Final Report of an Audit Conducted In Argentina September 9th, through September 25th, 2013
Evaluating the Food Safety Systems Governing the Production of Beef And Poultry Meat Products Intended for Export to Canada

This report was updated on April 21, 2017. For specific details, please see the Supplementary Response in the following sections:

Abbreviations and Special Terms Used In the Report

APHIS
Animal and Plant Health Inspection Service – United States Department of Agriculture
CCA
Central Competent Authority: SENASA
CCP
Critical Control Point
CFIA
Canadian Food Inspection Agency
BSE
Bovine Spongiform Encephalopathy
E. coli
Escherichia coli
FMD
Foot and Mouth Disease
FSIS
Food Safety and Inspection Service – United States Department of Agriculture
GMP
Good Manufacturing Practices
HACCP
Hazard Analysis and Critical Control Point
OIE
World Organization for Animal Health
MOP
Meat Hygiene Manual of Procedures
RTE
Ready-to-Eat
Salmonella
Salmonella spp.
SENASA
National Service for Animal Health and Agro-Food Quality (Servicio Nacional de Sanidad y Calidad Agroalimentario)
SRM
Specified Risk Material
SSOP
Sanitation Standard Operating Procedures
VIC
Veterinarian in Charge

Executive Summary

This report describes the outcome of an on-site audit of Argentina's poultry and beef inspection system that was conducted by the Canadian Food Inspection Agency (CFIA) from September 9 to 25, 2013.

This audit had three objectives:

  1. To conduct a maintenance audit of the beef inspection system for the beef products that are currently allowed to be exported into Canada. The goal was to verify that Argentina continues to maintain a food safety system for beef that is equivalent to that of Canada with the capacity to produce products that are safe, unadulterated, and properly labelled in accordance with the Canadian meat inspection system. From January 1 to December 31, 2012, Argentina exported 815,167 kilograms of processed beef products to Canada.
  2. To evaluate the programs and controls to determine if raw beef can be exported to Canada from the geographical regions of Argentina that the CFIA has determined to be free of Food and Mouth Disease (FMD) with and without vaccination.
  3. To conduct an initial review of the poultry inspection system to assess its equivalence with the Canadian poultry inspection system with the intention to allow the export of poultry to Canada from Argentina.

Overall, the audit of the Central Competent Authority (CAA) indicated an effective organizational structure, facilities, equipment, transportation, communication, personnel, and training of the competent authority, to support the objectives of meat and meat product inspection and certification programs for export to Canada.

However, the following issues need to be addressed:

  1. Beef inspection: not all the requirements of Chapter 4, Annex O of the CFIA Meat Hygiene Manual of Procedures (MOP) were being followed in all establishments. The Policy described in Annex O or equivalent must be implemented in order to allow the export of raw beef to Canada. The CFIA auditor determined that SENASA is not routinely incising the lateral retropharyngeal lymph node as required. SENASA followed up during the audit to remind field staff of this requirement. Beef grading was not evaluated during this audit.
  2. Poultry Inspection: a major difference was identified during the audit related to the trimming of partially condemned portions. In Canada, all inedible portions are removed prior to the approved carcasses leaving the evisceration room, while in Argentina, carcasses with minor condemnable portions are allowed to leave the evisceration floor and pass into the chilling system where these portions are then removed and discarded. The CFIA desk review had already identified significant differences between the Argentina's and Canada's poultry grading programs, consequently, CFIA concluded that Argentina's poultry grading program is not equivalent, and therefore export of Argentinian poultry with a grade designation cannot be allowed. However, Canada does allow the imports of ungraded poultry if all other requirements are met. This program was not reviewed as part of the on-site audit. Similarly, product standards for poultry mechanically separated meat differ between Argentina and Canada, so companies that intend to export this product will need to meet the CFIA standards. Finally, control of evisceration may need to be standardized through all poultry establishment to ensure that contamination is effectively controlled in all poultry plants.
  3. Compliance and Enforcement Issues: Although the CCA maintains the legal authority and the responsibility to enforce all applicable laws and regulations governing Argentina and third country requirements, the auditor found that these requirements were not consistently applied throughout the system. As such, oversight of the implementation of effective sanitation and establishment operations will need further improvement.

Following the review of the action plans provided by SENASA, Argentina's beef inspection system for slaughter, cutting and processing was determined to meet Canada's requirements and in addition to cooked boneless beef, raw fresh/frozen boneless beef is now approved for export to Canada.

However, based on audit observations and review of subsequent action plans from SENASA, Argentina's Poultry inspection system cannot be approved. See "Supplementary response" below-

Supplementary response based on the information received on April 15, 2016

Following the review of the action plans provided by SENASA, it was determined that Argentina's poultry meat inspection system for slaughtering, cutting, and processing meets Canadian requirements: in addition to cooked boneless chicken; fresh/frozen raw boneless chicken is now approved for export to Canada. However, the import of poultry feet is not allowed because the Canadian requirements for this product are not met.

Documents reviewed by CFIA confirm there are major differences between the Argentina and the Canadian grading poultry system. The CFIA had concluded that the poultry grading program in Argentina is not equivalent to Canada so the CFIA maintains the conclusion that the poultry grading program in Argentina is not equivalent. The import of poultry from Argentina cannot be authorized with a grade designation. Canada allows import of poultry without designation when all other requirements are met.

For mechanically separated poultry meat, the standards in Argentina and Canada are different, so the establishments that intend to export these products must meet Canadian standards.

1. Introduction

The Canadian Food Inspection Agency (CFIA) conducted an audit of Argentina's beef and poultry food safety inspection system from September 9 through 25, 2013.

The audit began with an opening meeting held in Buenos Aires with the participation of representatives from the Central Competent Authority (CCA) – Servicio Nacional de Sanidad y Calidad Agroalimentaria, SENASA, the CFIA auditor, and representatives from the Canadian Embassy in Argentina and the Government of Argentina.

