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

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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