Language selection

Government of Canada / Gouvernement du Canada

Search

Final report of a virtual audit conducted in the Netherlands to evaluate meat inspection systems governing the production of bovine and swine meat and meat Products – February 15 to 24, 2021

On this page

Abbreviations and special terms used in the report

CA
Competent Authority
CCA
Central Competent Authority
CCP
Critical Control Point
DG SANTE
European Commission Directorate General for Health and Food Safety
CFIA
Canadian Food Inspection Agency
E. coli
Escherichia coli
EC
European Commission
EFSA
European Food Safety Authority
EKS
Export Canalization System (Quality System Export Certification)
EU
European Union
FBO
Food Business Operator
HACCP
Hazard Analysis and Critical Control Point
KDS
Inspection Service Animal Sector
LNV
Ministry of Agriculture, Nature and Food Quality
MRL
Maximum Residues Level
NRCP
National Residue Control Plan
NVWA
Netherlands Food and Consumer Products Safety Authority
OA
Official Auxiliary/Assistant
OV
Official Veterinarian
Salmonella
Salmonella spp.
VMP
Veterinary Medicinal Product
VWS
Ministry of Health, Welfare and Sports
WFSR
Wageningen Food Safety Research

Executive summary

This report describes the outcome of a virtual audit of the meat inspection systems governing the production of bovine and swine meat and meat products in Netherlands intended for export to Canada. Due to COVID-19 travel restrictions, the Canadian Food Inspection Agency (CFIA) conducted this audit remotely from February 15 to 24, 2021. As a consequence, findings of this audit were based on document review and interviews of representatives from Food Business Operator (FBO) and Competent Authority (CA). Lack of on-site visit to the establishments selected for this audit resulted in limited review of the implementation of the competent authority and FBO controls at each establishment.

The main objective of the audit was to verify if Netherlands continue to implement a meat inspection system equivalent to that of Canada, and if that system is capable of producing safe, unadulterated, and properly labelled meat products for export to Canada.

The audit scope included virtual visits to the central competent authority (CCA) headquarters and 3 slaughter establishments (1 bovine and 2 swine) located in different regions.

The audit covered activities within the following subject areas:

Overall, the audit results showed that the inspection systems continue to maintain a level of sanitary protection to ensure that products exported to Canada are safe, unadulterated and properly labelled. The audit report includes the conclusions and recommendations for the Netherlands to address the deficiencies identified during the virtual audit.

1. Introduction

1.1 Audit objective, scope, and methodology

The audit covered verification of activities within the following subject areas:

The CFIA auditors virtually reviewed the administrative functions of central competent authority. The auditors evaluated regulatory framework, oversight framework, enforcement framework, training framework, export controls and import controls. Lack of on-site visit to the establishments selected for this audit resulted in limited review of the competent authority and FBO controls at each establishment.

Table 1: summary of audit scope
Competent authority/establishment audit Number of sites audited Location
Opening meeting 1 Virtual (Skype)
Bovine slaughter establishment 1 Virtual (Skype)
Pork slaughter establishments 2 Virtual (Skype)
Closing meeting 1 Virtual (Skype)

1.2 Legal basis for the audit and audit standards

The CFIA conducted audit under the specific provisions of Canadian laws and regulations, in particular:

The audit standards also included all applicable EU regulations determined as equivalent as part of the agreement between the European Community and the Government of Canada on sanitary measures to protect public and animal health in respect of trade in live animals and animal products as amended from time to time as part of bilateral negotiations.

2. Competent authority and oversight

2.1 Regulatory framework

Netherlands is an EU Member State and is required to implement European Parliament and the Council adopted regulations. Regulation (EC) No. 178/2002 lays down the general principles and requirements of Food Law (general food law regulation). The key relevant EU regulations are:

The key relevant Netherlands regulations are:

Conclusion

The competent authority has a regulatory framework to ensure the planning development, and implementation of meat inspection systems.