The CCA provided detailed information on various subjects of interest to the CFIA which included the following:

  • (1) Overview of SENASA structure and general information on Argentina
  • (2) Inspection of poultry, egg products and minor species
  • (3) Inspection of beef slaughter and processing
  • (4) Eradication plan for FMD
  • (5) Animal Health controls for poultry
  • (6) Export certification and
  • (7) Information systems.

2. Audit Objective, Scope, and Methodology

This was an initial audit of the poultry inspection system and an ongoing equivalence verification audit of the beef meat inspection system with special emphasis on:

  1. Inspection and certification of meat and meat products for export to Canada
  2. Inspection controls in Argentinian slaughter and processing establishments eligible to or willing to export meat and poultry products to Canada. These included following specific elements:
    1. E. coli O157:H7 testing and control measures in raw beef manufacturing facilities
    2. Listeria testing and control measures in Ready to Eat (RTE) meat producing facilities
    3. Abattoir programs related to the suitability of animals presented for slaughter (residue and disease status), humane handling, and the control of evisceration and dressing processes in slaughter establishments.
    4. Food Safety Enhancement Program requirements, e.g., HACCP plans and prerequisite programs
  3. Government oversight.

The CFIA auditor was accompanied throughout the entire audit by representatives from the CCA and from the regional and local inspection offices. Program effectiveness determinations focused on government controls and oversight within five areas of risk: (1) sanitation controls, including the implementation and operation of Sanitation Standard Operating Procedures (SSOP), (2) animal disease controls, (3) slaughter/processing controls, including the implementation and operation of Hazard Analysis/Critical Control Point (HACCP) programs and controls for the control of FMD (4) chemical residue controls, and (5) enforcement controls, including a government verification testing program for Salmonella spp. and Listeria monocytogenes.

Administrative functions were reviewed at CCA headquarters, one district office, and 10 local inspection offices at SENASA registered establishments, during which the auditor evaluated the implementation of those management control systems in place which ensure that the national system of inspection, verification, and enforcement were being implemented as intended.

The CCA selected 10 establishments to be audited, 2 of which are currently eligible to export to Canada. One of the beef slaughter establishments was in the region of Argentina that is classified by the CFIA as free of FMD without vaccination, while the remaining 4 were in the region that is free of FMD with vaccination. All five poultry establishments were chosen out of the list of establishments willing to export poultry meat products to Canada.

During the establishment visits, particular attention was paid to the extent to which industry and the government interact to control hazards and prevent non-compliances that threaten food safety, with an emphasis on the CCA's ability to provide oversight through supervisory reviews.

Table 1: Audit Scope Summary
Competent Authority Visits Number of Sites Visited Locations
Competent Authority: Central Authority 1 Buenos Aires, Argentina
Competent Authority: Regional Office 1 Buenos Aires, Argentina
Poultry Slaughter/Processing Establishments 5 Various locations
Bovine Slaughter / Processing Establishments 5 Various locations

3. Legal Basis for the Audit and Audit Standards

The audit was undertaken under the specific provisions of Canadian laws and regulations, in particular:

  • The Meat Inspection Act
  • The Meat Inspection Regulation 1990

The audit was conducted in a manner consistent with conventional program delivery audit standards, and was intended to assess the degree to which inspection activities performed by the CCA were consistent with the regulatory and procedural requirements and specifications.

4. Background

Argentina is currently eligible to export certain beef products to Canada. Between January and December 31, 2012, Argentina exported 815,167 kilograms of processed beef to Canada. Beef is currently the only species approved for export to Canada, and the list of products exported has been limited due to FMD.

CFIA performed an audit of Argentina's chemical residue control program in in 2010 and has been following up on Argentina's action plan to correct the findings of this audit. CFIA has performed some documentation review and a separate correspondence is being prepared to summarise those findings. Since then, the Animal Health branch of the CFIA determined that Argentina has the necessary controls in place to allow the import of raw beef to Canada, so long as the audit of the meat inspection system is acceptable.

5. Main Findings Concerning Government Oversight

Canadian import eligibility requirements dictate that the foreign inspection system be organized and administered by the national government of the foreign country and provide standards equivalent to those of the Federal system of meat and poultry inspection in Canada. In the case of Argentina, the authority to enforce inspection laws is exercised through the National Service for Animal Health and Agro-Food Quality (Servicio Nacional de Sanidad y Calidad Agroalimentaria, SENASA). The legal requirements and policies are written in the Decrees, Service orders and Circular Letters.

In addition to official inspection staff, SENASA permits the use of auxiliary personnel to perform post mortem inspection in poultry and beef slaughter establishments. Auxiliary personnel are company employees who conduct inspections under the direct supervision of SENASA, and they receive the same training as official inspection staff. The auxiliary personnel are not accredited i.e. they are not required to pass a written test before performing inspection duties, but they are continuously supervised by SENASA officials to ensure that they are effectively performing their work. In addition, they may be interviewed by SENASA to ensure that they understand their tasks.

Supervisory visits take place on a monthly basis in all slaughter plants. The report is signed by the Veterinarian in Charge (VIC) and plant management, and a copy is provided to the operator, the SENASA supervisor, Regional Office, and VIC. During the monthly visit, the supervisor conducts a plant tour with the VIC to review the plant operations and to discuss any outstanding issues. The rating on the supervisory report is acceptable, marginal, or not acceptable. In addition to the monthly supervisor's visit and report, staff from the headquarter's office in Buenos Aires also audit the establishment and SENASA staff on a yearly basis.

All non-compliances at the plant are recorded by SENASA on the Report of Official Control, and the corrective actions and signatures of the responsible individuals are also recorded on this document.

