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Final report of Virtual Audit of Chile's Meat Inspection Systems Governing the Production of Meat and Meat Products – February 14 to 28, 2022

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Abbreviations and special terms used in the report

CCA
Central Competent Authority
CCP
Critical Control Point
CFIA
Canadian Food Inspection Agency
CP
Control point
EIO
Team of inspection
ERP
Livestock Regional Officer
GMP
Good Manufacturing practices
HACPP
Hazard analysis and critical control points
LEEPP
List of exporting livestock-products facilities
MINSAL
Ministry of Health
MVIO
Official veterinary medical inspectors or also called MVO
NNC
Notification of non-compliance
PCR
National residues control program
SAG
Agricultural and Livestock Service
SOP
Standard Operating Procedures
SRIC
Regional Supervisor of Inspection and Certification
SSOP
Sanitation Standard Operating Procedure
TIO
Technical inspection officials

Executive summary

This report describes the outcome of a virtual maintenance audit of the meat inspection systems governing the production of bovine, swine, ovine and poultry meat and meat products in the Republic of Chile (Chile) intended for export to Canada. Due to COVID-19 travel restrictions, the Canadian Food Inspection Agency (CFIA) conducted this audit virtually from As a consequence, the findings of this audit were based on a document review and interviews of representatives from the Food Business Operator (FBO) and Chilean Agricultural and Livestock Service (SAG). The lack of on-site visits to the establishments selected for this audit resulted in a limited review of the competent authority and FBO controls at each establishment.

The main objective of the audit was to verify if Chile continues to implement a meat inspection system equivalent to that of Canada and if that system can produce safe, unadulterated, and properly labelled meat products for export to Canada.

The audit scope included virtual visits to the central competent authority headquarters and 5 slaughter establishments (2 bovine, 1 swine, 1 ovine and 1 poultry) located in different regions of Chile. The audited activities included the following subject areas:

Overall, the audit results showed that the meat inspection system, as audited continues to provide at least the same level of protection as that provided under the Safe Food for Canadians Act (SFCA) and Safe Food for Canadians Regulations (SFCR). The audit report includes the conclusions and recommendations for Chile to address the deficiencies identified during the virtual audit.

1. Introduction

1.1 Audit objective, scope, and methodology

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

The CFIA auditors virtually reviewed the administrative functions of central and regional competent authorities. The auditors also evaluated the regulatory framework, oversight framework, enforcement framework, training framework, export controls, and import controls. However, the lack of onsite visit to the establishments selected for this audit resulted in a 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 Locations

Opening meeting

Central and 4 regional authorities

 1 Virtual
Bovine slaughter establishments 2 Virtual
Pork slaughter establishment 1 Virtual
Poultry slaughter establishment 1 Virtual
Ovine slaughter establishment 1 Virtual
Closing meeting 1 Virtual

1.2 Legal basis for the audit and audit standards

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

The audit standards also included all applicable regulations determined as equivalent as part of the agreement between Chile 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

The key relevant law and regulations are:

Conclusion

The competent authority has a regulatory framework for planning, developing, and implementing meat inspection systems.

2.2 Oversight framework

Under Organic Law No. 18,755 (1988), the Agricultural and Livestock Service (SAG) is part of the Ministry of Agriculture. It is the central competent authority (CCA) for supporting the development of Chile's agriculture, forestry, and livestock industries by protecting and enhancing plant and animal health. In addition, the Ministry of Health (MINSAL) is responsible for the safety of all food products for human consumption. It has delegated the responsibility for meat and poultry inspection to SAG.

The oversight of Chile's meat inspection system consists of 4 levels: central, regional, sectorial, and establishment. The SAG Food Safety and Certification Department oversee 16 regional offices in Chile. The regional directorates of the SAG are responsible for supervising the performance of government veterinarians and inspectors to verify that the technical guidelines are implemented according to the instructions issued.