2.2 Oversight framework

In Netherlands, the Ministry of Agriculture, Nature and Food Quality (LNV) and Ministry of Health, Welfare and Sports (VWS) play the key role in food and feed safety, animal health and welfare. The Netherlands Food and Consumer Products Safety Authority (NVWA) is the independent agency under LNV and VWS and acts as a Central Competent Authority. The NVWA is in charge of the organization and the implementation of official controls for the meat inspection system. The NVWA supports data management and information exchange between the national and local authorities in the area of food safety and consumer protection. As described in the article 109 of Regulation (EU) No. 2017/625, NWVA is also responsible to draw up and communicate the Multi-annual national control plans (MANCP) and annual reports to the European Commission and to the European Food Safety Authority (EFSA).

The supervision of the NVWA Official Veterinarian (OV) is performed by Senior Official Veterinarian. As audited, these visits at the establishment are performed but not recorded. The supervision of the slaughterhouse is under the responsibility of the OV. In Netherlands, large slaughterhouses are under NVWA permanent supervision of OV. However, the supervision in medium and small slaughterhouses can be completed without the permanent presence of OV. As described in the Regulation (EU) No. 2017/625 Article 18, the post-mortem inspection is performed by an Official Veterinarian, under the supervision of the OV (Official Veterinarian is present on the premises) or, where sufficient guarantees are in place, under the responsibility of the Official Veterinarian.

The post-mortem inspection in the slaughter establishments is performed by Official Auxiliaries (OA) employed by Kwaliteitskeuring Dierlijke Sektor (KDS). KDS is a non-governmental delegated body annually accredited by the NVWA to provide inspection services in accordance with NEN-EN-150/ISO 17020. A contract between KDS and NVWA details the inspection procedures to be performed by the OAs at the establishment based on a quality manual. The KDS employees performing post-mortem inspection are paid by the NVWA. In addition to post-mortem inspection, KDS employees support NVWA in microbiological and chemical residue sampling at slaughter establishments.

The NVWA completes the weekly supervision of work completed by KDS at slaughter establishments. The inspection and supervision data are recorded in NVWA IT database.

Conclusion

Government oversight of meat inspection system and communication procedures between different levels of authorities and non-governmental delegated body is in place as described in the Regulation (EU) No. 2017/625. However, the supervisory visits by the Senior Official Veterinarian at the slaughter establishments are completed but not recorded.

As audited, all slaughter establishments exporting to Canada are not under the permanent supervision of OV. In Canada, ante-mortem and post-mortem inspection must be performed by a veterinarian inspector or inspector under the supervision of a veterinary inspector as described in the Safe Food for Canadian Act article 139 (1)(2) and 149 (1).

2.3 Training framework

As stipulated in the Regulation (EU) No. 2017/625, the competent authorities must have access to a sufficient number of suitably qualified and experienced staff so that official controls and other official activities can be performed efficiently and effectively. The Dutch government and the NVWA has a training program, tailored to the requirements of their employees. The official personnel at the time of hiring receives training focussed on meat inspection system. The OV receives minimum continuing education every year in the areas of their duties at the establishment including the EU Better Training for Safer Food (BTSF).

The KDS is responsible for providing the training to the OA responsible for post-mortem inspection. Initial training of the OA is completed at the Butchers Vocational Training College, followed by the practical training at the slaughter establishments. As audited, training of OV and OA was completed as per the plan.

Conclusion

The central competent authority possesses an adequate framework to train human resources involved in the planning, development and implementation of meat inspection systems as required by the Regulation (EU) No. 2017/625.

2.4 Export controls

As stipulated in Regulation (EU) No. 2017/625 articles 86 to 88, official certification results in the issuance of official certificates and attestations necessary for the purposes of exporting consignments of animals and goods to third countries. The food and feed exported or re-exported from the EU for placing on the market of a third country shall comply with the relevant requirements of Food Law, unless otherwise requested by the authorities of the importing country or established by the laws, regulations, standards, codes of practice and other legal and administrative procedures as may be in force in the importing country.