Although the CCA maintains the legal authority and the responsibility to enforce all applicable laws and regulations governing Argentinian and third-country requirements, it was observed that these requirements were not consistently applied throughout the system. Despite the issues identified during the audit at the various establishments relating to sanitation and slaughter/processing controls, SENASA specialists and local inspectors reacted appropriately to situations of non-compliance. SENASA specialists and inspectors worked cohesively to ensure that issues were handled promptly and effectively at the establishment, and inspectors were able to convey their knowledge and understanding of the expected roles and responsibilities of their position. Overall, the competence demonstrated by inspection staff indicated that SENASA's system for inspector training and periodic reviews is sound and effective.

Export certification is carried out in a manner different to that of the CFIA, and involves the issuance of a temporary certificate at the originating establishment which is exchanged for the final official certificate when the cargo is confirmed to have been transferred on-board the vessel. This process may change in the future when Argentina fully converts to electronic certification which is currently being tested under a pilot project in a number of official SENASA establishments. It is worth mentioning that the date on the final export certificate is the date the product is loaded on the ship, and that SENASA has control of the product up to this time. As in Canada, the main responsibility for meeting export requirements rests with the processing plant and penalties are applied in cases of non-compliance.

6. Sanitation Controls

An inspection system must contain requirements for sanitation, for sanitary handling of products, and for the development and implementation of sanitation standard operating procedures (SSOP). The pre-operational and operational sanitation standard operating procedures should minimise direct and indirect contamination of meat products to the greatest extent possible and be practicable. A properly implemented sanitation program must ensure that establishment, facilities, and equipment are cleaned and sanitized prior to start of operations, and includes the operational sanitation procedures, which will ensure that the appropriate hygiene is maintained during operations. SENASA staff performed a daily pre-operational inspection at all the establishments audited.

During the on-site portion of the audits, weaknesses were identified at one establishment in the manner in which the company performed and the inspection personnel verified the implementation of pre-operational sanitation procedures. The CFIA auditor identified obvious fat residue on transfer belts, cutting boards and metal bins in the evisceration and processing area. During the follow-up discussion, the CCA agreed to review their approach to preoperational inspection to ensure that the task was done in an effective manner.

During the review of the preoperational records, the frequency of verification and what was exactly to be done (record review versus onsite verification) was not always clear.

Operational controls for knife sanitation were very good throughout the work shift at the plants audited.

All plants audited used water that was sourced from underground wells or rivers. SENASA conducts regular water testing in all plants for microbial testing every 15 days and phyiso-chemical standards every 6 months. SENASA also checks the chlorine level twice a day, once during pre-operation and once during operations.

Pest control is well-controlled by SENASA. There are official documents that are submitted by the operator every 15 days which list the chemicals that have been used, all of which must be approved for use by SENASA.

7. Animal Disease Controls

The CFIA auditor evaluated animal disease controls, including a review of the mechanisms for animal identification, control of condemned and restricted product, implementation of the requirements for non-ambulatory disabled cattle and specified risk materials (SRM), and procedures for sanitary handling of returned and reconditioned product. Two diseases of concern were of interest during this audit are Bovine Spongiform Encephalopathy (BSE) and Food and Mouth Disease (FMD).

Argentina is categorized by the OIE as a negligible risk for BSE. In Argentina, only spinal cord and brain are considered as specified risk material (SRM), and must be disposed of in such a manner that they are not allowed to be recycled into the animal food chain. However, it is permissible for brains to be collected for human consumption. If the brains are not collected for human consumption, they must be collected and disposed of along with the SRM. All SRM is disposed of by either incineration or burial which effectively removes it from the food chain. No issues were identified with the controls for BSE.

There are specific controls for FMD for raw beef and cooked tubed beef. The CFIA auditor reviewed the process for maturation of the raw beef while in the zone of Argentina that the CFIA considers free of FMD with vaccination. Once all the carcasses have been placed in the maturation cooler, the room is closed, the door is locked by SENASA, and the temperature is monitored to ensure it reaches 2°C. After the carcasses have been stored in this cooler for 24 hours at this temperature, the door is unlocked by SENASA, and trained company personnel take the pH by inserting a probe into longissimus dorsi muscle between the 12th and the 13th ribs of every half carcass. Any carcasses which do not meet the required pH are identified by an official SENASA tag (yellow) and are sent for cooking or are cut at the end of the day to be sold into the domestic market. SENASA verifies 10% of the carcasses to monitor the company's results. The pH meter is calibrated by the company before taking the pH and then is re-checked after every 100 carcasses.

The auditor also reviewed the procedure for cooking of the cooked tubed beef and the pink juice test in 2 establishments. This program was well implemented controlled, and was audited by APHIS last year with fully satisfactory results. There is strict segregation between the cook and the raw side of the plant with positive air pressure on the cook side. SENASA keeps records of the temperature of the product which must be over 80°C and the results of the pink juice tests. Inspectors also check all the company's CCPs at random during the day and review records and verify that all instruments are properly calibrated. There is a very high safety margin with the process, as the beef is cooked to approx. 98°C, and the temperature is continually monitored and recorded on a thermograph. Traceability is unique to the combos and the company can trace product both forward and backwards.

During ante mortem inspection, the temperature may be taken of suspect animals if deemed necessary. Necropsies may be conducted on animals which arrive dead or die prior to slaughter. In order to inspect for the possible infection of the animals with FMD, during post mortem inspection every foot, muzzle and oral mucosa is inspected for lesions of FMD. The inspector has a button close by to stop the slaughter line in case any such lesions are identified at this station.

Argentina has a very robust traceability system. For beef, each producer has a unique brand which is applied to the live animal in addition to 2 ear tags. The ear tags can differentiate imported from native cattle, as the yellow tag is used for cattle from Argentina but red tag is applied if the animal is imported. Even if both ear tags are lost, the operator can verify the farm of origin with the brand which is also indicated on the transit document. In addition to the SENASA transit document, cattle arrive at the plant with commercial shipping documents and the official certificate for truck washing. Traceability is sufficiently detailed so that a single beef cut can be traced back to the carcass. Traceability is also well implemented in the poultry industry and can generally trace back to the grandparent flock. Mock recalls are conducted in all establishments on a minimum of once per year to test the effectiveness of the traceability system.