The regional director and the livestock regional officer (ERP) coordinate the sectorial offices. The ERP also supervises the regional supervisor of inspection and certification (SRIC). The SRIC oversees the slaughter establishments eligible to export by conducting periodic supervisory reviews, including administrative decisions and competency assessments of the official inspection personnel.

Each of the 66 sectorial offices in Chile has an Official Sector Veterinarian that provides administrative support to the Official Inspection Team (EIO) at the exporting establishments. In the establishment, the official veterinary medical inspectors (MVIO or MVO) and technical inspection officials (TIO) are supervised by the head of the inspection team officer (JEIO).

The CCA oversees the compliance and enforcement of national regulations and third countries requirements by evaluating the performance at the regional level. SAG verifies the implementation of the Canadian regulatory requirements in meat and poultry establishments certified by SAG as eligible to export to Canada. Additionally, SAG has oversight over the chemical residues and microbiology sampling plan and the laboratories that analyze products eligible to be exported to Canada. The Livestock Protection Division develops annually a quality control system (QMS) to assess the quality of work carried out by the SAG personnel at the regional and establishment level.

As audited, the personnel performed official verification tasks as per the frequency described in the guidance document D-PP-IT-003. However, the supervisory oversight was not completed as per the planned frequency of once every 4 months.

Conclusion

The government oversight was adequate for compliance with regulatory requirements for official controls of the food chain. However, the supervisory oversight was not completed as per the planned frequency of once every 4 months.

2.3 Training framework

Following Resolution No. 77 (2018), SAG Livestock Protection Division created an academy section responsible for the strategic implementation and maintenance of the national training framework. The SAG's academy section is responsible for developing employees' annual strategic training plan. SAG develops a yearly training plan based on the requirements of the different inspection teams related to meat inspection, food security, human resource management, and other procedures.

As audited, the training of inspectors and veterinarians was completed as per the annual training plan. The training records were kept at the establishment level.

Conclusion

The central competent authority possesses an adequate framework to train human resources involved in the planning, developing, and implementing meat inspection systems as required by Resolutions No. 77 (2018) and No. 5,631 (2020).

2.4 Export controls

SAG is responsible for the export certification and registration of the establishments that produce meat products for human consumption. As prescribed in Resolution No. 1,722 (2017), SAG maintains the List of Livestock Product Exporting Facilities (LEEPP), and export approval was provided upon verifying compliance with domestic and importing country requirements. SAG performs an annual inspection to verify the implementation of the Canadian requirements at establishments eligible to export to Canada.

Chile has a certification procedure D-CER-VCP-PP-007 for issuing or canceling the Animal Health Export Certificate (CZE). After the receipt of the application to export, the SAG official visually verifies all consignments using an export inspection checklist (F-CER-VCP-PP-004) and performs a document review before the issuance of the CZE. All information related to export certification was entered into the Export Certificate Registration System (SRCE).

The CFIA verified that the export certification at the audited establishments was performed as per the guidelines.

Conclusion

Adequate export controls and certification procedures are in place to export only eligible meat and meat products to Canada.

2.5 Import controls

The SAG Livestock Protection Division is responsible for assessing the country of origin and performing a recognition of the zoo-sanitary situation. The livestock facilities willing to export livestock products to Chile must be authorised by SAG. The general and specific sanitary requirements must be met as per the Official Zoo-sanitary Certificate issued by the country of origin.

Eligible livestock products can enter the country exclusively through the qualified ports (airport, seaport, land border crossing) under the oversight of the Ministry of Agriculture and the SAG.

Chile has established regulatory import controls for animals and animal products imported or transitioned from any third country as Decree No. 501 (2016). No border control post was audited during this audit.

2.6 Enforcement framework

As described in Resolution No. 1,045 (2012) article 32, the EIO at the establishments verifies the implementation of the Sanitation Standard Operating Procedures (SSOP), Good Manufacturing practices (GMP), Standard Operating Procedures (SOP), HACCP, and microbiological controls. The observation of non-compliance is recorded in the official non-compliance notice (NNC). The Non-Compliance Solution Report (ISNC) includes corrective and preventive actions the establishment takes in response to non-compliance.

Enforcement actions are taken in response to food safety or animal welfare non-compliances. Under Meat Law No 19,162, the enforcement actions include product seizure, suspension of the activities and the export certification, fine, and removal of establishment from the LEEPP. As audited, SAG officials completed enforcement actions and follow-ups as per the official requirements.

Conclusion

The competent authority has an adequate enforcement framework and legal authority to carry out the necessary official controls of the meat inspection system in case of non-compliance, as stipulated in Resolution No. 1,045 (2012).

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

3.1 Traceability and animal identification

The Resolutions No. 6,774 (2015) (red meat animals) and No. 8,203 (2015) (poultry) describe Chile's official program related to the traceability of the animals. All livestock farms must be registered in a traceability program and the official informatics system (SIPEC). SIPEC includes the origin, the date of birth, and the age of the animal. In addition, each farm is identified by a unique 9-digit number. Furthermore, all movement or transport of cattle, pigs, sheep, and poultry is accompanied by a record of animal movement form (FMA). The FMA contains the identification of the farm of origin, identification of the transporter, species, and the number of animals transported. Furthermore, animals are accompanied by Food Chain Report (ICA) containing information about the animal origin and production sites.

At the audited establishments, the operator implemented a written program to identify animals upon arrival at the slaughterhouse adequately. All these animals were individually identified using 2 ear tags, while the pigs and ovine were identified through an ear tag or a tattoo. The operators had a secure electronic system to maintain the food chain information.

Conclusion

Animal identification and traceability controls are in place as stipulated in Decree No. 30, Resolutions No. 6,774 (2015), and No. 8,203 (2015).

3.2 Ante-mortem inspection

SAG's official veterinarian and inspector conduct an ante-mortem inspection of animals at the slaughter establishments. The General Technical Standard No 62, paragraph IV describes the principles and objectives of the ante-mortem inspection in Chile. All the animals (100%) must undergo an ante-mortem inspection before slaughtering to determine their health status.

As audited, the local official personnel followed the ante-mortem procedures as described in the Instruction Circular No. 393 (2019).

Conclusion

Ante-mortem inspection controls are performed in slaughter establishments as stipulated in Decree No. 977 (1996) and the General Technical Standard No. 62.

3.3 Humane handling and animal welfare

Law No. 20,380 (2009) and the related Decrees No. 28, 30, 94, and 240 establish the rules for transport conditions and animal handling. General Rule No. 117 (2010) for poultry regulates the transport, handling, stunning effectiveness, and bleeding conditions.

As audited, the operators implemented a written animal welfare control program. The non-ambulatory animals are not allowed to be moved or dragged and must be stunned and bled on the spot following an adequate procedure. However, non-ambulatory hogs can be moved with a cart before stunning. The audited establishments have trained animal welfare officers responsible for implementing the animal welfare program. The carbon dioxide and electrical stunning were used for stunning the pigs and the birds, and mechanical stunning using penetrating captive bolt was used for cattle and ovine.

The official veterinarian is responsible for evaluating animal handling and stunning activities. The animal welfare verification results were recorded in Form F-PP-IT-032.

Conclusion

Animal welfare controls are implemented as stipulated in Law No. 20,380 (2009) and the related Decrees No. 2,8, 30, 94 and 240. Non-ambulatory hogs are allowed to be moved before stunning in contrast to the SFCR article 128 and 135 (1)(b).

4. Slaughter and post-mortem

4.1 Bovine, ovine and swine

The SAG official inspector (TIO) performs the post-mortem inspection under the supervision of the official veterinarian at the slaughter establishment. The post-mortem inspection includes an examination of identified carcasses, carcass parts, organs, tissues, and lymph nodes using observation, palpation, sense of smell, and incision. The TIO performs the post-mortem inspection as per the General Technical Standard No. 62.

As audited, carcasses and parts showing deviations at the ante-mortem and post-mortem are segregated from the evisceration line for a veterinary examination. The post-mortem inspection was recorded in the post-mortem report. The procedures to control fecal, ingesta, and milk were implemented as described in Chile Resolution No. 4,608 (2020). During each shift, the TIO completed a visual verification of carcasses at a pre-determined frequency.

4.2 Poultry

TIO conducts the post-mortem inspection under the supervision of the official veterinarian as described in General Rule No 117 (2010). The inspection includes the visual inspection of the external and internal surfaces of the carcasses and the display of their corresponding viscera. Fecal and ingesta contamination is controlled using a Critical Control Point (CCP) and a Control Point (CP).

As audited, post-mortem inspection was performed as per the regulatory requirements.

Conclusion

The TIO conducts the post-mortem inspection under the supervision of the official veterinarian as per General Technical Standard No. 62 (2002) and General Rule No. 117 (2010).

5. Microbiological controls

As stipulated in Standard No. 117 (2010) annex 2, antimicrobial aids such as chlorine and lactic acid are approved for use on poultry carcasses and offal. The audited poultry slaughter establishment used para acetic acid at a concentration of 150 ppm to 2000 ppm and was monitored using a CCP. Para acetic acid is permitted in Canada. However, it was not included in Chile's Standard No. 117 (2010) annex 2.

Audited swine, bovine and ovine establishments used antimicrobials on carcasses and parts as per Canadian standards.

Conclusion

Antimicrobials are utilized as per Chilean or Canadian standards. However, the poultry establishment used para acetic acid, which was not included in Chile's Standard No. 117 (2010) annex 2.

6. Chilling and freezing controls

As per Decree No. 94 (2008), slaughter establishments must have cooling chambers to refrigerate and maintain carcasses, meat products, and by-products that are fit for human consumption.

As audited, the cutting room temperature was adjustable and maintained at 12ºC or lower. Red meat carcasses were chilled to a temperature of 7ºC or lower before shipping. In the case of edible by-products, the temperature was maintained at 5ºC or lower. For poultry meat, the giblets were transported quickly to coolers at 2ºC or lower. After the evisceration process, carcass and offal parts waiting to be processed are kept at a maximum temperature of 4ºC. Air chilling was used to cool down the bovine and swine carcasses. The core temperature of carcasses after chilling was less than 7ºC before cutting. The food business operator controlled the chilling of carcasses via a CCP and a CP. The competent authority verified the implementation of chilling controls at each audited establishment.

Conclusion

Chilling and freezing controls are implemented as prescribed in Decree No. 94 and Decree No. 977 (1996).

7. Retained water control program

The water retention limits for refrigerated and frozen fowl carcasses are established by the Decree No. 977 (1996). In the poultry slaughter establishment, the air was used to chill carcasses. The establishment's retained water control program was officially verified every month.

The Chilean regulations do not establish water retention requirements for bovine swine and ovine carcasses and offals. As a result, audited bovine, swine, and, ovine slaughter establishments did not implement a written water retention control program for carcass, parts, and offal per the Canadian requirements detailed in the Canadian guideline Control Programs: water detention in edible raw red meat products.

Conclusion

The Retained water control program is implemented at poultry establishments. However, audited bovine, swine, and ovine slaughter establishments didn't implement a written water retention control program for carcass, parts, and offal as per the Canadian requirements detailed in the Canadian guideline Control Programs: water detention in edible raw red meat products.

8. Preventive control plans

Resolution No. 1,045 (2013) establishes that the operator of each establishment slaughtering, processing, and storing livestock products intended for human consumption and registered in the LEEPP must develop and implement a quality assurance system based on the principles of hazard analysis of control points (HACCP).

As audited, all establishments implemented a HACCP plan and pre-requisite program. The SAG performs monthly verification of the HACCP and pre-requisite programs at the establishment eligible to export meat products to Canada as per the established guidelines. The verification of the CCP and the associated monitoring and verification records was completed every week. Furthermore, SAG performed an annual HACCP assessment to meet the regulatory requirements.

However, the CFIA auditors noted that monitoring, verification, and preventive procedures for CCPs were not consistently documented and completed as per the written program.

Conclusion

HACCP and prerequisite programs are implemented as stipulated in Resolution No. 1,045 (2013). However, monitoring, verification, and preventive procedures for CCPs were not consistently documented and completed as per the written program.

9. Microbiological controls

The SAG is responsible for developing a microbiological control program and verifying compliance with domestic and importing countries requirements. The regional offices complete the distribution of the official microbiological samples as per the slaughter volume of each establishment.

All slaughter establishments implemented the microbiological control program for Salmonella and generic E. coli as per the Chilean requirements. However, in some audited establishments, the Salmonella sampling program didn't include a procedure for evaluating results. At another establishment, the number of generic E. coli samples did not reflect the written procedures. Similarly, another establishment's written procedure did not include an acceptable limit for generic E. coli.

The poultry establishment's written sampling program for generic E. coli and Campylobacter didn't reflect that sampling needs to be completed for export to Canada. At bovine slaughter establishment, sampling, testing, and follow-up for E. coli O157:H7 were completed per Canadian requirements. Furthermore, all carcasses at the swine slaughter establishment were tested for Trichinella spiralis. As audited, SAG officials verified that establishments had implemented a microbiological control program as per the domestic and importing country's requirements.

Conclusion

The microbiological control program was implemented per the established control programs and importing countries' requirements. However, deficiencies related to implementation of the microbiological control program were noted at some audited establishments, as identified in the report.

Furthermore, the poultry establishment's written sampling program for generic E. coli and Campylobacter did not reflect that sampling needs to be completed for export to Canada.

10. Chemical residue controls

Chile implemented the National Residue Control program (PCR) to monitor the illegal use of substances, misuse of authorized veterinary medicines, and minimize residue recurrence in live animals and animal products by Law No. 18,755. The SAG is responsible for designing and managing the PCR for livestock products annually. The regional authorities are responsible for implementing the PCR at the establishment level. The sampling frequency is determined per the EU Council Directive 96/23/EC annex IV for calculating the number of samples. All samples are analysed at laboratories accredited by the SAG Reference laboratory.

The regional supervisor assigns residue samples weekly to the MVIOs at the establishments eligible to export to Canada using the electronic Analysis Management System (SGA). SAG officials implement the PCR per the national monitoring plan at each establishment. In case a suspect animal is detected during the ante-mortem or post-mortem inspection, the carcass is identified, detained, and the targeted sample is sent to the laboratory for analysis.

At all audited establishments, samples were collected and analysed as per the plan, and appropriate follow-up was completed in response to non-compliance. It was noted that suspect carcasses sampled under chemical residue were allowed to enter the domestic market. However, establishments didn't have any written segregation program to segregate these carcasses to prevent their export to Canada.

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

Conclusion

Chile has implemented a residue control program (NRP) in accordance with Law No. 18,755. It was noted that suspect carcasses sampled under chemical residue were allowed to enter the domestic market. However, establishments didn't have a written segregation program to segregate these carcasses to prevent export to Canada.

11. Closing meeting

The virtual closing meeting was held with representatives from Chile on February 28, 2022, and the CFIA lead auditor presented a summary of the preliminary audit findings.

12. Conclusions

Overall, the audit results showed that the meat inspection system, as audited continues to provide at least the same level of protection as that provided under the Safe Food for Canadians Act (SFCA) and Safe Food for Canadians Regulations (SFCR). The audit report includes the conclusions and recommendations for Chile to address the deficiencies identified during the virtual audit.

13. Recommendations

The recommendations are linked to the specific conclusions made during this report

CFIA recommendation 1

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

SAG action plans/comments 1

The Service communicated to the regional teams, using Circular No. 457/2022, the draft report of the CFIA audit, requesting the lifting of the recommendations and findings communicated by the Canadian authority.

The authorized meat exporting establishments have corrected all the findings, and the Service has verified their compliance.

The supporting documents (corrective actions report and its annexes) for the recommendations and findings of each establishment were provided by SAG.

CFIA recommendation 2

CFIA recommends that the non-ambulatory hogs are not moved prior to stunning as per the Canadian SFCR article 128 and 135 (1)(b) to prevent avoidable suffering.

SAG action plans/comments 2

Chilean pork producers have modified their procedures to avoid unnecessary suffering of non-ambulatory pigs, based on the use of pistols with retained shank and electric pliers with amperage variation, according to the use regulated by national regulations and those of third markets. All the procedures described consider the protective working conditions for the employees since they handle dangerous tools.

The Service will verify compliance with the national procedures and Canadian regulations, generating Non-Compliance Notifications (NC) when applicable. The supporting documents (corrective actions report and its annexes) for the recommendations and findings of each establishment were provided by SAG.

CFIA recommendation 3

The CFIA recommends that all bovine, swine, and ovine establishments eligible to export meat and meat products 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.

SAG action plans/comments 3

The Service instructed, through Circular No. 150/2022, that the Canadian regulations regarding water retention in carcasses and offal must be complied with, incorporating the corresponding programs in the Quality Assurance Systems.

Each establishment producing pork, sheep and beef has carried out the necessary procedures to determine if there is water retention in carcasses and offal. The indicated procedures have been based on the CFIA guide "Control Programs: Water Retention in Edible Raw Red Meat Products".

The background information and the supporting documents (corrective actions report and its annexes) for the recommendations and findings of each establishment were provided by SAG.

CFIA recommendation 4

The CFIA recommends that monitoring, verification, and preventative procedures for CCPs be consistently documented and completed as per the written program.

SAG action plans/comments 4

The companies that presented the findings took corrective/preventive actions. In addition, the official inspection teams analyzed to determine that the monitoring procedures and results comply with the internal instructions for CCPs.

The background information and the supporting documents (corrective actions report and its annexes) for the recommendations and findings of each establishment were provided by SAG.

CFIA recommendation 5

The CFIA recommends that all poultry slaughter establishments that intend to export meat and meat products to Canada must implement a pathogen reduction program as per Canadian requirements.

SAG action plans/comments 5

SAG, based on the provisions of Exempt Resolution No. 2592/2003, carries out an official microbiological verification for Salmonella spp. in all slaughtering establishments of bovine, ovine, swine and poultry (chickens and turkeys) registered in the LEEPP. In addition, as established in the same regulatory framework, all slaughtering establishments registered in the LEEPP must implement a microbiological self-monitoring check to analyze the presence of generic E. coli (biotype I).

On the other hand, SAG carries out an official microbiological verification for Campylobacter spp. in all poultry slaughtering establishments (chickens and turkeys) registered in the LEEPP, with current authorization for the United States. However, through Circular No115/2022 dated February 7, 2022 (annex: General Recommendations 4), the scope of this official verification program for the Canadian market was extended to comply with its requirements.

The modifications to the abovementioned programs are described in the new version of the General Document for Microbiological Verification in Livestock Export Establishments, VMO (D-CER-VPE-PP-009_v04), which is in the process of being made official.

CFIA recommendation 6

The CFIA recommends that all the establishments exporting meat products to Canada implement a written segregation program to prevent the export of suspect carcasses sampled under a chemical residue monitoring program.

SAG action plans/comments 6

The Service, through Circular No. 572/2022 has instructed that all establishments authorized to export must generate and implement a procedure for the segregation and retention of carcasses and their products until the results of sampling are obtained in the case of suspicion of the presence of chemical residues. In addition, compliance with current Chilean regulations in this area has been strengthened.

The incorporation of this procedure into the quality assurance system was verified by the official service in all establishments authorized to export to Canada.

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