As described in Regulation (EU) No. 2017/625, the NVWA has established procedures for establishment requesting for the approval to export. The establishment applies to the NVWA and must demonstrates the capacity to implement the third countries export requirements to obtain the registration number. The NVWA perform an annual verification of the implementation of the third countries export requirements but as audited checklist didn't include the verification of the Canada import requirements. As per Regulation No. 178/2002/EC article 12, the exporting country shall comply with the importing country's requirements. The NVWA Import and Export Team in the NVWA Division Design and Services is responsible for the development of export certificates and associated instructions and documents.

The NVWA also uses an export verification system called Export Canalization System (EKS). EKS is a voluntary governmental quality system based on off site export certification and random on-site spot checks of the establishments. The exporting establishment can apply to the NVWA to be part of the EKS certification system for specific commodities and/or to export to a specific country. An initial audit and then a yearly audit determines the frequency for NVWA on-site verification. The compliance history of the establishment determines risk based inspection rate (level 0 to level 6) with a minimum of 5% on-site inspection rate for compliant establishment to a 10% for a new establishment using EKS certification system. As audited, certification procedures for establishments operating under EKS do not include on-site visual verification of each consignment by the NVWA.

Conclusion

Adequate export controls and certification procedures are implemented to ensure that only eligible meat and meat products from approved establishments are exported to third countries including Canada. However, certification procedures for establishments operating under EKS do not include on-site visual verification of each consignment by the NVWA. Also, the annual verification of third countries export requirements didn't include Canada.

2.5 Import controls

As indicated in the Regulation (EU) No. 2017/625, the competent authority perform official controls at the point of entry regularly on animals and goods entering the European Union. As per the Netherlands 1935 Commodities Act, all goods entering in Netherlands from other Member States have to meet those standards/requirements and provide a level of protection that is at least equivalent to the level sought by the national requirements.

There are 7 border control posts (BCP) in Netherlands owned by private companies and under the supervision of NVWA. The NVWA's Import Inspection Department in collaboration with Dutch Customs is responsible for implementation of veterinary import and transit controls. The documentary, identity and physical checks are completed by NVWA. Microbiological and chemical residue sampling is performed as per the national import monitoring plan. The consignments can be accepted, detained or refused depending on the results of the NVWA verification.

Conclusion

Netherlands has established regulatory import controls for animals and animal products imported or transitioned from any third country as per EU requirements. No border control post was audited during this audit.

2.6 Enforcement framework

In accordance with the Regulation (EU) No. 2017/625 article 138, the NVWA is responsible to impose immediate interventions in response to the non-compliances. The Netherlands Commodities Act and general administrative and criminals law provide the legal powers and authority to NVWA to stop operations, request corrective actions and set deadline to resolve the observed non-compliance. The Intervention Policy for meat IB01-SPEC 25 is a guideline for the Official Veterinarian to identify the violations and categorise the non-compliances by class A (serious) to D (minor) based on the impact on safety or health of humans, animals or environment.

Conclusion

The competent authority has an adequate enforcement framework and legal authority to carry out the necessary official controls of the meat inspection system. As audited, violations and enforcement measures at each establishment were categorised and completed based on the NVWA Intervention Policy as stipulate in Regulation (EU) No. 2017/625.

3. Ante-mortem, humane handling and animal welfare controls

3.1 Traceability and animal identification

As per the Regulations (EU) No. 625/2017, No. 2075/2005 and No. 853/2004 annex 2 section III, the Food Business Operators must, as appropriate, request, receive, check and act upon food chain information in respect of all animals sent or intended to be sent to the slaughterhouse. The Member State is responsible for the day to day enforcement through their national legislation and control activities.