8. Slaughter/Processing Controls

The CFIA auditor reviewed Slaughter/Processing Controls, which included ante-mortem inspection procedures, ante-mortem disposition, humane handling and humane slaughter, post-mortem inspection procedures, post-mortem disposition, implementation of HACCP systems in all establishments, and implementation of a testing program for generic E. coli in slaughter establishments and E. coli O157:H7 in beef slaughter establishments. SENASA staff was very engaged in monitoring humane handling and stunning procedures. The lairage facilities were very well constructed and maintained with few exceptions. With respect to humane handling and humane slaughter the following findings were noted in some establishments:

  • At 2 establishments, beef carcasses were noted to have extensive bruising, and not all bruised areas were removed before the carcasses passed into the cooler. Bruises were noted on both cows and young cattle although both categories of cattle appeared in good physical condition otherwise. The CFIA auditor discussed the need to reach back to the farm and trucking companies as the animals were arriving at the establishment with the bruises.
  • At one beef establishment, several animals had not been properly stunned and were stunned with multiple stuns. The company took immediate action to correct the employee's work and said they would be purchasing a different stun gun.
  • Many fractured wings were noted in 2 poultry plants. One VIC attributed this to the stunning procedure rather than improper catching techniques.
  • Several instances of common contact of unapproved beef carcasses with equipment were identified by the CFIA auditor at various establishments. The companies and SENASA staff agreed to follow up to correct these situations.

Ante-mortem inspection was conducted according to regulation by SENASA at all the sites visited. It is done in a careful manner and includes a detailed review of documentation. In poultry establishments, the VIC also receives the pre-slaughter sheet the day before which contains information similar to the Canadian flock sheets. It is worth mentioning that farms are required to have a veterinarian on staff who must report any diseases of concern to SENASA, which highlights the focus on the farms for the production of safe food. Stunning was very well done and controlled at all poultry facilities. For poultry, the documents received with the live animals include the: (1) Registro criador – the farm registration information, (2) DT-e – the official transit document, (3) Remito – commercial documents, and (4) Certificado lavado y desinfección de camiones - official washing and sanitation certificate. In the case of cattle, the DTe includes the date of the vaccination for FMD and brucellosis.

There is normally a 2 hour resting for the birds between arrival at the plant and slaughter, but the birds normally receive ante-mortem inspection as the trucks arrive at the plant. There is no time prescribed in SENASA Regulations but there does not appear to be an issue in meeting CFIA's requirements that birds receive ante-mortem inspection within 24 hours of being slaughtered. If there is high mortality, necropsies may be performed to determine the cause.

The companies were very engaged in ensuring humane handling and proper facilities for the receipt of live animals and were quick to follow up when a non-compliance was identified. However, the auditor noted numerous carcasses that were bruised at 2 beef plants that were judged to have occurred prior to arrival at the plants, and in some cases the bruising was not adequately trimmed on the kill floor before moving to chilling. The humane handling and trimming requirements were both discussed with plants and SENASA.

SENASA requires that live cattle be washed in order to reduce microbial contamination prior to slaughter. This includes washing the parts of the animal where the cuts will be made during the dressing procedures. All beef plants audited used hyper-chlorinated water from 5-15 ppm for this purpose, and washing occurred at several points, including after receiving and just prior to slaughter and the animals were visibly clean before slaughtering. This may be part of the reason for the low rates of detection of Salmonella and E. coli O157:H7.

SENASA has legal requirements for GMPs and SSOP implementation but HACCP is not currently a legal requirement. However, all the plants visited had implemented a HACCP plan, in most cases to meet export country requirements. If the plant has a HACCP plan, it is monitored by SENASA staff through random checks. However, there may be no record to show that the verification has taken place unless an issue is identified and it would then be recorded on the Report of Official Control.

The beef post-mortem inspection meets the CFIA requirements with the exception of failure to incise the lateral retropharyngeal lymph nodes at all 5 beef plants that were audited. The CCA agreed to follow up and have this corrected immediately.

For poultry, the line speed is related to good practices and is based on the plant's operational capacity. The official veterinarian may order a reduction in line speed if there are problems and if it is determined that it is required. There is an official inspection station post defeathering where the majority of condemned birds are removed. There are 2 subsequent inspection points, 1 post evisceration (point # 1), where the viscera, carcass and internal cavity are inspected, and a subsequent inspection point (Point # 2) after evisceration and final washing just prior to the chill tank. There are normally 2 inspectors or auxiliary staff performing 100% inspection of both the carcass and the viscera at Inspection Point #1. In addition, a certain percentage of birds must be inspected post chilling. At this inspection station, SENASA verifies that chickens are properly sorted and sent to cut-up as required so that fractures, bruises and minor pathological lesions defects are removed.

There were no issues identified in the canning facility.

A mock recall is conducted at least once per year in all establishments. No issues were identified.

Poultry slaughter plants must have documented systems for process controls and written procedures that are approved by the CCA. Poultry must meet the required microbiological standard, as outlined in Resolution # 198/95 that requires that Salmonella spp. be absent in 25 g. All plants had at least one re-processing station where contaminated birds were washed before being returned to the evisceration line, and the employees performing this task are trained to assess birds for suitability to be returned to the line. A post-mortem report is completed for all lots which details the condemned birds.

Unlike in Canada, Argentina does not require the removal of the oil sac during the evisceration and carcass dressing for poultry.

The CFIA auditor noted that the light intensity of 300 lux was not sufficient, and several establishments had much higher intensities to address this concern. CFIA recommends that the CCA reviews the design of the work stations in poultry plants to ensure that space and light intensity is adequate for the inspection staff and company personnel to effectively perform their respective tasks related to inspection or re-conditioning contaminated birds. Related deficiencies were noted at inspection points 1 and 2 in different establishments and these were discussed with the CCA.

