Final Report of an Audit Conducted In Four European Union Member States February 3rd Through February 21st, 2014
Evaluating The Food Safety Systems Governing The Production of  Beef And Beef Products For Export To Canada

7. HACCP Plan and Pre-Requisite Programs Controls

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An inspection system must provide an appropriate regulatory framework to demonstrate an appropriate control over the relevant food safety requirements. In the context of equivalence with Canada, the CCA must mandate for each FBO the development, implementation and maintenance of an HACCP system, or any alternate equivalent system. The CFIA auditors reviewed the implementation of HACCP systems in all visited establishments to determine the appropriate maintenance of the CCA oversight. This included the assessment of appropriate implementation of HACCP plans, pre-requisite programs, sanitation programs and sanitary handling of products.

In the EU, all requirements for the hygiene of food are laid down in the following three main regulations:

  • Regulation (EC) 852/2004: General hygiene procedures for food at all stages of the production process, from primary production to sale to the EU consumer (so-called "from-farm-to-fork approach").
  • Regulation (EC) 853/2004: Supplemental to Regulation (EC) 852/2004 laying down all specific requirements for food businesses dealing with food of animal origin. EU has legal requirements for the mandatory HACCP. Accordingly, all the plants visited had implemented HACCP plan(s), pre-requisites and sanitation controls.
  • Regulation (EC) 854/2004: This provides the specific rules for the competent authority of official controls to be implemented on products of animal origin intended for human consumption. So, accordingly all the plants visited have their HACCP systems verified by their competent authority through random checks on a regular basis.

In general, HACCP controls were adequately performed and verified. However, a number of shortcomings were identified by the auditors. These have been summarized under following sub headings in the MSs specific Annexes:

  • HACCP Systems Design and Maintenance
  • Sanitation
  • Good Hygiene Practices (GHP)
  • Ventilation
  • Building, construction, design and maintenance of the premise
  • Outside premises
  • Pest Control Program
  • Traceability and Recall Procedures
  • Equipment Maintenance and Calibration

In most cases, competent authorities (CAs) took appropriate compliances actions. Although the CAs in the respective MSs seemed to be committed to follow up on these deficiencies, the CFIA would request that the response from respective MSs commits to verify the implementation of corrective actions and preventative measures for all items.

Generally speaking there is scope for improvement in keeping the written programs and records complete and up to date. For example, deficiencies regarding verification procedures were noted in various establishments. Similarly the establishments need to improve their programs to control the contamination of meat products.

Multiple issues in one establishment warrant the need for development and implementation of effective action plan to address all findings.

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