The Netherlands 2011 Animal Welfare Law requires that the animal must be identified and accompanied by a document including data related to the identification of animals. The NVWA Official Veterinarian is responsible to perform the verification of the operator controls and the accompanying documentation of the animals. At the receiving of animals, the operator and officials verify the transport document, the food chain document and the truck disinfection certificate. The transport document includes the information about the farm of origin, transporter and the animals. The food chain document contains information about the veterinary drug usage, associated withdrawal period and the attestation for free of chemical residues.

At the establishments audited, the operator has a written program that included that the animals has to be adequately identified at their arrival at the slaughterhouse. The cattle have to be individually identified using 2 ear tags and bovine passport, while the pigs were identified through a ear tag or a tattoo. The operators had a secure electronic system able to maintain the food chain information during the entire slaughter operations.

Conclusion

Animal identification and traceability controls are in place as stipulated in the 2011 Animal Welfare Law, the Regulations (EC) No. 2075/2005 and No. 853/2004.

3.2 Ante-mortem inspection

Netherlands follows the ante-mortem inspection requirements prescribed in the Regulations (EU) No. 2019/624, No. 2017/625 and No. 2019/627.

The NVWA OV conducts ante-mortem inspection for every truck load of live animals and accompanying food chain information documents as described in the Netherlands 2020 Netherlands guidelines "Physical assessment of animals for slaughter during the ante-mortem inspection of domestic ungulates and farmed game" K- RV-AM-WV04. The officials perform ante-mortem examination within 24 hours of animal's arrival at the slaughterhouse and less than 24 hours before slaughter. After the ante-mortem, the OV categorized the animals in 3 categories:

The category 2 and 3 animals are segregated, marked and entered in the system for further post-mortem examination.

Conclusion

Ante-mortem inspection controls are in place as stipulated in the Regulation (EU) No. 2017/625.

3.3 Humane handling and animal welfare

The Council Regulation (EC) No. 1099/2009 on the protection of animals at the time of killing (arrival, moving, and handling of animals) partly regulates the transport of animals related to operations at slaughter establishments. The EU Member States are responsible for the enforcement of animal welfare regulations.

The Netherlands 2011 Animal Law and Animal Welfare Law recognize the intrinsic value of the animal that must be protected from distress, pain, injury, illness, thirst and hunger. On a daily basis, the NVWA Official Veterinarian verifies the implementation of the FBO's humane handling procedures during the unloading of the animals, the ante-mortem inspection and periodically during operations.

As audited, the non ambulatory animals are not allowed to be moved and must be stunned and bled on the spot. The audited establishments have trained animal welfare officers responsible to implement the animal welfare program. The carbon dioxide and electrical stunning is used for stunning the pigs and penetrating captive bolt for cattle in the audited establishments. The Official Veterinarian performs daily inspection of the effectiveness of the stunning.

Conclusion

Animal welfare controls are present as stipulated in the Regulations (EC) No. 854/2004 and No. 1099/2009.

4. Slaughter and post-mortem

As per the Regulations (EU) No. 2019/624 article 9 and No. 2017/625 article 17, post-mortem inspections and auditing activities are essential to protect human health, animal health and animal welfare. The post-mortem therefore remain under the responsibility of the Official Veterinarian. Certain tasks may be carried out by the Official Auxiliary provided sufficient guarantees are met for these objectives and if certain criteria and conditions are complied with.

The KDS OA perform post-mortem inspection under the supervision of the NVWA OV. At medium and small slaughter establishments, the post-mortem was completed by KDS OA without the physical presence of OV at the establishment. The post-mortem inspection consisted of an examination of carcasses, carcass parts, organs, tissues and lymph nodes, by means of observation, palpation, sense of smell, and incisions. The NVWA OV makes the post-mortem judgments using the guiding principles described in the guideline K-RV-PM-WV01 concerning the disposition of carcasses, carcass parts and organs for suspect animals detected at the ante-mortem by the NVWA and at the post-mortem by the KDS OA.

