Final report of a maintenance audit conducted in Mexico to evaluate meat inspection systems governing the production of meat and meat products intended for export to Canada

February 19 to 29, 2024

On this page

• Abbreviations and special terms used in the report
• Executive summary
• 1 Introduction
  • 1.1 Background
  • 1.2 Audit objective, scope, and methodology
  • 1.3 Legal basis for the audit and audit standards
• 2 Competent authority and oversight
  • 2.1 Regulatory framework
  • 2.2 Oversight framework
  • 2.3 Training framework
  • 2.4 Export controls
  • 2.5 Import controls
  • 2.6 Enforcement framework
• 3 Ante-mortem, traceaibiltiy, humane handling and animal welfare controls
  • 3.1 Traceability and Animal identification
  • 3.2 Ante-mortem inspection controls
  • 3.3 Humane handling and animal welfare
• 4 Slaughter and post-mortem controls
• 5 Processing controls
  • 5.1 Antimicrobial controls
  • 5.2 Chilling and freezing controls
  • 5.3 Water retention control program
  • 5.4 Allergen control program
  • 5.5 Lethality controls
• 6 Preventive control plans
• 7 Microbiological controls
• 8 Chemical residue controls
• 9 Closing meeting
• 10 Conclusions
• 11 Recommendations

Abbreviations and special terms used in the report

CFIA

Canadian Food Inspection Agency

CCA

Central Competent Authority

CCP

Critical Control Point

CENAPA

National Animal Health Verification Services Centre

DETIF

Directorate of Federal Inspection Type

DGIAAP

Director General of the Agri-Food, Aquaculture and Fisheries Safety

EU

European Union

FSIS

Food Safety and Inspection Services

GMP

Good Manufacturing Practices

HACCP

Hazard Analysis and Critical Control Points.

MVRATIF

Authorized Veterinary Medical Officials

MRL

Maximum residue limit

MVO

Official Medical Veterinarian/Veterinary Medical Official

NOM

Mexican Official Standard.

NRCP

National Residue Control Program

NRTE

Non-ready-to-eat

OTM

Over thirty months

OV

Official Veterinarian

PCP

Preventive Control Plan

RTE

Ready-to-eat

SADER

Secretariat of Agriculture and Rural Development

SENASICA

National Service for Sanitary, Food Safety and Food Quality

SIS

Computer Supervision System

SOP

Standard Operating Procedure

SSOP

Sanitation Standard Operating Procedures (SSOP),

SRM

Specified Risk Material

STEC

Shiga toxin producing E. coli

TIF

Federal Inspection Type

USA

United States of America

USDA

U.S. Department of Agriculture

UTM

Under thirty months

Executive summary

This report describes the outcome of onsite maintenance audit of the meat inspection systems of Mexico governing the production of bovine, swine and poultry (processed) meat and meat products intended for export to Canada.

The Canadian Food Inspection Agency (CFIA) conducted an onsite audit of Mexico's meat inspection systems during the period of February 19to 29, 2024. The objective of the audit was to verify that the meat inspection systems governing bovine, swine and poultry (processing) meat and meat products in Mexico function in a manner determined to be equivalent to those of Canada, that is, producing meat products that are safe, unadulterated, and properly labelled. The evaluation focused on verification of activities within the following subject areas:

• competent authority and oversight
• ante-mortem, humane handling and animal welfare controls
• slaughter and post-mortem controls
• processing controls
• preventive control plans (PCP)
• microbiological controls
• chemical residue controls

Overall, the audit results showed that meat inspection systems governing the production of bovine, swine and poultry (processed) meat and meat products in Mexico are performing adequately as intended and generally demonstrates an acceptable implementation of controls over all areas in a manner equivalent to that of Canada. The audit report includes conclusions and recommendations for the SENASICA to address the deficiencies identified during the on-site audit.

1 Introduction

1.1 Background

Mexico is one of Canada's major trading partners and currently exports bovine, swine and poultry (processed) meat and meat products to Canada. From January 1, 2021 to April 18, 2023, Mexico exported meat products to Canada with a total value of approximately $330 Million.

The CFIA audited Mexico's bovine, swine, and poultry (processed) meat inspection systems from February 19 through 29, 2024. The audit began with an opening meeting held virtually on February 12 and 13, 2024 with the participation of representatives from the Mexico's Central Competent Authority (CCA) that is, National Service for Sanitary, Food Safety and Food Quality (SENASICA), CFIA auditors, and Canada's Embassy in Mexico.

In opening meeting, the CFIA presented the audit scope, objectives, audit methodology, regulatory authorities, and logistic requirements for onsite audit. SENASICA provided detailed information on various subjects of interest to the CFIA and presented the following information during the opening meeting:

• Overview of SENASICA organisation for meat inspection system including the Directorate of Federal Inspection Type (TIF)
• Inspection system for bovine, swine, poultry and animal welfare at slaughter
• Inspection ante-mortem, post-mortem and processing controls
• Official Laboratory Services, the National Animal Health Verification Services Center (CENAPA)
• Chemical residue monitoring control programs
• Microbiological monitoring control programs
• Oversight, training and enforcement framework, and export and import control programs and certification for products and by-products of animal origin
• Laboratories networks, surveillance, monitoring, and official sampling for generic Escherichia coli (E. coli) in bovine and porcine carcasses
• Official sampling plan for Shiga toxin producing E. coli (STEC) in raw bovine meat products
• Official sampling for Listeria monocytogenes (L. monocytogenes) and Salmonella for sampling ready-to-eat (RTE) meat products.

Prior to on-site audit, the CFIA's Meat Import and Systems in Food Import and Export Division completed a document review of Mexico's meat inspection system. At the time of audit, following meat products can be exported from Mexico to Canada:

• bovine (Mexican and foreign origin) – raw and processed, canned
• swine (Mexican and foreign origin) – raw and processed, canned
• poultry (imported from approved sources only) – raw and processed
• broths/bouillon cubes, flavours and meat extracts prepared from CFIA-approved sources and export of beef pork and processed poultry meat products to Canada

In 2019, the CFIA conducted audit of Mexico's meat inspection systems including initial audit of caprine and ovine meat inspection system and provided its recommendations. The CCA submitted an action plan which was accepted by CFIA, but it didn't include corrective actions to rectify the CFIA findings observed at the audited caprine and ovine slaughter establishment. Therefore, the CFIA was unable to conclude that Mexico's caprine and ovine meat inspection system was equivalent to that of Canada.

