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
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 World Organisation for Animal Health (WOAH; founded as Office International des Épizooties (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.
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