The commission decision of 29 June 2007 article 1 and the Regulation (EC) No. 999/2001 lays down rules for the prevention, control and eradication of Transmissible Spongiform Encephalopathies (TSEs) in animals. The World Organisation for Animal Health (WOAH; founded as Office International des Épizooties (OIE)) considered Netherlands as a country with negligible Bovine Spongiform Encephalopathy (BSE) risk status. The bovine slaughter establishment audited slaughtered cattle from Netherlands and a small percentage from Belgium that also have a negligible BSE status. The operator performed a food safety analysis control including SRM and the removal of the spine is monitor by a Critical Control Point (CCP).

Conclusion

Post-mortem inspection for bovine and swine were completed as per Regulation (EU) No. 2017/625. Post-mortem inspection in medium and small slaughterhouse was completed by KDS Official Auxiliaries without the presence of the Official Veterinarian at the establishment.

4.1 Antimicrobial controls

As stipulated in the Regulations (EC) No. 2015/1474 and No. 101/2013, the slaughter establishments in Netherlands can use antimicrobial aids such as steam vacuum or lactic acid application to reduce microbiological surface contamination on bovine and pork carcasses. As audited, the bovine and swine slaughterhouses are allowed but did not currently use any antimicrobial interventions.

Conclusion

Usage of antimicrobial aids is allowed in Netherlands by the Regulations (EU) No. 2015/1474 and No. 101/2013 but were not used in the audited slaughter establishments.

4.2 Chilling and freezing controls

The Regulation (EC) No. 853/2004 lays down chilling requirements applicable to domestic ungulates and poultry. During cutting, boning, trimming, slicing, dicing, wrapping and packaging, the Food Business Operator ensures the maintenance of meat at not more than 3°C for offal, 7°C for ungulates meat. The ambient temperature of the areas of 12°C or an alternative system must have an equivalent effect. However, meat may be boned and cut prior to reaching the temperature mentioned above when the cutting room is on the same site as the slaughter premises, provided that it is transferred to the cutting room either directly from the slaughter premises or after a waiting period in a chilling or refrigerating room.

Air chilling was used to cool down the bovine and swine carcasses. The core temperature of carcasses after chilling was less than 7°C before cutting. The Food Business Operator controlled chilling of carcasses via CCP. The competent authority verified the implementation of chilling controls at each audited establishment.

Conclusion

Chilling and freezing controls were in place as prescribed in the Regulations (EC) No. 852/2004 and No. 853/2004.

4.3 Water Retention Control Program

The EU and national legislation does not establish water retention requirements for bovine, swine carcasses and offal. As per the Canadian requirements, the FBO are responsible to develop a written Water Retention Control Program for carcass, parts and offal as per the Canadian requirements detailed in the Control Programs: water retention in edible raw red meat products.

Conclusion

The audited establishments didn't develop written and validated Water Retention Control Program as per the Canadian requirements.

5. Preventive control plans

The application of HACCP program and principles is a mandatory requirement for all establishments according to the Regulations (EU) No. 178/2002, No. 852/2004, No. 853/2004 and No. 854/2004. As stipulated in the article 5 of Regulation (EC) No. 852/2004, the Food Business Operators implement and maintain a permanent procedure or procedures based on the HACCP principles.

As audited, the NVWA completed the annual HACCP audit to verify the implementation of HACCP controls at the establishments. However, it was observed that the follow-up to minor non-compliances identified during annual HAACP audits was not documented. The CFIA auditors noted deficiencies related to elements of HACCP and prerequisite programs such as lack of employee flow diagram, and documented corrective actions as per CCP 1 (fecal contamination) written procedures in an audited swine slaughterhouse.

