Final Report Of An Audit Conducted In The United States February 5th, through February 22nd, 2013 Evaluating The Food Safety Systems Governing The Production Of Meat And Poultry Products Intended For Export To Canada

Complete Text

Table of Contents

• 1. Introduction
• 2. Audit Objective, Scope, and Methodology
• 3. Legal Basis for the Audit and Audit Standards
• 4. Background
• 5. Government Oversight
• 6. Sanitation Controls
• 7. Animal Disease Controls
• 8. Slaughter and Processing Controls
  • 8.1 Humane handling and animal welfare
  • 8.2 Listeria monocytogenes control requirements for Ready-to-Eat (RTE) meat product
  • 8.3 Mandatory testing for generic E. coli in abattoirs and certain raw meat processing establishments
  • 8.4 Cooling of heat treated meat products and poultry products
  • 8.5 Salmonella control requirements in RTE meat products manufactured by a dry-cure process or other like process that does not involve heat treatment
  • 8.6 HACCP
• 9. Laboratory Controls
• 10. Enforcement Controls
• 11. Closing Meeting
• 12. Conclusions And Action Items

Executive Summary

This audit report describes the outcome of an on-site audit of the United States' meat and poultry inspection system conducted by the Canadian Food Inspection Agency (CFIA) from February 5th to February 22nd, 2013.

This was a routine ongoing equivalence verification audit. The audit objective was to ensure that the United States continues to maintain a food safety system for meat and poultry that is equivalent to that of Canada, with the resultant 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, the United States exported 713 073 375 kilograms of raw and processed meat and poultry products to Canada.

The onsite audit scope included three (3) beef, two (2) pork and three (3) poultry slaughter establishments, as well as four (4) meat processing establishments producing ready-to-eat (RTE) meat products. Additionally, CFIA auditors visited two (2) government offices, including the USDA-FSIS headquarters, and one (1) government laboratory conducting microbiological and chemical residue testing.

Determinations concerning the effectiveness of the USDA-FSIS's food safety system were made by the evaluation of the performance within the following six components upon which system equivalence is based: (1) government oversight, (2) sanitation controls, (3) animal disease controls, (4) slaughtering and processing controls, (5) laboratory controls and (6) enforcement controls.

Overall, the audit showed USDA-FSIS's food safety system is performing as intended in an adequate manner and meets the criteria for all six components; as a result no establishment was delisted during this audit. However, specific audit findings in two (2) establishments would have warranted delistment, if the findings were not satisfactory corrected within 30 days from the date of the audit. These finding and compliance action taken indicate a need for improvement of USDA-FSIS's oversight related to sanitation and animal welfare requirements.

During the audit visits to the above two establishments, USDA-FSIS auditors and local inspection staff reacted appropriately to the situations of non-compliance. Auditors and inspectors worked cohesively to ensure that identified issues were handled promptly and effectively at these establishments. Within the timeframe provided by CFIA, the two (2) establishments developed and implemented corrective actions and preventive measures addressing the concerns identified during the audit. Following USDA-FSIS and CFIA's review of the action plans, the two (2) establishments remained eligible to export to Canada.

In other establishments visited, issues relative to the following items were found: SRM removal, HACCP implementation in establishments (including the one subject to 'Voluntary Reimbursable Inspection Services'), implementation of animal welfare requirements, policies related to the control of Listeria monocytogenes in Ready-to-Eat (RTE) meat products and policies related to the control of Salmonella in non-heat treated RTE products.

Further, CFIA auditors have determined that the following export requirements for Canada as specified in the current USDA-FSIS Export Library for Canada – "meat products produced under the Voluntary Reimbursable Inspection Services do not meet the Canadian requirements and are prohibited for export to Canada" are valid. These products produced under the voluntary inspection are not subject to HACCP, Sanitation SSOP, and Listeria control requirements. In addition, FSIS program personnel do not verify these establishments/products for adherence to food safety requirements as required for all meat products eligible for export to Canada.

The overall audit process underscores the need for ongoing technical discussions to occur between the Central Competent Authority (CCA) and the CFIA to maintain equivalency between our two systems.

However, the following items need particular attention from the FSIS:

• Animal welfare requirements for poultry and pork in the US
• Ante-mortem inspection procedures for poultry
• SRM controls in inedible products and appropriate validation regarding edible product
• Implementation of FSIS requirements for validation for 5-7 D reduction of Salmonella in US establishments producing non-heat treated RTE products
• HACCP requirements and implementation in FSIS regulated establishments

Abbreviations And Special Terms Used In The Report

CCA

Central Competent Authority
(Food Safety and Inspection Service - United States Department of Agriculture/ Food Safety and Inspection Service)

CCP

Critical Control Point

CFIA

Canadian Food Inspection Agency

Codex alimentarius

Harmonized International Food Standards developed by the Codex Alimentarius Commission

D reduction

Reduction in the number of target micro-organisms by order of log10 magnitude, for example: 2D reduction = 102 (100x) reduction; 5D reduction = 105 (10 0000) reduction.

E. coli

Escherichia coli

FSA

Food Safety Assessment

FSEP

Food Safety Enhancement Program

FSIS

Food Safety and Inspection Service

HACCP

Hazard Analysis and Critical Control Point

HIMP

HACCP based Inspection Model Plants

MOI

Memorandum of Interview

NR

Noncompliance Record

PHIS

Public Health Information System

POE

Port of Entry

RTE

Ready-to-Eat

Salmonella

Salmonella species

SRM

Specified Risk Material

SSOP

Sanitation Standard Operating Procedures

Validation

Within the HACCP process, the collection and evaluation of scientific and technical information to determine whether the HACCP plan and/or CCP, when properly implemented, will effectively control the identified food hazards

Voluntary Reimbursable Inspection Service

Inspection services provided by FSIS to accommodate business needs, such as obtaining certifications necessary to meet requirements of importing countries or the inspection of nonamenable products. FSIS collects fees from all facilities (including official establishments) that request inspection and certification services that are not required by the statutes. FSIS conducts voluntary reimbursable services only when they are requested by the facility.

FSIS requires all facilities where it provides voluntary reimbursable services to maintain themselves, at a minimum, in accordance with 9 CFR 416.1 - 416.6. Non-official facilities are not required to comply with the requirements of Sanitation SOPs and HACCP, and although a non-official facility voluntarily may choose to have Sanitation SOPs and HACCP plans, inspection program personnel are not to perform any of the Sanitation SOP or HACCP verification activities found in FSIS Directive 5000.1, Revision 2.