%
2008-2009 $6,350 $4,504 $3,913 13% 62% 29%
2005-2009 (4 years) $25,780 $18,030 $10,831 40% 42% 30%

Further, the NAAHP’s budget is levelling off just as the program is becoming operational. Based on the program’s original timelines and budget allocation, the NAAHP’s funding was set to decrease to ‘maintenance level’ starting in 2007-2008.17 By this time, it was expected that the program would be operational and staffed appropriately. However, NAAHP is operating approximately two years behind its original schedule. The program’s funding approached forecasted levels in 2008-2009, suggesting that the CFIA is responding to the program’s increased resource demands.

Progress has been hindered by staff shortages and delays. There are very few veterinarians with aquatic animal experience, causing delays in staffing key positions within the Program. Staff shortages caused delays in the pace at which regulatory amendments and other implementation activities could move forward. In response, in early 2009 the NAAHP proposed borrowing several CFIA Operations Branch staff to alleviate the shortfall and expedite those components that have experienced delays.18

Staffing delays during the early years of the program have caused a cascade effect in the progression of other NAAHP objectives. For example, the policies and procedures needed by the CFIA’s Operations Branch to deliver their part of the program are now being developed by the Aquatic Animal Health Division19, and the initial amendments to the Health of Animals Regulations and Reportable Disease Regulations have recently begun.20 The regulatory amendments are required to provide authority to the CFIA for mandatory reporting of disease, import control, emergency response and domestic disease control measures. But until the CFIA promulgates regulatory changes under the Health of Animals Act, DFO retains a regulatory responsibility for delivering the Fish Health Protection Regulations (FHPR). This responsibility has put dual pressure on the laboratories to deliver both traditional FHPR and NAAHP diagnostic work at the same time. When the NAAHP regulatory and policy structures are in place to replace the functions of the FHPR, the FHPR can be repealed and the traditional FHPR resources will be freed up to contribute to furthering the goals of the NAAHP.

The delays in program implementation make it difficult to determine the extent to which all intended outcomes will occur. Further, according to the program’s most recent business plan21 the CFIA now expects full program implementation in 2012-2013, a full seven years after NAAHP was created.

The NAAHP’s achievements thus far have assisted the CFIA in its negotiations with other countries for access to foreign markets where previously it has been denied. Lobster to Chile and Colombia and salmonid eggs to Ireland, Chile, and Iceland are now permitted.22 23 The program has also facilitated access to new markets for Canadian products (such as the European Union for ornamental animals).

DFO has spent more than 70 percent of allocated funds on the NAAHP. While DFO has also faced delays, they have been less significant than those experienced by the CFIA. The NAAHLS and National Reference Laboratories are now operational and a number of diagnostic tests for priority disease have been validated. DFO interviewees noted that some initiatives have been delayed due to the need for CFIA to clarify requirements and expectations. For example and as stated previously, DFO cannot amend its Fish Health Protection Regulations until the Health of Animals Regulations are revised.

Table 4: Comparison Between Funding Allocated to NAAHP and Funds Expended by DFO
Year TB Allocation*(000’s) Expenditures(000’s) % of TB Allocation Expended on NAAHP
2005-2006 $7,010 $2,928 41%
2006-2007 $7,970 $5,858 73%
2007-2008 $5,480 $5,057 92%
2008-2009 $5,480 $5,208 95%
2005-2009 (4 years) $ 25, 940 $19, 050 73%

*Allocations for Years 3 and 4 include $1,500,000 from DFO internal resources.

The AAHC and CCFAM-CFIA FPT committees have provided an opportunity for CFIA staff to meet with the aquatic industry. Agency interviewees claimed that they had a better understanding of Canadian aquaculture and wild fish industries as a result of their participation in the two committees.

Additionally, presentations by NAAHP and participation in the AAHC have contributed to increased awareness in the wild fish sector about aquatic animal diseases. However, based on interviews with AAHC members, and on NAAHP briefing reports to senior management, the credibility of the program among stakeholders and stakeholder support has suffered due to the delays, and the level of stakeholder participation and attendance at meetings has declined. External stakeholders are beginning to question the Agency’s commitment to the program.

At DFO, the scientific expertise in aquatic animal diseases already present provided the foundation for the development of the NAAHLS. In addition, the DFO high-level senior management support for the initiative and the maintenance of funding in the face of resource challenges facilitated progress. The need to respond to aquatic animal disease outbreaks such as the Viral Hemorrhagic Septicemia (VHS) outbreak in the Great Lakes has drawn scarce resources away from program development and contributed to delays. DFO interviewees noted that progress has also been hindered by communication challenges, and the need for clarity on requirements from the CFIA with respect to testing and surveillance.

DFO interviewees and external stakeholders expressed concern regarding the scope of NAAHP, which focuses on diseases rather than the full range of aquatic animal health issues. The slow progress and other uncertainties associated with NAAHP have resulted in reduced stakeholder engagement and support. There have been several cross-country tours involving provinces, industry associations and other stakeholders. However, Aboriginal groups are concerned about lack of involvement24.

There is no overall communications strategy for NAAHP. However, a strategy has been developed for the upcoming changes to the HAA Regulations, and another is being planned for changes to the Reportable Diseases Regulations. The NAAHP website has been reported by CFIA and DFO interviewees as inadequate, as it is not up to date and contains little current information on program implementation.

Some AAHC members interviewed reported that the committee has been ineffective as an advisory vehicle. For example, some AAHC members noted that full meeting minutes were not provided and that comments they had made were not captured and therefore could not be used as a source of advice. Some provincial and territorial stakeholders and industry members also questioned the efficacy of the AAHC as an advisory vehicle.

Conclusions:

  • The NAAHP has not been implemented as planned, and anticipated timelines for the achievement of program objectives have not been met. Within the CFIA, shortages of veterinary and scientific personnel with aquatic animal health expertise contributed to delays. These personnel were not available within the CFIA, or even within the federal government. Therefore, the time required to hire and familiarize the new staff with the Agency caused further delays in program implementation.
  • The CFIA will be largely reliant on DFO for disease testing and wild specimen collection under the NAAHP. The Agency is not yet in a position to articulate their long-term testing requirements to DFO given the delays in program implementation. This limits the ability of DFO to plan for their activities in support of the NAAHP.
  • The time required to amend regulations was a major barrier to full implementation within the CFIA and DFO. As a result, limited progress has been achieved with respect to the activities and outputs outlined in the program’s logic model. Consequently, even more limited progress has been made toward immediate, intermediate and ultimate program outcomes. Nevertheless, there is no evidence to suggest that outputs and outcomes will not be achieved, albeit much later than originally anticipated. Therefore, while the program’s implementation plan is behind schedule, the program’s logic appears sound.
  • Industry and other stakeholders are slowly becoming more aware of the role of NAAHP in managing aquatic animal diseases but claim that the program has had little impact on their activities thus far. Several key informants voiced their dissatisfaction with the slow progress of the NAAHP.
  • From 2005-2009, DFO spent approximately 73 percent of allocated funds on NAAHP while the CFIA spent approximately 42 percent of allocated funds on the program.
  • The AAHC is not viewed as an effective advisory vehicle.

Recommendations:

1. A joint CFIA-DFO communications strategy should be developed for NAAHP to improve communications with the provinces and territories, industry and other stakeholders, and enhancements should be made to the program’s website to ensure that it is current and comprehensive

6.2 Efficiency and Economy

Key Findings:

The NAAHP has been designed to take advantage of CFIA’s regulatory capabilities, and of DFO’s knowledge of aquatic animal science. The program is designed to build on existing program infrastructure and operational networks that have been developed for the Terrestrial Animal Health Program at the CFIA.

An assessment conducted in 2008-2009 indicates that the provinces, territories, and industry have existing capabilities and infrastructure appropriate for supporting some of the program’s surveillance and disease diagnosis requirements.25 To minimize duplication and overlap, interviewees noted that the NAAHP needs to take advantage of these capabilities. The NAAHP Business Case states that the program should consult with provinces and industry to confirm roles and responsibilities for the purposes of aquaculture and aquatic surveillance, and other testing requirements.26 Because of delays in program design and implementation, relationships with external stakeholders have not yet been clearly defined and the program has yet to determine the extent to which it can or will work collaboratively with the provinces, territories and industry.27 Similar to the NAAHP’s approach for provincial and territorial involvement, the Australian aquatic animal health program co-ordinated delivery of the national program by building upon the existing capacity within the smaller territorial programs.

There is limited opportunity for program efficiency as most program elements cannot be reduced due to international obligations to the World Trade Organization Agreement on Sanitary and Phytosanitary Measures (SPS Measures).28 The SPS Agreement names the World Organization for Animal Health as the relevant organization for animal health, and the Aquatic Animal Health Code, or Aquatic Code, is used to assure the sanitary safety of international trade in aquatic animals and their products.29 The Aquatic Code has been used by the NAAHP as a model for programming efforts.

The CFIA component of the program has yet to finalize its operational requirements, making it difficult to identify the full extent of resource requirements to deliver the program and determine if planned resource levels are sufficient. There are several reasons to expect resource requirements to increase in the future, in particular, requests for export permits are expected to increase; resources will be needed for mandatory reporting and disease response; and resource levels will need to increase for import controls.

All of these factors are outside the sphere of control of the program. In addition, future DFO expenditures to meet CFIA requirements for sampling and testing are unknown.

Finally, several studies of aquatic animal health programs in other countries suggest that public spending on animal health management provides a return on investment.30 Specifically in the case of the NAAHP, a detailed cost-benefit analysis of the program concluded that the costs are relatively small compared to the potential harm to the industry if it were to be seriously affected by disease introduction or spread.31 For example, an outbreak of Viral Hemorrhagic Septicemia or VHS in the late 1990s caused massive die-off among pilchards and herring in British Columbia and was estimated to cost the industry $20 million.32

Conclusions:

  • The NAAHP has been designed to take advantage of the CFIA’s regulatory capabilities, and of DFO’s knowledge of aquatic animal science as the most appropriate and efficient means of achieving intended outcomes.
  • The overall program design uses the strengths of both the CFIA and DFO: the CFIA has a regulatory mandate and experience based on the terrestrial animal program, and DFO has diagnostic science infrastructure.
  • Given the necessary role of the CFIA and DFO in the design and delivery of the program, and international obligations to the WTO, there is no evidence to indicate that an alternative organizational approach would be more efficient.
  • Secondary research suggests that public spending on animal health management programs such as the NAAHP provide a return on investment, and are a cost-effective way to prevent and control animal disease.
  • The provinces, territories and industry have existing capabilities and infrastructure appropriate for supporting some of the program’s surveillance and disease diagnosis requirements, but the NAAHP has not yet determined the extent to which it can use these resources. Use of existing provincial, territorial, and industry capacity could have an impact on costs to the federal government.

Recommendation:

2. The program should make use of the CFIA's assessment of the surveillance and monitoring capacity of the provinces, territories and industry, and DFO should evaluate the diagnostic laboratory capacity of provinces, territories and other third party laboratories. Options for the future role of these groups as possible partners in the NAAHP should be jointly investigated by the CFIA and DFO.

6.3 Performance Measurement Strategy

Key Findings:

According to interviewees, the development of a performance measurement strategy in CFIA and DFO to provide information for oversight of resource allocation and the achievement of NAAHP outputs and outcomes is at an early stage, due to delays in program development.

While the CFIA has introduced horizontal reporting to provide data on resources expenditures, including financial expenditures and full-time equivalent staff positions (FTEs), there is no evidence that the Agency is collecting data against the performance indicators identified in the program’s Results-based Management and Accountability Framework (RMAF). The lack of performance information has not affected this evaluation study due to delays in program implementation. However, performance information will be essential to support program management, future evaluations of the NAAHP, and future funding requests to federal government central agencies.

DFO has incorporated some key NAAHP outputs and outcomes in a sub-activity level Performance Measurement Framework for Sustainable Fisheries and Aquaculture. When completed, the Laboratory Information Management System or LIMS is expected to meet all NAAHP operational and management needs for information. In some cases, clarification of CFIA information requirements is required so DFO can ensure that the information is available.

The BC Fish Health Program annual report provides an example of the level of performance-related information that is provided by another program and could thus be examined by the NAAHP as it develops its performance measurement system. The report includes a summary of program rational, delivery approach and summary data of monitoring, surveillance, sampling and test results. The program has also produced a more detailed report covering several years examining trends in fish health and an Annual Summary of Diseases by species, geographic area and summaries of fish mortality by cause. Some of the data is provided by the aquaculture industry. This is a practice that could be used to support the NAAHP’s disease monitoring activities.

Conclusions:

  • The CFIA has not developed a performance measurement strategy for the NAAHP, limiting the ability of the Program to demonstrate achievement of objectives in the future and on-going program performance. Isolated instances of program monitoring do exist, but are not sufficient for the purposes of on-going performance management and decision-making. DFO is including some key NAAHP outputs and outcomes, including diagnostic tools for diseases, identification, diagnostic laboratories and scientific research conducted in a sub-activity level Performance Measurement Framework for Sustainable Fisheries and Aquaculture.
  • The DFO LIMS is expected to meet all DFO operational and management requirements for information about disease testing and diagnosis.

Recommendations:

3. A performance measurement strategy33 should be developed for the NAAHP that is linked to the program’s Results-based Management Accountability Framework. Further in-depth examination of the extent to which NAAHP is achieving expected outcomes in the form of an evaluation should be undertaken in 2012 after the NAAHP is fully operational.

7.0 Recommendations

  1. A joint CFIA-DFO communications strategy should be developed for the NAAHP to improve communications with the provinces and territories, industry and other stakeholders, and enhancements should be made to the program’s website to ensure that it is current and comprehensive.
  2. The program should make use of the CFIA's assessment of the surveillance and monitoring capacity of the provinces, territories and industry, and DFO should evaluate the diagnostic laboratory capacity of provinces, territories and other third party laboratories. Options for the future role of these groups as possible partners in the NAAHP should be jointly investigated by CFIA and DFO.
  3. A performance measurement strategy should be developed for the NAAHP that is linked to the program’s Results-based Management Accountability Framework. Further in-depth examination of the extent to which the NAAHP is achieving expected outcomes in the form of an evaluation should be undertaken in 2012 after the NAAHP is fully operational.

1 Canadian Food Inspection Agency. National Aquatic Animal Health Program – Regulatory Amendments Update. Presentation to the Interbranch ED Forum. September 25, 2009.

2 NAAHP Situation Analysis for VPs Policy and Programs; Operations and FAIT Branches, December 28, 2008 and January 8, 2009.

3 Canadian Food Inspection Agency, Report on Plans and Priorities 2009–2010

4 Fisheries and Oceans Canada, Report on Plans and Priorities 2009–2010

5 See Annex A for a list of documents reviewed.

6 CFIA website CFIA Agency Overview – Science and regulation … working together for Canadians

7 Department of Fisheries and Oceans, Report on Plans and Priorities 2009-2010

8 Canada must meet international trade standards when it restricts importation of any products. To control import of aquatic animals, Canada must have information on the disease status of its own aquatic populations, and must demonstrate that a reasonable risk exists from imported products. The NAAHP will provide a framework whereby Canada can collect this type of information.

9 Government of Canada, 2005 Federal Budget. http://www.fin.gc.ca/budget05/pdf/bp2005e.pdf

10 Government of Canada, Canada’s Economic Action Plan – Budget 2009. http://www.budget.gc.ca/2009/pdf/budget-planbugetaire-eng.pdf

11 Regulatory Impact Analysis Statement - Regulations Amending the Health of Animals Regulations. Canada Gazette Part 1. Vol. 143, No. 51. Available online at: http://www.gazette.gc.ca/rp-pr/p1/2009/2009-12-19/html/reg1-eng.html

12 Canadian Fisheries Statistics 2006. Fisheries and Oceans Canada, Economic Analysis and Statistics. Ottawa: 2006.

13 Regulatory Impact Analysis Statement - Regulations Amending the Health of Animals Regulations. Canada Gazette Part 1. Vol. 143, No. 51. Available online at: http://www.gazette.gc.ca/rp-pr/p1/2009/2009-12-19/html/reg1-eng.html

14 status as of December 2009

15 It is common practice within the CFIA to re-allocate funds to priority issues. The Agency faced a series of crises over the course of the NAAHP’s development such as the Listeriosis outbreak in 2008, and the 2007 Avian Influenza outbreak in Saskatchewan.

16 Documents reveal that it was intended that the CFIA was to use internal resources to supplement a $1.16M shortfall in existing reference levels in 2007-08 and ongoing. These funds were never transferred to the NAAHP fund and therefore we cannot confirm if additional funding was made available for NAAHP.

17 Situation Analysis for VPs Policy & Programs; Operations; & FAIT Branches, January 8th, 2009

18 Ibid

19 Ibid

20 The program was able to successfully present the Regulatory Impact Analysis Statement (RIAS) for the proposed regulatory amendments in the Canada Gazette in December 2009.

21 Presentation to RMOC, CFIA NAAHP Five Year Business Plan, April 21, 2009.

22 Presentation to AAHC. Aquatic Animal Health: Export Program. May 2009 Update.

23 Aquatic Animal Health Division, personal correspondence. November 5, 2009.

24 Communications Strategy Changes to the Health of Animals Regulations, October 15, 2009

25 National Stakeholder Survey Report. NAAHP Workshop. Prepared by the National Aquatic Animal Health Program. February 23 & 24, 2010. Ottawa, ON

26 A Business Case in Support of a National Aquatic Animal Health Program, March 2002,by the Canadian Aquaculture Industry Alliance and the Office of Sustainable Aquaculture, Department of Fisheries and Oceans

27 The use of third parties for export certification requires negotiation with trading partners

28 The World Trade Organization. http://www.wto.org/english/thewto_e/ coher_e/wto_oie_e.htm

29 The Aquatic Code provides details of health measures to be used by the veterinary or other competent authorities of importing and exporting countries so that the transfer of pathogenic agents for animals or humans is minimized but unjustified sanitary barriers are avoided. Many countries are increasingly relying on this Code with respect to health risks and trade in aquatic animals

30 See: Moran, D and Abdulai, Fofana (2007) and Tisdell, C.A., Harrison, S.R. et al. (1999).

31 A Business Case in Support of a National Aquatic Animal Health Program, March 2002, by the Canadian Aquaculture Industry Alliance and the Office of Sustainable Aquaculture, Department of Fisheries and Oceans

32 Hastings T, Olivier G, Cusack R, Bricknell I, Nylund Å, Binde M, et al. 1999. Infectious salmon anaemia. Bulletin of the European Association of Fish Pathologists.19:286-8.

33 A performance measurement strategy is a results-based management tool that indicates the selection, development and ongoing use of performance measures for program management and decision making. Source: Treasury Board Secretariat, Centre of Excellence for Evaluation/ (2009) Guide for the Development of Performance Measurement Strategies and for Ensuring that they Effectively Support Evaluation. Ottawa.