Conclusion

HACCP and prerequisite programs were generally implemented as stipulated in the Regulations (EC) No. 178/2002, No. 852/2004, No. 853/2004 and No. 854/2004. However, deficiencies related to the implementation and official verification of HACCP and prerequisite programs were noted. Also, the follow-up of the minor non-compliances identified during annual HAACP audits was not documented.

6. Microbiological controls

As stipulated in the Regulation (EC) No. 882/2004, the competent authorities verify that food is safe and wholesome and that the criteria are met. The European Food Safety Authority (EFSA) monitors and analyses information and data on biological hazards, chemical contaminants, food consumption and emerging risks. The EU Member State has to follow the recommended number of microbiological sampling and submit results to the EFSA for publication.

The Netherlands national microbial sampling plan includes the testing of domestic and imported meat products. The distribution of the official microbiological samples is completed on the basis of the slaughter volume of each establishment. The results of the official samples are recorded in the laboratory system of the WFSR laboratory.

At the audited slaughter establishments, the carcasses and meat products were tested according the operator's sampling plan as per the annex 1 of the Regulation (EC) No. 2073/2005. In 1 swine establishment, the Salmonella sampling was not completed as per the written program.

At the bovine slaughter establishment, the operator implemented control measures and testing plan for E.coli O157:H7/NM in raw beef products precursor materials as per Canadian export requirement. The establishment used the N60 method for beef meat intended to be used in production of raw ground beef. However, written control program for the control of E. coli 0157:H7 at the audited bovine slaughterhouse didn't include the sampling methodology used and corrective actions to be taken in case of non-compliances.

As described in the Regulation (EU) No. 2015/1375 specifics rules on official controls for Trichinella spiralis in meat. As audited, every carcass is sampled for Trichinella spiralis in the swine slaughter establishments. The carcasses are tested and held until results are negative. The testing is completed by an external accredited laboratory and the results are sent to NVWA and FBO.

Conclusion

The slaughterhouse operators microbiological sampling was performed as per Regulation (EC) No. 2073/2005 except in 1 swine slaughter establishment where the Salmonella sampling was not completed as per the written program.

Written control program for the control of E. coli 0157:H7 at the audited bovine slaughterhouse didn't include the sampling methodology used and corrective actions to be taken in case of non-compliances.

7. Chemical residue controls

Netherlands implement chemical residue monitoring plans for the illegal use of substances, misuse of authorized veterinary medicines, and minimize residue recurrence in accordance with Council Directive 96/23/EC and 96/22/EC on measures to monitor certain substances and residues thereof in live animals and animal products. The maximum residue limit (MRL) for each substance in Netherlands are established as per Regulation (EU) No. 37/2010.

The EU Directive 2001/82/EC relating to off label use of veterinary medicinal products is followed by the Netherlands. This policy may only be applied in cases where there is no registered medicinal product for the species and indication in question. Unless the medicinal product used indicates a withdrawal period for the species concerned, the specified withdrawal period shall not be less than 28 days for carcasses and parts.

The prohibited substances are included in the Regulation (EC) No. 37/2010 table 2, the Directive 96/22/EC and implemented in Netherlands by the 2012 Netherlands Veterinary Product Decree. The Council Directive 96/23/EC and 96/22/EC requires the Netherlands to adopt and implement a national residue monitoring plan for specific groups of residues. Based on the slaughter volume of each commodity, the DG SANTE sends the number of samples to be collected and analyzed for each group.

The minimum number of animals to be sampled each year is based on the number of animals slaughtered the previous year, per commodities and per group of substances. The NVWA is responsible for the development and implementation of the National Residue Control Plan (NRCP). The sampling level and frequency depends on the slaughter volume per species, compliance history and the slaughter establishment participation in a quality assurance programme as per the Council Directive 96/23/E.