The requirements for generic E. coli testing are outlined in Circular 3834/2008. For poultry, the sample is taken by carcass swabbing. For beef, generic E. coli is used as an indicator of carcass contamination. SENASA requires that carcasses be tested at a rate of one test per 300 carcasses using the sponge method on 4 carcass sites: the rump, flank, brisket and neck. The company must graph the results so they are easy to interpret and SENASA has set acceptable, marginal and unacceptable limits. For carcasses, the limits are: acceptable (<5 cfu/cm2), marginal (5-100 cfu/cm2) and unacceptable (>100 cfu/cm2).

For the chemical residue program, (Plan Nacional de Control de Residuos e Higiene en Alimentos (CREHA), SENASA field staff are informed about the samples that need to be taken for chemical residues testing every 2 months and access the plant-specific plan on-line through a password protected system. Each plant is assigned a level of sampling based on the production and the export market. SENASA local staff receives all the results of the chemical residue testing, regardless if the result is positive or negative. If a result is positive, SENASA will trace back to the producer, and the next 5 shipments from that producer will be sampled. In addition, and the violator's name is published on the SENASA website.

9. Laboratory Controls

The inspection system must have a laboratory control program, organized and administered by the national government, which includes random sampling of internal organs and fat of carcasses for residues identified by the exporting country's meat and poultry inspection authority or by CFIA as contaminants. Although no laboratories were audited, the plants' participation in both the mandated testing for microbial and chemical residues was audited. No issues were identified during onsite visit. However, as stated earlier, a few equivalence issues were noticed during documentation review of the Argentina's Chemical Residue Control Programs by CFIA and are being addressed through separate correspondence.

10. Microbiological And Enforcement Controls

The CFIA auditor reviewed enforcement controls. These controls included the enforcement of inspection requirements and the testing programs for Salmonella spp., Escherichia coli 0157:H7, Listeria monocytogenes.

With respect to the control of Listeria monocytogenes, there were no concerns identified in the establishments that were producing ready to eat meat products.

Samples for Beef Microbiological Testing were routinely negative for Salmonella spp. and E. coli O157:H7 as verified during the audit.

With respect to the control of E. coli O157:H7: (1) one beef slaughter establishment did not consider E. coli O157:H7 as a hazard likely to occur in its HACCP plan. The operator agreed that this was required and said the company would make the required change. SENASA also agreed to follow up to make sure their policy was fully implemented. For the sampling of trimming, the plants audited were not performing N-60 sampling as required under the Canadian policy described in chapter 4, Annex O of MOP. Additionally, their method of sampling did not focus on external surface of the trims.

Salmonella testing is conducted according to the requirements of the Food Safety and Inspection Service of the United States Department of Agriculture (FSIS/USDA) as outlined in Circular Letter 3764. This requires 82 samples for young cattle and 58 for cows/bulls, and once completed, testing must continue with 1 test per month. If a positive is found, the companies must perform additional tests in order to determine the cause of the positive, and the product is placed under control and directed to cooking. SENASA must also take 53 samples for ground beef in addition to those for carcasses. Plants are required to chart their results in order to assess trends.

For E. coli O157:H7, the reference document is Circular 3834/2008. Carcasses must be sampled at a rate of 1 sample per month regardless of slaughter volume. Trimmings must be sampled once per month based on volume of production (one sample if production is under 50 000 kg per month or 2 samples of production is greater than 50 000 per month). If ground beef is manufactured, testing is also required at a rate of one sample for production up to 50 000 kg per month or 4 tests if production is greater than 50 000 per month. One company collected a pooled sample of trim every 2 hours to collect a total of 1 kg for the day from the company selected the required sample size. Although the in-house lab is not accredited, samples taken by the company are in addition to those required above by SENASA, and the plant must inform SENASA if they detect a positive result. Argentina's policy for E. coli O 157 controls in raw beef significantly differs from Canadian policy.

For poultry, the company may do excision testing for Salmonella to meet EU requirements which requires an absence of Salmonella in 25 g, and this is done according to the EC Regulation 2073/2005 on Microbiological criteria. Historically there are no Salmonella positives, but if a positive Salmonella is detected the operator must perform additional tests to determine the source. SENASA does not yet have an approved test for Campylobacter, so testing for Campylobacter was not being performed at the time of the audit but is under consideration.

The CFIA auditor noted several differences between the Canadian and Argentinian approach to poultry inspection. The first is related to the controls over evisceration and contamination. One plant was found not to have a written policy for zero fecal contamination, and contaminated carcasses were to be controlled at inspection station #2. However, since this station was not monitored 100% of the time, it's possible that contaminated birds could pass into the chiller, during which time the contamination could be transferred to other carcasses. In some plants, inspection point #2 is a verification point for the removal of lungs, crops and windpipes, and a check for fecal contamination. The CFIA auditor noted that 1 establishment had a CCP to address zero fecal contamination and also had completed a validation study to confirm its effectiveness and this is one effective way to demonstrate control.

Related to the control for fecal contamination, there appears to be some confusion about inspecting the cavity of the bird. Although SENASA legislation requires 100% of the birds to be inspected, it was not always clear if this was occurring, or if indicators such as micro standards are used instead of visual inspection to determine the overall effectiveness of the evisceration controls as related to detection of fecal contamination. The CFIA requires that each carcass be inspected and that both the exterior and the cavity of the carcass must be examined.

Another major difference is the trimming of partially condemned portions for poultry. In Canada, all inedible portions are removed prior to the approved carcasses leaving the evisceration room, while in Argentina, carcasses with localized condemnable portions are allowed to leave the evisceration floor and pass into the chilling system where these portions are then removed and discarded. These portions may include minor pathology (up to 30% dermatitis or cellulitis) and trimmable bruised portions. Regarding the chilling of poultry, SENASA requires that carcasses be chilled to a max of 10°C when exiting the chillers and within 6 hours must reach a temperature of max 2°C +/- 2°C. There are no written requirements for giblets but the CFIA auditor was informed that giblets are treated similarly as are the carcasses.

With regard to edible feet collection of poultry, while the majority birds are condemned at the de-feathering post mortem station, a small number of birds may be condemned post evisceration, normally due to mutilation or contamination and not for pathology. For Canada, the edible feet must only be from approved carcasses, so the CCA would need to address the birds that would be condemned post evisceration and how to retrieve and remove the associated feet if Argentina plans to export edible chicken feet to Canada.

The standards for mechanically separated poultry meat are slightly different in Argentina and Canada. CFIA requirements for MSM are:

  • no more than 0.027% of calcium for every 1% of protein;
  • no bone particles larger than 2 mm in size; and
  • a minimum protein content of: 10%; or if destined for retail sale, 14%

While in Argentina the MSM standards are:

  • it shall contain no more than 1% solid bone
  • 98% of bone particles shall be no larger than 1.5 mm and none shall be larger than 2 mm in size
  • calcium shall be not greater than 0.235%

11. Closing Meeting

The closing meeting was held in Buenos Aires on September 25 with SENASA. At the meeting, preliminary findings from the audit were presented by the CFIA auditor. The CCA also provided a presentation on the Argentina's chemical residue monitoring program.

12. Conclusions and Recommendations

Overall, the audit of the Central Competent Authority (CAA) indicated an effective organizational structure, facilities, equipment, transportation, communication, personnel, and training of the competent authority, to support objectives of meat and meat product inspection and certification programs for export to Canada.

However, the following issues need to be addressed:

  1. Beef inspection: not all the requirements of Chapter 4, Annex O of the CFIA Meat Hygiene Manual of Procedures (MOP) were being followed in all establishments. The Policy described in Annex O or equivalent must be implemented in order to allow the export of raw beef to Canada. The CFIA auditor determined that SENASA is not routinely incising the lateral retropharyngeal lymph node as required. SENASA followed up during the audit to remind field staff of this requirement. Beef grading was not evaluated during this audit.
  2. Poultry Inspection: a major difference was identified during the audit related to the trimming of partially condemned portions. In Canada, all inedible portions are removed prior to the approved carcasses leaving the evisceration room, while in Argentina, carcasses with minor condemnable portions are allowed to leave the evisceration floor and pass into the chilling system where these portions are then removed and discarded. The CFIA desk review had already identified significant differences between the Argentina's and Canada's poultry grading programs, Consequently, CFIA concluded that Argentina's poultry grading program is not equivalent and therefore export of Argentinian poultry with a grade designation cannot be allowed. However, Canada does allow the imports of ungraded poultry if all other requirements are met. This program was not reviewed as part of the on-site audit. Similarly, product standards for poultry mechanically separated meat differ between Argentina and Canada, so companies that intend to export this product will need to meet the CFIA standards. Finally, control of evisceration may need to be standardized through all poultry establishment to ensure that contamination is effectively controlled in all poultry plants.
  3. Compliance and Enforcement Issues: Although the CCA maintains the legal authority and the responsibility to enforce all applicable laws and regulations governing Argentina and third country requirements, the auditor found that these requirements were not consistently applied throughout the system. As such, oversight of the implementation of effective sanitation and establishment operations will need further improvement.

Following the review of the action plans provided by SENASA, Argentina's beef inspection system for slaughter, cutting and processing was determined to meet Canada's requirements and in addition to cooked boneless beef, raw fresh/frozen boneless beef is now approved for export to Canada.

However based on audit observations and review of subsequent action plans from SENASA, Argentina's Poultry inspection system cannot be approved. See "Supplementary response" below-

Supplementary response based on the information received on April 15, 2016

Following the review of the action plans provided by SENASA, it was determined that Argentina's poultry meat inspection system for slaughtering, cutting, and processing meets Canadian requirements: in addition to cooked boneless chicken, fresh/frozen raw boneless chicken is now approved for export to Canada. However, the import of poultry feet is not allowed because the Canadian requirements for this product have not been met.

Documents reviewed by CFIA confirm there are major differences between the Argentina and the Canadian grading poultry system. The CFIA had concluded that the poultry grading program in Argentina is not equivalent to Canada so the CFIA maintains the conclusion that the poultry grading program in Argentina is not equivalent. The import of poultry from Argentina cannot be authorized with a grade designation. Canada allows import of poultry without designation when all other requirements are met.

For mechanically separated poultry meat, the standards in Argentina and Canada are different, so the establishments that intend to export these products must meet Canadian standards.

Refer to Annex 1 for details regarding CFIA recommendations.

13. Annexes

Annex 1: Summary of Servicio Nacional de Sanidad y Calidad Agroalimentaria's (SENASA) Action Plans/Comments to the Canadian Food Inspection Agency (CFIA) Recommendations/Findings from September 2013 Audit of Argentina's Beef and Poultry Inspection Systems

1. Sanitation Controls
No CFIA Recommendations SENASA Action Plans / Comments
1.1 CFIA recommends that SENASA creates tools in order to ensure that pre-operational standards are met and to ensure that training on pre-operational procedures is provided to SENASA personnel.

In this regard, and monitoring of the action list sent with your letter of 12th June, 2014, SENASA advises that these actions will be implemented immediately as soon as trade for these products is established between Argentina and Canada.

Supplementary Response Provided on April 30, 2015:

This measure is implemented through Memo DIPOA No. 198/2015 of April 10, 2015. "Compliance with Pre-Operational Standards and Training": by virtue of the visit carried out by Canadian Health Authorities and regarding detected findings, we hereby inform that from today on, Veterinary Inspection Services shall adjust to Chapter XXXI of Decree 4238168 in order to ensure compliance with Pre­ Operational standards, by training their official staff at each establishment, about such procedures.

Likewise, the Veterinary Inspection Services shall keep records of such trainings and assessments, which shall be appropriately filed later in order to be audited when the SENASA Headquarters require doing so. The memo is enclosed herewith for your knowledge.

(…) SENASA has instructed all establishments authorized within its sphere on subjects regarding pre-operational inspections through Memo DIPOA No. 198/2015 of April 10, 2015.

2. Slaughter/Processing Controls
No CFIA Recommendations SENASA Action Plans / Comments
2.1 SENASA is requested to investigate the cause of the bruising of the bovines and fractured wings of poultry (e.g. handling at the farm, during transport, etc.) and ensure appropriate actions are taken to prevent re-occurrence.

In this regard, and monitoring of the action list sent with your letter of 12th June, 2014, SENASA advises that these actions will be implemented immediately as soon as trade for these products is established between Argentina and Canada.

Supplementary Response Provided on April 30, 2015:

The measures adopted in order to avoid the repetition of these situations are detailed in Chapter XXXII of Decree 4238/68, published in the Official Bulletin, through Resolution No. 46/2014, and are being implemented since February 4, 2014.

Decree 4238-68, Chapters 1 to 30, was provided to the CFIA.

2.2 There should be no points of common contact between unapproved carcasses and equipment in order to prevent cross-contamination. The contact points have been eliminated, diminishing thus the occurrence of cross-contamination between carcasses.
2.3 The CFIA requires that 4 pairs of lymph nodes in the cattle heads be incised during post mortem inspection. Circular 4122/2013 is the memo that was issued to the field advising staff of the need to incise the 4 pairs of lymph nodes in cattle for export to the US and Canada, and included anatomical pictures of the lymph nodes.
2.4 CFIA recommends that SENASA review the design of the work stations in poultry plants to ensure that the workspace and light intensity permit inspection staff and company employees to effectively perform their tasks related to the inspection and processing of poultry. The establishments applying for the export of poultry to Canada shall be required to have adequate space for inspection and control tasks according to the requirements of CFIA in its Chapter 19 Program of Poultry Inspection for which SENASA shall provide compliance assurances.
2.5 All trimmable lesions, such as bruised portions, dermatitis and cellulitis must be removed from carcasses before the approved carcasses exit the slaughter area and enter the chilling system.

The model official inspection established through Service Order No. 02/2009 contemplates the control at inspection points ante mortem and post mortem, post plucking, post gutting, post internal and external washing up, at the exit from the chilling system and in the area of carcass cutting, where carcasses and/or their parts are disposed of, which may represent a risk for the safety of the final product.

The establishments carry out the validation of the process line and the product through their respective HACCP/APPCC systems. It is controlled, documented and duly validated, performing a process validation, which is verified by the SIV at the establishment. Besides, microbiological analyses of process hygiene and food safety of all the manufactured products are officially conducted on a periodical basis.

Supplementary Response Provided on April 15, 2016:

Following the visit of the technicians of Argentina in Canada in November and December 2015, the competent authority of Argentina has created assessment guidelines for adjusting poultry meat slaughter and processing establishments who want to export to Canada.

In these guidelines, all trimmable lesions, such as bruised portions, dermatitis and cellulitis will be removed from carcasses before the approved carcasses exit the slaughter area and before chilling. To do so, a post-evisceration official inspection station and an operator station have been added to verify the performance of the detection system of these defaults before chilling. The operators also integrated the monitoring of theses defaults in their HACCP, records and training program will be made available.

The establishments who want to export to Canada must completely comply with Argentina assessment guidelines for poultry meat slaughter and processing establishments who verify the compliance requirements of the establishments to the Canadian import eligibility requirements.

2.6 The CFIA desk review of Chapter XXI has identified significant differences between the Argentina's and Canada's poultry grading programs, with the conclusion that Argentina's specifications on poultry grading do not meet the equivalence requirements laid out in the Canadian Livestock and Poultry Carcass Grading Regulations. Due to the lack of equivalence in the requirements established in the Canadian legislation about the bird carcass classification, only then dispatch of non-classified poultry products would be permitted when all the rest of the requirements provided for that destination are complied with.
2.7 The CFIA requires SENASA to ensure the uniform implementation of a zero fecal tolerance in poultry slaughter establishments, and that the cavity of every bird is inspected as part of the routine post mortem inspection.

The model official inspection provided for by Service Order 02/2009, 'Guidelines to take into account in ante mortem and post mortem Inspections of Birds and Lagomorphs', contemplates the control at the ante mortem and post mortem inspection points (post plucking, post gutting, post internal, and external washing up, and lastly a later control to the pre-chilling system). The ante mortem and post mortem inspections of the slaughtered animals and the maintenance of the hygiene practices provided for in the Order mentioned above are done to assure that the fresh meat produced for human consumption is safe and healthy. The test conducted at these two stages involves, among others: inspection of viscera, of the cavity and the external surface of birds; the basis of the standard is controlling; observing diseases or pathologies affecting the general condition of the bird, and sanitarily verifying the proper operative process.

The inspection procedure has scientific grounds; it is adequate for the variety and incidence of the diseases and defects present in slaughtered animals in our country. The presented inspection program is efficient and the inspection authority assumes the responsibility for all decisions made in respect to the results of said ante mortem and post mortem inspections.

The industry and the inspection authority shall share the responsibilities for the production of safe and healthy meat. The staff of the industry shall broadly participate in the application of quality control systems and in the hygiene surveillance and control, under the supervision and verification of the inspection authority, in order to assure the compliance with the requirements.

The establishments assure the control of all birds as regards preventing the presence of fecal contamination of carcasses before their entry to the chilling system. The establishments assure the control of all birds as regards preventing the presence of fecal contamination of carcasses before their entry to the chilling system.

It must be controlled, documented and duly validated in their Hazard Analysis Critical Control Point (HACCP) system. A process validation is done, which is verified by the SIV at the establishment.

Supplementary Response Provided on April 30, 2015:

Furthermore, SENASA expresses its gratitude for the acceptance of the visit by Argentinean technicians for assessing the program for the inspection of poultry meat of the CFIA.

Likewise, we inform you that once such visit is concluded, an action plan shall be drafted and submitted so as to comply with the requirements of Canadian equivalence.

Supplementary Response Provided on April 15 2016:

Following the visit of the technicians of Argentina in Canada in November and December 2015, the competent authorities of Argentina have created assessment guidelines for adjusting poultry meat slaughter and processing establishments who want to export to Canada.

In these guidelines, a zero fecal contamination tolerance is implemented before chilling in poultry slaughter establishments. To do so, the dressing and trimming methods have been revised at the evisceration to avoid and prevent the fecal contamination. The cavity and the external surface of every carcass are inspected as part of the routine post mortem inspection. Furthermore, a post-evisceration official inspection station and an operator station have been installed to verify the performance of the detection system of the fecal contamination before chilling system. The operators also integrated the monitoring of uniform implementation of a zero fecal tolerance in their HACCP, records and training. The post-evisceration official inspection station and an operator station allows the cavity of every bird to be inspected, as part of the routine post mortem inspection, through the detection of the fecal contamination for the zero tolerance program.

The establishments who want to import to Canada must completely comply with Argentina assessment guidelines who verify the compliance requirements of the establishments to the Canadian import eligibility requirements.

2.8 CFIA requests that SENASA specify the chilling requirements for poultry giblets.

For the case of edible offal (considered as food/meat for the case of Argentina Regulation 4238/68 chapter I, 1.1.9 and 1.1.16), the requirements for chilling are the same as those provided for carcasses under Regulation 4238/68, Chapter XX, section 20.5.11. Carcasses be chilled to a max of 10 degree C when exiting the chillers and within 6 hours must reach a temperature of max 2°C ± 2°C.

Supplementary Response Provided on April 30, 2015:

All establishments that request authorization for exporting to Canada giblets and all parts of slaughtered carcasses collected during preparation procedures, including separated necks and separated sections, shall be requested to be cooled at 4°C, or less, according to the requirements of the CFIA for which this National Service shall ensure its compliance by verifying procedures and records for such destination.

2.9 As HACCP is a mandatory requirement according to the Canadian Meat Inspection Regulations, SENASA must have HACCP in place in all establishments eligible to export meat products to Canada and a record of all official verifications must be maintained.

Within the Argentine national legislation, at present, the HACCP classification is a mandatory requirement for all establishments authorized by SENASA in accordance with Resolution 205 dated 14th May, 2014, which amends Chapter XXXI of Law/Decree 4238 of 1968.

Supplementary Response Provided on April 30, 2015:

All exporting establishments adjust to the conditions and requirements of the countries of destination pursuant Chapter I subparagraph 1.1.4.1 of Decree No. 4232/68.

Since May 20, 2014 (date of publication in the Official Bulletin), SENASA has ensured the verification of HACCP systems of all the authorized establishments covered by Decree No. 4238/68, through Resolution No. 205/2014 (which amends Chapter XXXI of Decree No. 4238/68).

The verification of the HACCP system is carried out through:

a) Supervision Reports carried out by the Supervisors of Zone or Area Offices each time they visit the establishments for which they are responsible. The frequency of such visits is regulated by Circular Letter No. 4056A/2013 (which is enclosed herewith).

b) Periodic Verifications from SENASA Headquarters, registered through Diagnostic Assessments.

Likewise, Veterinary Inspection Services verify the system through records of SSOP's carried out every production day in the establishment. An annual Check List of the HACCP System is carried out on establishments authorized for export to the United States, Canada, and Japan.

Decree 4238-68, Chapters 1 to 30, was provided to the CFIA.

3. Microbiological and Enforcement Controls
No CFIA Recommendations SENASA Action Plans / Comments
3.1 All raw beef products exported to Canada must meet the CFIA requirements for E. coli as outlined in annex O, chapter 4 of the Manual of Procedures (MOP).

As of the opening of the trade between Argentina and Canada for fresh unprocessed beef, all Argentinean establishments licensed by SENASA and authorized by CFIA shall implement the requirements established in Chapter 4, Annex O of MOP, in order to comply with the policy of CFIA about E. coli O157:H7, in trimmings, according to the procedure N-60 (if the production is larger than 25000 kg).

References:
Circular 3514/ on E. coli O157:H7 and meeting the US requirements
Circular 3834/2008 on Argentina's controls for E. coli O15:H7.
Circular 4008/2012 on the implementation of the testing of the Non Shiga toxin-producing E. coli (Non-STEC) to meet the US requirements.

Supplementary Response Provided on April 30, 2015:

All exporting establishments that are interested in exporting raw fresh/frozen deboned bovine meat shall comply with the requirements of the CFIA for "E. coli 0157:H7" controls; such requirements are detailed in Annex 0, Chapter 4 of the MOP and in the amended Annex A of Chapter 10 of the Manual of Procedures.

3.2 Should Argentina plan to export edible chicken feet to Canada, SENASA must address how to retrieve and remove the associated feet from carcasses that are condemned post evisceration.

The procedure of claw removing is done after the health inspection of the ante mortem and post mortem points (post plucking) of birds. In case of evidence of signs or alterations compromising or providing suspects in relation to possible alterations in the general condition of a bird, a complete seizure of it is done in said sector.

The claws declared fit for human consumption after their post mortem inspection are subjected to a manufacture process (Scalding, peeling, classification, and packing. It is clear that those claws declared unfit are derived to the circuit of inedible products.

Supplementary Response Provided on April 15 2016:

Argentina is no longer interested in exporting edible chicken feet in Canada.

3.3 If establishments want to export poultry mechanically separated meat to Canada, the product must meet Canadian requirements. In respect to mechanically separated meat, SENASA confirmed that there would be no inconveniences in complying with the Canadian standards, according to the details of the draft report.
3.4 If establishments want to export poultry meat to Canada, the uropygial gland must be removed. The establishments applying to export poultry to Canada shall be required to eliminate the uropygial gland, for which SENASA provides certification assuring such compliance.
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