In 2023, Mexico again expressed interest in exporting caprine and ovine meat and meat products to Canada and requested CFIA to resume work on recognition their inspection systems for these species. The CFIA clarified to Mexico CCA that documents review, and an onsite audit will be required to complete the evaluation of caprine and ovine meat inspection systems. However, in November 2023, the CCA confirmed that the caprine and ovine slaughter establishment is no longer interested to export caprine and ovine meat to Canada and withdrew their request for recognition of caprine and ovine systems.

1.2 Audit objective, scope, and methodology

The audit verified meat inspection system activities within the following subject areas:

• competent authority and oversight
  • regulatory framework
  • oversight framework
  • training framework
  • export controls and import controls
  • enforcement framework
• ante-mortem, humane handling and animal welfare controls
  • traceability and animal identification
  • animal movement controls
  • ante-mortem inspection
  • humane handling and animal welfare
• slaughter and post-mortem controls
• processing controls
  • antimicrobial control
  • chilling/freezing controls
  • water retention control program
  • allergen control program
  • lethality treatment
• preventive control plans
• microbiological controls
• chemical residues controls

The CFIA auditors reviewed administrative functions SENASICA at one of the regional/state supervisory offices. The auditors evaluated the implementation of regulatory framework, oversight framework, enforcement framework, training framework, export controls and import controls. During the audit, the CFIA auditors reviewed the documents, observed onsite conditions and activities, and interviewed the competent authorities and establishments officials. In addition, the CFIA also verified the implementation of SENASICA corrective actions to 2019 audit recommendations. The representatives from the CCA accompanied the auditors throughout the audit.

1.3 Legal basis for the audit and audit standards

The CFIA audited Mexico's meat inspection systems under the specific provisions of Canadian food safety and animal welfare laws and regulations, in particular:

• Safe Food for Canadian Act and Regulations
• Health of Animals Act and Regulations

The CFIA audited Mexico's inspection systems in a manner consistent with conventional program delivery standards to assess the degree to which inspection activities performed by the CCA were in alignment with the Mexican and Canadian regulatory and procedural requirements and specifications.

2 Competent authority and oversight

2.1 Regulatory framework

In Mexico, the regulatory framework consists of acts, regulations, notices, orders, and official standards that regulate meat inspection systems and animal health controls. It is mandatory for the central and regional food safety and animal health authorities to implement the Mexican regulatory framework that regulate the food safety and animal health programs.

The Federal Animal Health Act and Regulations govern the slaughter of animals and processing of products of animal origin for human consumption, animal welfare, good livestock production practices applicable to primary production and Federal Inspection Type (TIF) establishments. This is the key piece of legislation underpinning Mexico's authority over food safety and animal health and welfare. The Ministry of Agriculture, Livestock and Rural Development issues the Mexican Official Standards (NOM) under the Federal Animal Health Act. The key relevant NOMs, agreement and laws that regulate meat inspection systems including animal welfare are:

• NOM-008-ZOO-1994 establishes the zoo sanitary specifications for building and equipping establishments for slaughtering animals and those dedicated to industrializing meat products and 1997 and the Draft Amendment of the Mexican Official Standard NOM-008-ZOO-1994.
• NOM-009-ZOO-1994 establishes the sanitary meat processing standards.
• NOM-033-SAG/ZOO-2014 approves the methods for slaughtering domestic and wild animals in slaughter establishments.
• Mexican Official Standard NOM-130-SSA1-1995 establishes the food packed in hermetically sealed containers subjected to thermal treatment, sanitary determinations, and specifications.
• NOM-120-SSA1-1994 establishes services, hygiene and safety practices for processing food, non-alcoholic and alcoholic beverages.
• Agreement DOF 09/10/2014 allows establishing the criteria to determine the maximum limits of toxic and contaminating residues, of the operation of analytical methods, the National Program of Control and Monitoring of Toxic Residues in goods of animal origin, aquaculture and fishery resources, and Program of Monitoring of Toxic Waste in animals, as well as the consultation module, which are regulated by the Secretariat of Agriculture, Livestock, Rural Development, Fisheries and Food. In addition, this agreement allows the competent authorities to issue official letters for the updates or specific requirements of the countries with which Mexico has a commercial relationship.
• NOM-O51-ZOO-1995 governs the humane treatment of animals during transportation.
• NOM-033-ZOO-1995 governs the humane sacrifice of domestic and wild animals.
• Professional Career Service Law governs the mandatory training of veterinarians

2.2 Oversight framework

Under administration of SENASICA, the Mexico's meat inspection systems function at central, state/regional and establishment levels. The SENASICA is an administrative body of the Secretariat of Agriculture and Rural Development (SADER) and administers the overall inspection services. In SENASICA, the Directorate General of the Agri-Food, Aquaculture and Fisheries Safety (DGIAAP) supervises the Directorate of TIF establishments (DETIF). The DETIF provides direct oversight to the TIF establishments that produce meat and meat products for domestic and international market. The mission of SENESICA is to regulate, manage and promote the health, safety and agri-food quality activities and reduce the inherent risk in agriculture, livestock, aquaculture, and fisheries for the benefit of producers, consumers and industry.

There are 32 states in Mexico. At state level, the state supervisors work directly under the supervision of DETIF. The state supervisors supervise the establishments and are responsible for verification of export requirements, enforcement actions, and pathogen reduction and chemical residues sampling programs. The state supervisor visits unannounced and randomly monthly as per the Mexican regulatory requirements.

The SENASICA team at TIF establishments consists of Official Veterinarians (OV)/Official Medical Veterinarians (MVO) employed and paid by SENASICA. In addition, team at TIF establishments also consists of Authorized Veterinary Medical Officials (MVRATIF) contracted by a third-party organization and paid by the operator. The MVRATIF works under the direct supervision of the OV/MVO and performs all inspection tasks except signing off the export certificates. The OV/MVO signs off export certificates.

The MVO performs the inspection and verification tasks related to the production and processing of meat and meat products. In addition to MVO, the MVRATIF also carry out daily inspection activities. These activities are ante and post-mortem inspection, and monitoring and verification of Good Manufacturing Practices (GMP), Preventive Control Plan (PCP), Sanitation Standard Operating Procedures (SSOP), and conducting official sampling and export verification activities.

The DGIAAP, through the DETIF, develops and implements a Computer Supervision System (SIS) that documents evaluation and verification of food safety and animal welfare control programs to minimize food safety risks. The SIS methodology is based on an annual documentary verification of all risk mitigation programs and an onsite verification of control programs throughout the year.

The SIS is made up of 6 operating codes and each of these codes has an operating procedure for MVO assigned to the TIF establishments to carry out the daily inspection/supervision activities and verification of the processes. State Supervisors and MVO/MVRATIF document these activities by completing various SIS forms specific to implementation of different components of meat inspection system at TIF establishments.

During onsite audit, the CFIA noted that OV/MVO/ MVRATIF are present on-site and perform ante and post-mortem inspection, assess food safety compliance and issue certificates at bovine and swine slaughter and red and poultry meat processing establishments. The OV assigns tasks to veterinarians who perform ante-mortem/post-mortem inspection and other inspection activities (daily/weekly inspections, sampling etc.) under OV supervision. The CCA/State Supervisor ensures that sufficient numbers of veterinarians are present at slaughter and meat processing establishments.

The CFIA also noted that SENASICA has a direct administration system that governs the central directorates and the central directorate DETIF and regional/state supervises establishments responsible for food safety and animal welfare controls. The CFIA further noted that DETIF State Supervisors completed supervisory oversight controls consistently at the minimum prescribed frequency of every month at the audited establishments.

During the audit, the CFIA verified the oversight and supervision of the regional office and audited TIFs governed by the corresponding State Supervisor. There are procedures in place to avoid conflict of interest between the public and contracted veterinarians. For example, MVRATIF employees work under direct supervision of OV/MVO and are not permitted to sign off the export certificates.

2.3 Training framework

The article 27 of the Federal Animal Health Regulations governs training programs and promotes exchange of technologies or scientific advances in the field of Good Livestock and Manufacturing Practices, Operational Procedures Standard for Sanitation, Hazard Analysis and Control of Critical Points (HACCP) and the Traceability System in TIF establishments.

Under the Article 240 of the Federal of Animal Health Regulations, the SENASICA develops and executes the annual training program for official veterinarians, state supervisors and central office personnel. This program is instrumental in determining the training needs and establishing priorities for inspection officials. Its objectives are to acquire and enhance scientific and technical knowledge and skills of inspection staff at TIF establishments.

As stipulated in the Federal Animal Health Act and Professional Career Service Law, the MVO and the state supervisor must receive at least 40 hours per year of continuing education and must undergo an evaluation of their professional abilities at least once every 5 years. The MVRATIF must complete at least 16 hours of continuing education per year for obtaining a new authorisation provided by SENASICA which remains valid for 2 years.

Some in-class and online courses are available for general training for all employees, while others are specific based on staff roles and responsibilities. The list of training topics includes but is not limited to animal welfare, food safety and HACCP system, Shiga-like Toxin producing Escherichia coli (STEC), sponge sampling and N60 sampling, food safety management, and importing country requirements (USA, Canada, Chile, European Union). Additional training courses include implementation and application of sanitary and phyto-sanitary measures, food safety and risk assessment and management, bovine and swine slaughter, and ante- and post-mortem inspection. The competent authority maintains the training records of its employees at each establishment or regional office, or central headquarters office.

As audited, CFIA auditors reviewed training records of MVO and MVRATIF and noted that the SENASICA employees performing inspection activities at the audited TIF establishments and regional office completed the training requirements as per their training program. Online webinars and in class training tools were available to maintain employees' field of competence up-to-date. Continuous education and training were available for all inspection staff. SENASICA also assessed the competence of its employees and contracted veterinarians after receiving training. The CFIA auditors observed that SENASICA planned and executed annual training program for SENASICA or contracted inspection staff as per their regulatory training framework.

2.4 Export controls

Under the Federal Animal Health Act, it is mandatory for all bovine and swine slaughtering and meat products processing TIF establishments that trade products internationally must register with SENASICA. This registration remains valid for 5 years. Without registration, no establishment can produce or perform processing activities to generate products of animal origin for export. For international trade of animal products, the registered establishments must meet the specific sanitary requirements of the importing countries.

To export meat and meat products internationally, the operator submits electronically request to SENASICA for the issuance of export certificate. Thereafter, SENASICA's MVO reviews the documents and inspect the shipments, products and transport container and then issues export health certificate for TIF establishment if the products meet the importing countries requirements. MVO is responsible for control of the export health certificates and security of seals and stamps.

SENASICA establishes the shipping control and frequency as per the importing countries requirements and history of operator's compliance to regulatory requirements. As observed during audit, the state supervisor audited the establishments and carried out the verification of export controls at the prescribed frequency of once a month. MVO also verifies the export eligibility of the establishment and the information provided by the operator for the export certificate. MVO inspected 100% of export shipments and at least 10% of boxes for each export shipment. Before signing off export certificates, MVO performs the pre-loading onsite verification of the trailer and the product destined for export. The verification includes review of documents review, checking internal product temperature, and inspection of product condition and labelling and condition of the trailer.

The Canadian import requirements are electronically available to the MVO at TIF establishments. Additionally, SENASICA also sends email notifications about Canadian requirements to the state supervisors. The product can be exported directly from the TIF establishment of origin or from an external TIF processing establishment. To move the product from the establishment of origin to another processing TIF establishment, a local MVO signed health certificate must accompany the shipment that includes the eligibility requirements for Canada. The establishment requests MVO for certification by email prior to shipment.

The CFIA also noted that the state supervisor communicated the updated Canadian import requirements to the MVO and operator via email, and SENASICA implemented export controls as stipulated in its regulations. However, the labelling requirements including those for the pre-packaged RTE or NRTE meat product destined for consumers in Canada were not implemented at some of the audited establishments as stipulated in the the Canadian requirements, Food labelling for industry and bilingual food labelling requirements. Additionally, CFIA also observed the inconsistency in the verification of annual validation of operator's water retention control program by SENASICA.

2.5 Import controls

SENASICA is responsible for negotiating certification and import requirements. It assesses the foreign country's meat inspection system and approves the establishments eligible to export to Mexico. The SENASICA inspection staff is responsible for and carry out inspection of the imported products and live animals at their arrival at the points of entry, ports and airports as required by the articles 32 to 36 of the Federal Animal Health Act. The CFIA did not visit any border inspection points, ports or airports during this audit.

The audited TIF establishments did not import live animals for slaughter. The CFIA noticed that SENASICA consistently completed chemical residue sampling of imported meat and meat products for years 2021 to 2023 to verify compliance with the import requirements as prescribed in the Federal Animal Health Act. Mexico imports raw poultry meat from Canada or USA establishments eligible to export to Canada for further processing at their meat processing establishments and export the processed poultry meat to Canada.

2.6 Enforcement framework

The Federal Animal Health Act(article 1, 2, 167, 168 and 169) and the Federal Weights, Measures and Standardization Act authorise the SENASICA to sanction non-compliance related to meat production, and humane treatment of animals during slaughter and transportation. The MVO/MVRATIF have the legal authority to suspend or cease production and certification activities or detain animals and products if operators do not initiate or implement corrective actions to regulatory non-compliance.

Enforcement actions at establishments may result from the daily inspection activities of the MVO or from findings of SENASICA state supervisions. Briefly, MVO remains permanently at TIF establishment and conducts on-site verification of GMP. This is in addition to daily tasks related to export requirements, such as zero tolerance for faecal, ingesta or milk contamination, processing controls, final products standards (deboning and cutting) and export certification.

SENASICA is responsible for imposing immediate actions in case of non-compliance. The competent authorities prioritise corrective actions to eliminate or contain risks to human health and animal welfare depending on the level of non-compliance (minor, major or critical). The State Supervisor or the MVO verifies the compliance within deadlines and the efficiency of the corrective measures applied by the establishment. The supervisor supervises establishments and the MVOs at least once a month. However, the frequency can increase when there are risks to public health, animal welfare or when the result of supervision indicates the need.

Mexico enforces corrective actions in response to non-compliance detected with any food safety and animal welfare regulations.

The range of actions depends on the severity of regulatory non-compliance. In response to non-compliance, the local MVO and the State Supervisor initiate enforcement actions such as requesting corrective actions, setting timelines, issuing advisory and warning, imposing fines, seizure of the products, recall of products, suspension of export certification, and cancellation of registration or permit. Additional actions in the event of non-compliance include destroying of non-compliant products, limiting processing of products, declaring emergency or taking further administrative enforcement measures as needed.

The CFIA observed that the competent authority has a regulatory enforcement framework in place to carry out the necessary official controls at slaughter and meat processing establishments in Mexico. SENASICA at central level via the state supervision and local MVO, implements the enforcement framework and has a procedure in place to escalate the repetitive non-compliances to the higher management level from local to central level to mitigate risk.

As audited, the competent authority implemented enforcement measures at each establishment as per Mexican regulations. The CFIA, however, noted that SENASICA need to strengthen the oversight and enforcement activities in the wake of multiple preventive control plan issues as mentioned in the establishment specific findings.

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

3.1 Traceability and animal identification

The Federal Animal Health Act provides legal basis for the implementation of traceability systems for animals and products of animal origin. SADER manages the registration of livestock production units and the National Livestock Census. Mexico has identification and traceability systems in place for cattle, swine, sheep, and goats. SENASICA issues a Certificate of Mobilization that must accompany all bovine and swine animals in Mexico during their movements. The traceability of products of animal origin within TIF establishments is ensured through records, batches, identification numbers, bar codes, electronic devices and other elements that can identify the source of all animals, products, raw materials, ingredients or processing and packaging materials in the establishment.

SENASICA maintains national database for animal traceability called National Cattle Individual Identification System (SINIIGA) as per NOM001-SAG/GAN-2015. Ear tags are used to identify bovine individually. The individual identification is a unique and permanent number assigned to the animal (birth or at importation) and remains active until death or slaughter of animal. Ear tags are destroyed once the cattle die or are slaughtered. Pigs are identified by farm of origin. Every farm is registered and has a a designated number. Day of slaughter is used as the lot number in the establishments for traceability purpose.

As audited, Mexico has functional traceability and animal identification system in place. There is georeferenced system in Mexico, developed by the National Organisation for Agri-food Certification (ONCA), can lead to the farm of origin for traceability purpose. After receiving animals at the slaughter establishment, bovine and swine meat and meat products were identified by documents as a lot number for traceability purposes.

The CFIA also observed that all cattle and hogs arrived at slaughter establishments with appropriate documentation and identification as required by the Mexican regulations and importing countries. The auditors reviewed the Certificate of Origin of Animal, Certificate of Animal Movement/Mobilization and a Certificate of Disinfection for livestock transport vehicles that accompanied animal shipments.

3.2 Ante-mortem inspection

Under NOM-009-ZOO-1994, it is mandatory that the MVO or MVRATIF performs ante-mortem inspection of animals and verifies the Certificate of Origin of Animal, Certificate of Animal Movement/Mobilization and a Certificate of Disinfection. The Sanitary Inspection Manual for the TIF slaughter establishments describes the ante-mortem inspection procedures.

The veterinarian reviews the information in the accompanying documents and visually inspects cattle and hogs in the truck during unloading and movement to the pen. The animals must remain in the pens for a period to allow them to rest prior to ante-mortem inspection. The veterinarian (MVO or MVRATIF) segregates animals showing deviations into a suspect pen for further inspection. A veterinarian must examine the animals within 24 hours of arrival at the slaughterhouse and less than 24 hours before slaughter and re-inspect the animals after 24 hours if the operator delays slaughter activities. The veterinarian fills out the ante-mortem form with data concerning origin and ante-mortem inspection results and determines the suitability of animals for slaughter, signs off the ante-mortem form and recommend to the operator to schedule the slaughter before the animals move to the stunning area.

During the audit, the CFIA interviewed MVO/MVRATIF and verified records of ante-mortem inspection and monitoring and verification of the animal shipment accompanying documents by the veterinarian at the audited bovine and swine slaughter establishments.

3.3 Humane handling and animal welfare

The Federal Animal Health Act supplements NOM-051-ZOO-1995 establishing the standards for humane treatment of animals during transport and slaughter. In addition, Mexico implements NOM-033-SAG/ZOO-2014 for fasting, feeding, and watering of animals before slaughter. The animals should always have free access to clean and fresh water in abundance in the pens and be fed according to species when the rest period is greater than 24 hours. Animals remain in the rest pens for the periods of minimum time of 12 hours for swine and 3 hours for cattle before slaughter.

The veterinarian inspects animals for signs of distress and verifies animal welfare at slaughter via ante-mortem and stunning inspection and monitors bleeding at pre-determined frequencies as per regulations. The operators at the slaughter establishments have animal welfare officer responsible to develop and implement the animal welfare program. The operator segregates all suspect animals in suspect pen for further inspection.

All the audited slaughter establishments had an animal welfare program for animal receiving, emergency slaughtering, stunning and bleeding. The operators monitor animal welfare during transportation, unloading and movement through the receiving pens, stunning and bleeding. The veterinarian investigates and follows up on incidents of animal welfare non-compliance detected during transportation, handling and slaughter of animals and verifies operator and producer corrective actions.

As described in the NOM-033-SAG/ZOO-2014, the operator employs approved stunning methods using mechanical, electrical stunning or carbon dioxide techniques. As audited, the operator's animal welfare officer and SENASICA monitored the effectiveness of the stunning techniques daily.

SENASICA assesses and approves the establishment interested in slaughtering of cattle using ritual slaughter (slaughter without pre-slaughter stunning). For Kosher slaughter, the operator prepares and restrains the animal in a way that minimises the stress and allows access to its neck for ritual slaughter. Using a specialised sharp knife, a qualified Jewish slaughterer makes a single ritual cut on animal's neck for rapid bleeding and quick onset of unconsciousness. Alternatively, slaughterer can perform a kosher slaughter by a continuous back-and-forth movement of knife on the neck. These movements are required to push the knife deeper and cut both carotid arteries and jugular veins at the same time to achieve rapid blood loss and quick onset of death.

The CFIA visited an establishment slaughtering cattle using ritual slaughter for meat production and observed that the operator immobilized animal and its head well without causing distress and the Jewish slaughterer "rabbi at this establishment" performed the ritual cut by sliding the specialized knife continuously without interruption on the animals' throat cutting the animals esophagus, carotid arteries, and jugular veins. He made the complete cut without lifting off the knife from the animal's neck for another cut during back-and-forth movements of knife. The knife had straight blade whose length was at least twice the diameter of the animal neck. The rabbi sharpened the specialized knife using a specialized stone and verified knife sharpness before its use.

The CFIA also noticed that once the animal's throat cut was completed, animal bled for 30-60 seconds. If animal remained conscious after 60 seconds, operator stunned the animals using captive bolt. Operator's qualified staff monitored the animals for signs of sensibility or consciousness (eye reflex, free and loose tongue, vocalizing etc.). The operator monitored and SENASICA verified kosher slaughter at pre-determined frequency. The operator must continue to implement ritual slaughter controls as per the Canadian requirements as prescribed in the ritual slaughter without pre-slaughter stunning and its guidelines, and method of production claims on food labels.

As audited, the operator stuns and bleeds the non-ambulatory cattle, on-site without moving it. However, at both audited swine slaughter establishments, the operators did not stun and bleed the non-ambulatory pigs where they were lying, and rather carried such hogs in cart to the emergency stunning area at the slaughter floor. This is a non-compliance to Canadian requirements that require stunning and bleeding of the non-ambulatory animals onsite without moving them. The CFIA also noted that a hog's legs were protruding out of the truck's side railing when truck arrived at the slaughter establishment.

During 2019 audit, CFIA had noted that the operator did not stun and bleed the non-ambulatory pigs onsite at the audited swine slaughter establishment. Despite the guarantees provided by SENASICA in its action plan, CFIA noticed similar deficiency at two of the audited swine slaughter establishments during 2024 audit.

4 Slaughter and post-mortem controls

In Mexico, NOM-009-ZOO-1994 governs the slaughter and post-mortem inspection of bovine and swine carcasses and parts. MVO or MVRATF approval is mandatory for commencement of slaughtering of animals. Physical presence of the MVO is mandatory to complete the post-mortem inspection at each bovine and swine slaughter establishment. The post-mortem inspection consists of an examination of carcasses, carcass parts, organs, tissues, and lymph nodes, by means of palpation, smell, incision, and visual inspection. The MVO is responsible for making decisions on the disposition of carcasses, carcass parts and organs to ensure wholesomeness and suitability of carcass and its parts for human consumption.

The MVO completes post-mortem inspection of 100% of the carcasses at each bovine and swine slaughter establishments. There are inspection stations in each establishment; one each for inspection of head and tongue, red and grey viscera, and carcass. In addition, the MVO examines the external and internal sides of the caudal and cranial parts of the carcass and corresponding lymph nodes. For a suspect animal detected at ante-mortem or during the post-mortem inspection, MVO identifies the carcass with a tag and segregates the corresponding viscera and head and rails out the carcass at the designated final inspection station. As audited, each slaughter establishment audited had such a station.

The operator identifies each carcass with a label that contains information about the lot and a sequential number for each carcass slaughtered. The operators and MVOs maintain correlation between the carcass, head, and viscera. The operators assign sequential numbers to identify each carcass prior to entry of the carcass into the evisceration floor. Operators enter these numbers in the Information Technology system. The operators monitor the correlation between the carcass, red/grey viscera, and head, while the MVO verifies the correlation.

The World Organisation for Animal Health (WOAH) recognizes Mexico as a negligible risk for BSE. Mexico's Procedures Manual for Identification, Removal and Disposal of Hazardous Materials for Specific Bovine Spongiform Encephalopathy defines Specified Risk Materials (SRM) and establishes a Standard Operating Procedure (SOP) for handling of SRM in bovine slaughter establishments. SRM for cattle aged 30 months or greater consists of:

1. Brain, cerebellum, skull, eyes, trigeminal ganglia, spinal cord, vertebral column (excluding the vertebrae of the tail, the transverse processes of lumbar and thoracic vertebrae and the wings of the sacrum), and lymph dorsal root of cattle 30 months or older.
2. Distal ileum of the small intestine and tonsils of cattle of all ages

SRM is inedible and prohibited for use as human food. Mechanical separation of beef for human consumption is also prohibited in Mexico. SRM must be removed from carcasses of cattle, and edible material to be separated and removed in accordance with the procedures prescribed in the SRM Manual.

TIF operators slaughter cattle only born and raised in Mexico. The operator verifies the age of the cattle at the head station and uses dentition to determine if the animal is under (UTM) or over 30 months of age (OTM). The operator identifies and segregates SRM. The operator is responsible for developing, implementing, and maintaining procedures regarding the management of SRM, while SENASICA through the MVO verifies compliance with the operators' procedures. The MVO performs SRM verification of 100% of the carcasses.

There is zero tolerance for fecal, ingesta and milk contamination on bovine and swine carcasses. The operator develops and monitors a critical control point (CCP) for feces, ingesta and milk at the end of the evisceration line prior to the final wash. The operator monitors 100 % of the carcasses before the end of the evisceration room. The MVO verifies the CCP for the zero-tolerance task after the operator.

As audited, MVOs completed the post-mortem inspection of cattle and hogs, while the operators and MVOs maintained correlation between the carcass, head, and red/grey viscera at the audited slaughter establishments. The CFIA also noticed that, in addition to SRM control, operators had functional zero tolerance CCP for fecal, ingesta and milk contamination on bovine and swine carcasses.

5 Processing controls

5.1 Antimicrobial controls

In Mexico, there is no specific regulation to regulate the use of antimicrobial processing aids for microbial intervention. However, operators use antimicrobial aids to reduce microbiological contamination on the surface of carcasses, half-carcasses or quarters in bovine and swine slaughterhouses. The use of antimicrobial aids depends on international norms and the export requirements of the foreign countries such as the EU, Canada and the USA.

The antimicrobial agents currently approved for use in Mexico are lactic acid, acetic acid, citric acid and peracetic acid. Operators use these agents for the final washing of carcasses at the end of the evisceration line and as microbiological control for products fallen on the floor. Additionally, the operators can also develop and implement non-chemical microbial control interventions (use of steam or hot water) in their preventive control plan to reduce bacterial loads from carcass surfaces as per Canadian requirements.

As audited, the operators control the concentration of the antimicrobial agents during operations as a control point and conduct concentration titration at pre-determined frequency. However, the CFIA observed that operator did not include the use of peracetic acid in the SOP for offal chilling at one of the swine slaughter establishments. The CFIA also noticed that the operator conducted validation of lactic acid use but conducted no validation of peracetic acid and citric acid used on parts at one of the bovine slaughter establishments.

5.2 Chilling and freezing controls

As per NOM-008-ZOO-1994, the meat products intended for freezing must be stored at a minimum room temperature of -18°C and those intended for cooling must be stored in chambers between 0 and 4°C. Both freezing and cooling temperatures must be in the prescribed ranges during the storage and distribution chains. At the audited establishments, operators implemented the chilling and freezing controls as per the requirements. The MVO verified the operator's records for temperature of chillers and freezers used to store carcasses and meat products. However, the CFIA noticed that freezer temperature was higher than required temperature of -18°C at one of the red meat and poultry meat processing establishment.

5.3 Water retention control program

The Mexican regulations do not require validation and implementation of water retention control program for bovine and swine carcasses and parts. As, audited, the operators develop, implement, and validate the water retention control program as export requirements of the foreign countries such as Canada. The auditors observed the use of air chilling in the bovine and swine slaughter establishments and washing of offal with water during offal harvesting operation. The CFIA noticed that the operator used water to wash livers during harvesting but did not validate water retention control annually for offal at one of the bovine slaughter establishments. At another bovine slaughter establishment, the operator's water retention control program for carcasses and offal did not require annual validation. The operator started annual validation in 2023.

The common processing steps like final carcass wash, offal washing using water during harvesting, and the use of antimicrobial solutions for microbial intervention have a potential to promote the retention of water in carcasses and offal. The Canadian requirements require slaughter establishments to complete the annual validation of retained water control in carcasses, offal and edible parts meant for export to Canada. Therefore, the operators must develop and implement retained water control programs for carcasses, parts and offal in all TIF establishments exporting meat to Canada as per the Canadian requirements as prescribed in the Canadian control programs: water retention in edible raw red meat products. OV/MVO must carry out an annual verification of the implementation of water retention control procedures in carcasses and their parts meant for export to Canada.

5.4 Allergen control program

As stipulated in article 214 of the Regulations of the Federal Animal Health Law, TIF establishments must have controls for raw materials and additives that are used for the processing of goods of animal origin and that contain allergens. For processed animal-source products, the establishments must comply with the NOM-051-SCFI/SSA1-2010 which stipulates that all ingredients or additives that cause hypersensitivity, intolerance or allergy must be declared in accordance with the legal provisions.

The "Mexican Manual of Inspection and Verification of the Food Safety System for the Official Inspection Personnel" establishes the verification requirements at the exporting TIF establishment. SENASICA personnel must verify the compliance of the establishment with the requirements including allergens and their labelling procedure and records in compliance to the NOM-009-ZOO-1994.

As audited, the operator's list of allergens included all Canadian priority food allergens. The operators include allergens in the list of ingredients on the label for meat products to be exported to Canada. Operators implement the allergen control program adequately and SENASICA verifies it at the audited establishments.

5.5 Lethality controls

Lethality treatments refer to the thermal treatment applied to a meat product to achieve a reduction in the viable pathogenic organisms. The Mexican regulations (Federal Animal Health Act and NOM -008-ZOO-1994) and the United States Department of Agriculture (USDA)'s Food Safety and Inspection Services (FSIS) guidelines on heat treatment describes the requirements that apply to ready-to-eat (RTE) food placed on the market for human consumption. These requirements relate to heat treatment (temperature-time) used to cook a processed meat product and prevent the product from becoming contaminated during the process. Additional requirements are control of temperature, pressure, sealing and microbes as per international standards. The operator must complete the quality control check for temperature and pressure internally via validation of the autoclave or cooking device and externally by third party every year.

The CFIA audited an establishment producing and exporting to Canada a RTE meat product called "Chashu". The CFIA reviewed the operator written cooking and cooling program and controls used for RTE meat products sealed in plastic containers. The heat treatment for cooked meat product reaches an internal temperature of 105°C for at least 90 minutes. Thereafter the product is cooled down to 25°C within 1.5 hours followed by further cooling to less than 4°C within 4 hours. The SENASICA verifies the implementation of operators written program for cooking and cooling of RTE meat products. For Trichinella spiralis control, operator instantly cooks the pork RTE products at internal temperature of 75°C. TIF establishments eligible to export to Canada supply the raw pork to the audited establishment.

The CFIA also visited another establishment processing and exporting 3 non-ready-to-eat (NRTE) poultry meat products to Canada namely chicken wings, frozen seasoned chicken strips and frozen breaded seasoned chicken breast chunks. The operator implements USDA's FSIS guidelines for temperature – time combination for cooking treatment and performs risk-based Listeria and Salmonella sampling for these products and validates thermal process controls. Operator monitors and verifies cooking step using a CCP. The Canadian or the USA poultry slaughter establishments eligible to export meat to Canada are the only source of the poultry meat used for these products. During the audit, the CFIA noticed that all 3 products are NRTE and labelled as cooked/fully cooked which implies as RTE.

The operators must follow CFIA Food labelling for industry guidelines in order to reflect the accuracy of NRTE or RTE and their applicable validated cooking or heating instructions respectively.

In addition, for RTE products, operator must follow Canada's Control measures for Listeria monocytogenes in RTE products for sampling and testing, and conduct testing of L. monocytogenes in an accredited laboratory.

6 Preventive control plans

As per chapter II, article 18 of the Federal Animal Health Act, the TIF establishments must conduct risk analysis, and establish critical control points, operating procedures, and sanitation standards. Additionally, under NOM-008-ZOO-1994, it is mandatory for the TIF establishments to maintain pre-requisite programs for premises, sanitation, labelling, receiving material, water potability, pest control, and equipment maintenance. The establishments must have self-control programs for HACCP plans and pre-requisite programs. Self-control programs must cover animal welfare, when applicable, GMPs, SSOPs and HACCP, and be recognized by SENASICA. These programs and procedures are mandatory for all animal slaughtering and processing establishments for food of animal origin whose products are destined for export to Canada.

The operators establish and implement different components of HACCP and pre-requisites program in slaughter and processing establishments. They also maintain written sanitation SOPs for daily sanitary activities and sanitation records before and during the production process.

The SENASICA ensures satisfactory levels of compliance with Mexican requirements by verification of HACCP and pre-requisite programs. The CFIA auditors conducted a pre-operational sanitation review at a slaughter establishment. The auditors noted that the MVO verified sanitation of establishment once operators completed their pre-operational sanitation procedures and determined if the establishment met the sanitation standards to start operations. The MVO verified establishments' pre-operational sanitation procedures daily prior to start of operations as per SENASICA's established procedures.

The CFIA auditors noted various deficiencies related to different elements of HACCP and prerequisite programs at slaughter and processing establishments. These deficiencies included condensation over the exposed meat and meat products in deboning and slaughter areas, rusty overhead structures, and railing in various areas of establishments, broken floor and paint flake coming off walls in slaughter and deboning areas and worn-out meat conveyer/contact surfaces.

The CFIA also observed gaps between the door and floor at shipping/material receiving/waste removal areas, meat pieces and debris on the floor in the various areas of establishments, incomplete implementation of annual mock recall exercise and inconsistent monitoring of implementation of good GMPs. At 2 audited establishments, operators did not identify the physical or chemical hazards for the receiving or incoming raw meat. At another establishment, HACCP manager did not verify the training record of the training completed by employees.

7 Microbiological controls

Under the Federal Animal Health Act, SENASICA develops and implements the microbiological control program for TIF establishments producing edible products and by-products of animal origin. SENASICA's State Supervisor and MVO verify if establishments comply with the microbiological criteria and food safety standards defined in the national legislation. The program is risk-based and considers data from previous years controls. SENASICA also implements USDA's FSIS standards and guidelines to supplement Mexico's microbiological sampling plan and specimen testing methodology. Mexico's microbiological controls include self-monitoring by the food business operators and official sampling by SENASICA.

The CFIA auditors observed that the MVO received official annual microbiological sampling plan from SENASICA via State Supervisor to collect the required microbiological samples from TIF establishments for analysis at accredited laboratories. In addition, all TIF establishments eligible to export to Canada implemented a microbiological control program to meet the requirements of the importing countries. Both operators and officials implemented the sampling plan and these requirements to maintain market access.

At the establishments visited, the CFIA noticed that the operator tested carcasses and meat products on a daily, weekly, or monthly basis following the FSIS sampling frequency specific to the type of product. The sampling of bovine and swine carcasses were completed for generic E. coli and Salmonella spp. using sponge method as per FSIS frequency. Specimens were tested at ISO 17025 or equivalent standards accredited laboratories. In case of non-compliances, the laboratories notified the concerned MVO, State Supervisor, and operators. The follow-up actions might include suspension of the export certification, conduct root cause analysis, and initiate appropriate corrective actions.

As audited, both operators and SENASICA implemented the microbiological sampling and testing plan as designed for 2023 and 2024 (in progress) at swine slaughter establishments. SENASICA completed microbiological sampling for 2023 with a compliance rate of 100% at audited establishments. The operator microbiological sampling was also up to date for 2024 at the audited establishments. Mexico employed FSIS USDA method MLG 4.10 to test specimens from swine carcasses for Salmonella spp. Responsible parties communicated the sampling plan and test results as per program requirements. A system of regulatory corrective actions and verification was in place to respond to non-compliant Salmonella testing results.

The meat and meat products derived from bovine that are considered as precursor material for the preparation of finished raw ground meat and were tested for the presence of E. coli O157:H7/NM as per Canadian Control Measures for Escherichia coli O157:H7/NM in Raw Beef Products. Officials samples were tested at the National Center for Animal Health Monitoring Services (CENAPA) or third party ISO/IEC:17025 accredited laboratory. The testing laboratory used the USDA's FSIS molecular methodology MLG 5C.03 to test the E. coli 0157:H7/NM in beef trims samples. In addition to SENASICA sampling, the operator also completed the beef trims sampling for E. coli O157:H7/NM and tested the samples at ISO accredited in-house or third-party laboratory.

However, at one of the bovine slaughter establishments, the in-house laboratory was not ISO accredited where operator tested the beef trims using FSIS molecular methodology (BAX Real-Time PCR Assay for E. coli 0157/STEC). In addition, the operator of this establishment neither tested the ground beef for E. coli 0157 nor established the lot definition for E. coli 0157 not exceeding 4500 Kg as per Canadian requirements.

As audited, the RTE products processing and producing TIF establishment implemented microbiological sampling plan for both meat products and the environment. The operator completed sampling for L. monocytogenes and Salmonella for all type of meat products and E. coli 0157:H7 for bovine meat products. The product remained at the establishment until receipt of negative results. The operator also completed environmental and food contact surface sampling at the frequency of 3 samples a month for the detection L. monocytogenes and Salmonella. The MVO verified operators' compliance to implementation of L. monocytogenes and Salmonella sampling plan and pathogen reduction program (5 samples per month).

In addition, the SENASICA also developed and implemented official microbiological sampling plan annually for RTE at red and poultry meat processing TIF establishments. The targeted micro-organisms included E. coli O157:H7, Shiga-like toxin producing E. coli (STEC), L. monocytogenes and Salmonella spp.

For microbiological controls, Mexico must meet the Canadian microbiological requirements for E. coli O157, Salmonella in raw breaded chicken products and RTE meat products, and Listeria monocytogenes in RTE foods.

For Trichinella spiralis controls in Mexico, it is mandatory for the primary producers to provide a certificate that the hogs supplied to slaughterhouses are free of Trichinella. Operator inactivated the Trichinella by freezing the carcasses. Additionally, the operator conducted surveillance for Trichinella and completed 100 samples per day from 100 hogs supplied by different farms. Operator pooled the samples and sent over for laboratory analysis by muscle digestion method. No positive samples were detected at the audited swine slaughter establishments.

8 Chemical residue controls

Under Mexico's 2022 Federal Animal Health Act and Agreement, SENASICA is responsible for the implementation of national program for the monitoring and control of chemical residues (toxic residues and pollutants) in meat and meat products in Mexico. These regulations authorise SENASICA to establish a National Residue Control Program (NRCP) for products of animal origin. In addition, the Agreement also authorises the SENASICA to establish maximum residue limits (MRL) of toxic substances and pollutants in products of animal origin, and performance of analytical methods. Furthermore, the EU Regulation 2022/1644 and Codex Alimentarius: Veterinary Drug Residues in Food, 2nd. edition, volume 3 (1994) are additional considerations for the NCRP and annual sampling plan in Mexico.

The objective of NRCP is to monitor livestock and slaughter establishments to verify that animal products intended for consumption do not contain chemical substances beyond the permitted limits or action levels. The NRCP covers sampling for monitoring and investigative/targeted purposes and includes collection of samples from slaughtered and live animals according to an annual schedule specified for establishments in various regions of the country.

The number of samples depends upon the previous year slaughter volume, species type and compliance history. The central office of SENASICA develops and send sampling schedule to the State Supervisors for onward transmission to establishment. The MVO and MVRATIF perform the sampling at establishment as per the sampling plan, while CENAPA laboratories conduct testing and analysis. SENASICA conducts root cause analysis and complete appropriate follow-up in response to the non-compliant results.

Clenbuterol is banned substance and must not be used in food producing animals in Mexico and Canada. However, SENASICA reported consistent violations for clenbuterol in cattle, swine and ovine for 3 years (2020 to 2022). The CFIA reviewed SENASICA's root cause analysis and preventive control measures for the use of clenbuterol in bovine and swine production. As per Federal Animal Health Act, it is crime to use clenbuterol in animals and the offenders can be penalised a jail term up to 6 years. There is another federal regulatory agency in Mexico that conducts trace back investigation for the use of clenbuterol and penalise the users. However, bovine and swine production, which may be associated with use of clenbuterol, is out of SENASICA's State Supervision jurisdiction. SENASICA is working closely with TIF establishments to encourage the animal producers to supply clenbuterol free animals. The CFIA observed that SENASICA is undertaking initiatives and preventive measures to the best of their abilities within their jurisdiction to control the use of clenbuterol in food producing animals in Mexico.

In Canada, the CFIA conducts inspection to monitor the presence of chemical residues in meat and meat products exported from Mexico to Canada. The meat products must comply with Canadian maximum residue limits for veterinary drug residues as established by Health Canada.

9 Closing meeting

The closing meeting was held virtually on March 07, 2024. The CFIA presented a summary of audit preliminary establishments and systemic findings.

10 Conclusions

Overall, the audit results showed that meat inspection system governing the production of bovine, swine, and poultry (processed) meat and meat products in Mexico performs as intended in an adequate manner and generally demonstrated an acceptable implementation of controls over all areas in a manner equivalent to that of Canada. The audit report includes recommendations below to address the deficiencies identified during the on-site audit.

11 Recommendations

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

CFIA recommendation 1

CFIA recommends that all establishment's specific findings to be corrected by the operators and verified by SENASICA in a timely manner.

SENASICA action plans/comment 1

SENASICA provided the establishment's specific corrective actions implemented by the operators and verified by SENASICA.

CFIA recommendation 2

SENASICA must provide evidence to guarantee that all swine slaughter establishments stun and bleed the non-ambulatory pigs onsite that is, where they are lying, in accordance with Canadian requirements.

SENASICA action plans/comment 2

SENASICA informed the establishments authorized to export to Canada of the requirements regarding on-site stunning of non-ambulatory animals through its Official Letter No. B00.04.01.-2396-2024. Instructions were also sent to official staff through Circular No. 0022-2024 to verify compliance with these requirements.

CFIA recommendation 3

The CFIA recommends that:

• operators using the antimicrobials during chilling/processing of carcasses, parts and viscera include those in their preventive control plans and conduct validation
• SENASICA verifies the implementation of these requirements in all establishments eligible to export to Canada.

SENASICA action plans/comment 3

SENASICA informed the establishments authorized to export to Canada of the requirements regarding the use of antimicrobials in their processes through its Official Letter No. B00.04.01.-2397-2024. Instructions were also sent to official personnel through Circular No. 0024-2024, to verify compliance with these requirements.

CFIA recommendation 4

The CFIA recommends that:

• all establishments exporting meat and offal to Canada have a written and validated water retention control program as per Canadian requirements.
• SENASICA consistently verifies the validated water retention control program implementation at all establishments exporting meat and offal to Canada.

SENASICA action plans/comment 4

SENASICA informed the establishments authorized to export to Canada of the requirements regarding the validation of all their processes to determine the need to establish a water retention procedure, which must be updated and maintained annually through Official Letter No. B00.04.01.1157-2024. Instructions were also sent to official staff through Official Letter No. B00.04.01.1159-2024, to verify compliance with these requirements.

CFIA recommendation 5

The CFIA recommends that:

• meat processing establishments eligible to export meat products to Canada must control and monitor the labelling of heat treated RTE or NRTE products and record the accuracy of category of products and their validated cooking or heating instructions as applicable on the labels as stipulated in the Food labelling for industry.
• for RTE products, operator also must follow Canada's Control measures for Listeria monocytogenes in RTE products for sampling and testing.
• operators must conduct testing of L. monocytogenes in an accredited laboratory.

SENASICA action plans/comment 5

SENASICA informed the establishments authorized to export to Canada of the requirements regarding product labeling through Official Letter No. B00.04.01.-2404-2024. Instructions were also sent to official personnel through Circular No. 0023-2024 to verify compliance with these requirements.

Additionally, a virtual meeting was held on October 17, 2024 with staff from all establishments authorized to export to Canada, supervisors and official veterinarians assigned to them, in which they were told that they must comply with and verify compliance with the microbiological requirements of the products according to the process category to which they correspond.

CFIA recommendation 6

The CFIA recommends that SENASICA:

• strengthen the official oversight and enforcement activities in the light of multiple audit observations regarding Operators' preventive control plans
• verify the Operators' development and implementation of preventive control plans effectively to correct and prevent deficiencies identified in this report (Section 6 and Annex 1)

SENASICA action plans/comment 6

SENASICA held a virtual meeting on October 17, 2024 with staff from all establishments authorized to export to Canada, supervisors and official veterinarians assigned to them, in order to convey the need to strengthen the preventive control plans of the companies, as well as to follow up on them punctually through their staff and to verify compliance with the scheduled dates by the official staff.

CFIA recommendation 7

The CFIA recommends that:

• operator's in-house lab must be accredited for testing of E. coli 0157 as per Canadian requirements
• ground beef must be tested for E. coli 0157 according to procedures described in the Canadian Control Measures for Escherichia coli O157:H7/NM in Raw Beef Products
• lot definition for E. coli 0157 exceeded 4,500 Kg, a non-compliance to Canadian definition. The exporting countries must meet the Canadian requirements of lot definition for control measures of E. coli 0157 in raw beef products
• all establishments exporting meat and meat products to Canada must meet Canadian microbiological requirements; E. coli O157, Salmonella in raw breaded chicken products and RTE meat products, and Listeria monocytogenes in RTE foods.

SENASICA action plans/comment 7

SENASICA informed the establishments authorized to export to Canada of the guidelines established by the CFIA for the sampling of E. coli O157/NM through Official Letter No. B00.04.01.-2362-2024. Instructions were also sent to official personnel through Circular No. 0021-2024, in order to verify compliance with these requirements.

Additionally, a virtual meeting was held on October 17, 2024 of this year with staff from all establishments authorized to export to Canada, supervisors and official veterinarians assigned to them, in which they were told that they must comply with and verify compliance with the microbiological requirements of the products according to the process category to which they correspond.