At each establishment, The NVWA is responsible to implement the NRCP as per the national monitoring plan. As audited, the NVWA OV or the KDS OA perform the sampling at each establishment. In case of suspect animal detected during the ante-mortem or post-mortem inspection, the carcass is identified, detained and the targeted sample is sent to the WFSR laboratory for analysis. In case detection of violative results over the MRL, the WFSR laboratory sent the results to the NVWA and triggers a follow-up at the slaughter establishment and farm of origin to determine the root cause as required by the Commission Delegated Regulation (EU) No. 2019/2090. Follow-up sampling, inspection at the farm and enforcement action is taken as per the requirements.

The CFIA reviewed the NRCP and results from 2017 to 2020. The Netherlands' NRCP include the number of samples, species, targeted tissues (matrix), points of sampling, substances for testing, and test analytical methods as prescribed in the European Commission's legal provisions to ensure wholesomeness of the meat products.

In Canada, the imported meat products from Netherlands are subjected to routine monitoring for chemical residues. The results are assessed and must comply with Canadian maximum residue limits. The maximum residue limits for veterinary drug in food are established by Health Canada.

Conclusion

The Netherlands NRCP is developed and implemented as described in the Regulations (EU) No. 2019/625, No. 37/2010, No. 396/200, No. 1881/2006. The monitoring system for residues and contaminants as stipulated in the Directive 96/23/EC.

8. Closing meeting

The closing meeting was held with representatives from Netherlands on February 24, 2021 via videoconferencing. At the meeting, a summary of the preliminary findings from the audit were presented by the CFIA lead auditor.

9. Conclusions

Overall, the audit results showed that the inspection systems continue to maintain a level of sanitary protection to ensure that products exported to Canada are safe, unadulterated and properly labelled. The audit report includes the conclusions and recommendations for the Netherlands to address the deficiencies identified during the virtual audit.

10. Recommendations

The recommendations are linked to the specific conclusions made during this report. Therefore, the competent authority should interpret each recommendation in conjunction with the conclusion listed in the table.

CFIA recommendation 1

The CFIA recommends that all establishment specific findings be corrected and verified in a timely fashion.

NVWA actions plans/comment 1

NVWA provides a response to CFIA recommendations for the operator's correctives actions and NWVA verification of the findings in the establishments audited.

CFIA recommendation 2

The CFIA recommends that:

The supervisory oversight performed by Senior Official Veterinarian be documented.

All establishments must be under permanent supervision of OV during the production of meat and meat products intended for export to Canada.

Follow-up to minor non-compliances identified during annual HAACP audits be documented.

NVWA actions plans/comment 2

In 2019, the NVWA developed a new method for supervisory oversight on NVWA inspectors in Teams Veterinary Inspection and Export Certification (VKE Teams) operating in slaughterhouses, including the Official Veterinarians. All these inspectors will be observed on-site on their performance with regards to the execution of supervisory tasks, with a frequency of at least once every 3 years. The observations will be carried out across the VKE Teams and the results will be documented in the form verification work of employees' in the database KIM. This form consists of 3 parts:

After the observation, agreements are made with a team leader on the follow-up on the results of the verification. The focus areas of the 3 parts have been translated and attached as annex 1. The method meets the ISO 17020 norm.

Due to the pandemic, this method was not implemented in 2020. By November 2021, all NVWA inspectors in VKE Teams will have received a training on the observation of colleagues working in slaughterhouses. The training is developed and provided by the Team Uniformity (under the Department Quality and Standardisation). From January 2022, the observations will be carried out.

The only small slaughter establishment (calves) without permanent supervision, with an export registration for Canada and this export registration has been withdrawn. This requirement will become part of an instruction (RE) that will be set up by the NVWA, which is used for the approval of establishments for export to Canada.

The NVWA will take the following actions in order to document the follow-up to minor non-compliances:

CFIA recommendation 3

CFIA recommends that:

Each shipment of meat and meat products for export to Canada be verified by the NVWA official.

The NVWA annual verification of third countries export requirements include the verification of Canadian export requirements.

