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
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%
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