NVWA actions plans/comment 3

The certification process of the EKS does not include on-site visual verification of each consignment by the NVWA, because the visual on-site checks are replaced by randomized on-site inspections. These randomized inspections are more thorough compared to the non-EKS on-site checks, since there is more time available.

However, all consignments exported from establishments operating under EKS are verified by NVWA veterinarians specialized in export from the Department of Remote Certification. These certifying officials have a lot of experience in the verification of export documents and check if all the certification requirements are met, before issuing the certificates. If necessary, the certifying officials request more evidence from the exporter to verify this.

EKS has been in operation for over 5 years and has proven very effective in supervising export certification. Many establishments are functioning well under EKS, and the ones that do not act according to EKS requirements, receive increased supervision or are removed from the system and placed under increased supervision.

Team ABB-1 will carry out Canada-export-inspections to verify if the Canadian requirements are met at establishments with an export registration for export to Canada.

The NVWA will set up an RE-instruction for the approval of establishments for export to Canada. This instruction will contain the Canadian export requirements that the establishments must comply with, as an addition to the requirements laid down by EU-legislation. These are the following:

All establishments exporting meat, meat products and offal to Canada must:

This RE-instruction will be used by Team Audit and Corporate Relations 1 (ABB-1) to verify if the establishments that already have (or apply for) an export registration for export to Canada, comply with the Canadian export requirements. This Canada-export-audit will be carried out by Team ABB-1 with a minimum of once every 3 years. For this inspections, Team ABB-1 cooperates closely with the Official Veterinarians in charge in the VKE Teams. Since 2021, results of these export-inspections are recorded in the system SPIN, and via this system, the frequency of these inspection is secured. Only establishments that fulfil the Canadian requirements, will maintain their export registration for export to Canada.

The establishments are currently developing a retained Water Control Program and implementation is foreseen before the end of this year. In order to set up the RE-instruction, the NVWA is analyzing the Canadian STEC-requirements to see which actions are necessary to fulfil these. The NVWA will share the RE-instruction after finalization. When the retained Water Control Program is implemented and the establishments have taken the actions regarding the STEC-requirements that might be necessary, Team ABB-1 will carry out the Canada-export-inspections, cooperating with the Official Veterinarians in charge in the VKE-teams.

CFIA recommendation 4

The CFIA recommends that all establishments exporting meat, meat products and offal to Canada have a written and validated retained Water Control Program for carcasses, parts and offal as described in the Canadian requirements Control Programs: water retention in edible raw red meat products.

NVWA actions plans/comment 4

At the moment, the establishments are developing a retained Water Control Program and implementation is foreseen before the end of this year.

Also refer to the NWVA response in the previous CFIA recommendation for the NVWA annual verification of third countries export requirements include the verification of Canadian export requirements.

CFIA recommendation 5

The CFIA recommends that HACCP and pre-requisite programs are implemented and monitored effectively to correct and prevent the deficiencies identified in this report.

NVWA actions plans/comment 5

Team ABB-1 and the VKE Teams will take the necessary actions to improve the monitoring on the implementation of these programs, to prevent the deficiencies that have been identified by CFIA.

CFIA recommendation 6

Provide MRL levels for trenbolone, nandrolone, thiouracil, decoquinate, pyrantel , diethylstilbestrol or other stilbene compounds.

Confirm if the use of trenbolone and nandrolone is accepted, in which species and at which dosage. Furthermore, provide details about the official and veterinary controls over the use of these veterinary products.

NVWA actions plans/comment 6

The action levels for the requested substances are laid down in annex 2 provided by NVWA.

The use of all the requested substances is not accepted. Therefore, MRLs do not exist and we use action levels.

The Netherlands runs a monitoring program where we monitor for veterinary products. Both illegal and legal substances are included in this monitoring program. Also the business runs so-called 'self-control programs'. In case non-compliance is detected (both in official controls or other controls), measures will be taken based on Commission Delegated Regulation (EU) 2019/2090.

Date modified: