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1.0 Overview
In Canada, beef sold across provinces or exported must be produced by a licensed operator inspected by the Canadian Food Inspection Agency (CFIA). Examples of activities carried out by an operator include processing and slaughter.
Each operator is responsible for producing safe, properly labelled beef that complies with relevant laws. Each operator must also minimize food safety risks by:
- establishing and maintaining a Preventive control plan (PCP) and supporting records
- providing written documents and records to CFIA inspectors upon request
- developing and implementing corrective actions in a timely manner when issues are identified
- reporting any food safety issues to CFIA
The role of CFIA is to enforce federal laws under its mandate and verify that operator's develop and effectively implement controls to minimize potential risks. CFIA inspectors and veterinarians work together to assess industry compliance by overseeing activities related to:
- facilities, personnel and processes
- animal health and welfare
- slaughter processes
- raw beef processing
- ready-to-eat beef processing
- sampling and testing
In addition to direct observation of an operator's activities, CFIA inspectors review written procedures and plant documentation, such as:
- the PCP and records
- sampling data and test results
- sanitation records
- employee hygiene
- cooking temperatures
- export certificates
Contamination can occur at any point in the production process. Because contamination is not always visible to the naked eye, CFIA also collects its own samples, which are sent for testing to CFIA and other off-site laboratories. This is over and above any sampling and testing conducted by an operator and is done to verify the effectiveness of the operator's controls. CFIA conducts both random and directed sampling and testing:
- random sampling and testing is conducted to identify trends and gather information on the occurrence and levels of contaminants in food and on equipment
- directed sampling and testing is conducted to investigate suspected problems
When CFIA inspectors observe an issue or non-compliance, they quickly inform the operator and a Corrective Action Request is issued. When food safety may be at risk, CFIA requires the operator to take appropriate action in a specified time frame. In addition, inspectors may hold certain products and/or seize and detain non-compliant product. For issues that don't pose food safety risks, operators are usually given more time to correct the problem.
CFIA also has several enforcement options which can be used if an operator is not complying with relevant laws and/or has not made corrections effectively and/or by a specific deadline. These options include:
- suspending the operating licence
- issuing Administrative Monetary Penalties (AMPs) in some cases
- seizing and detaining non-compliant product
- recommending prosecution
If a food product needs to be recalled because it poses a health risk, the operator is responsible for removing it from the marketplace. CFIA verifies that the recalled products have been removed from store shelves.
2.0 The inspection process
2.1 Facilities, personnel and processes
Hazards
Various hazards in the environment and operational practices of facilities such as slaughter facilities or beef processing plants may be identified. These can include:
- outside sources of contamination (excessive dust, pests, etc.)
- airborne contamination (poor ventilation, condensation, etc.)
- contamination from poor personal hygiene and manufacturing practices (inadequately trained personnel, poor sanitation practices, etc.)
- inadequate temperature controls during manufacturing, transportation and/or storage of food products
- contaminated incoming products (ingredients, supplies, etc.)
- presence of physical hazards (metal, plastic, etc.)
Industry responsibilities
Each operator is responsible for managing hazards in the work environment and in its operational practices through a systematic approach which is detailed in their PCP. Some of the ways they do this are by:
- developing, implementing and maintaining a PCP and supporting records to identify and control food safety hazards within a plant
- developing, implementing and maintaining preventive controls as part of the PCP to assist in controlling the likelihood of introducing food safety hazards to the product through the work environment and operational practices. Such preventive controls must cover:
- premises (outside property, building, etc.)
- transportation and storage (purchasing, receiving, shipping, etc.)
- equipment (design, maintenance, etc.)
- personnel (good manufacturing practices, good personal hygiene, etc.)
- sanitation and pest control
- recall program
- operational (allergens, food additives, etc.)
- maintaining procedures for and records of monitoring activities and steps taken when an issue is identified
CFIA inspection
CFIA inspectors assess the effectiveness of an operator's PCP. Some of the ways they do this are by:
- reviewing and assessing a PCP when it first opens to determine whether the PCP is complete and implemented effectively as described
- reviewing the operator's records and observing effective implementation of the PCP to reassess that food safety hazards remain under control
- interviewing and observing plant personnel and processes
Compliance and enforcement
CFIA can use a number of compliance and enforcement options if an operator is not complying with relevant laws or has not made corrections effectively or by a specific deadline. These include:
- holding certain products
- seizing and detaining non-compliant products
- requiring the operator to correct issues or non-compliances in a specific time frame
- issuing a Corrective Action Request to the operator
- launching a food safety investigation to assess where a problem may have originated
- suspending the plant's operating licence
- issuing AMPs
- recommending prosecution
2.2 Animal health and welfare
Regulatory requirements
Federal regulations outline requirements for:
- animal health – animals must be healthy and free from disease before slaughter
- animal welfare – animals must be handled humanely before and at slaughter
- traceability – animals must be properly identified to be able to follow them from one point in the supply chain to another, which is important during an investigation
Industry responsibilities
Producers, transporters and operators of beef processing and/or slaughter plants are responsible for complying with animal health, welfare and certain traceability regulations. Some of the ways they do this are by:
- ensuring the humane treatment of animals during transportation, herding and stunning
- identifying and separating apart any animals not fit for slaughter, including injured or diseased animals
- ensuring animals are properly identified for traceability purposes
CFIA inspection
CFIA inspectors and veterinarians work together to verify an operator's compliance with animal health, welfare and traceability regulations. Some of the ways they do this are by:
- observing the animals' conduct and behaviour for any signs of disease
- verifying animal identification records and tags
- overseeing humane treatment of animals during herding and slaughter
Compliance and enforcement
CFIA can use a number of compliance and enforcement options if an operator is not complying with animal health, welfare and traceability rules or has not made corrections effectively or by a specific deadline. These include:
- identifying and removing any animal not deemed acceptable for slaughter
- requiring the operator to correct issues in a specified time frame
- issuing a Corrective Action Request to the operator
- suspending the operating licence
- issuing Administrative Monetary Penalties (AMPs)
- issuing AMPs
- recommending prosecution
2.3 Slaughter process
Hazards
Beef can become contaminated during the slaughter process. Some of the hazards include:
- bacterial contamination of the carcass during removal of hide and digestive tract
- bacterial cross-contamination during splitting of the carcass
- bacterial growth during chilling/aging of carcasses
- specific animal tissues at risk for Bovine Spongiform Encephalopathy (BSE) (spinal cord, brain, etc.)
Industry responsibilities
Each operator is responsible for managing hazards that may occur during slaughter. Some of the ways it does this are by:
- ensuring only clean animals are received at the slaughterhouse
- decontaminating carcasses with hot water and/or approved antimicrobial products
- removing any visible feces from carcasses
- continuously sanitizing equipment (knives, saws, hooks, etc.) during production
- implementing proper chilling procedures and maintaining proper temperatures for aging of carcasses
- maintaining records for potential recall and traceability purposes
- removing and managing specific animal tissues at risk for BSE
- sampling and testing carcasses
CFIA inspection
CFIA inspectors verify the effectiveness of an operator's controls during the slaughter process. Some of the ways they do this are by:
- inspecting or overseeing the inspection of carcasses and their parts
- ensuring that suspect carcasses are properly set aside for veterinarian examination
- observing the removal and handling of specific animal tissues at risk for BSE
- interviewing and observing plant personnel and processes
- sampling and testing carcasses to verify that the operator's controls are working
- reviewing test results as well as corrective measures taken when positive results are identified
- reviewing operator documentation and records, such as:
- the PCP and supporting records, including sanitation and chilling procedures
- monitoring records
- procedures for and records of steps taken when an issue is identified
Compliance and enforcement
CFIA can use a number of compliance and enforcement options if an operator is not complying with relevant laws or has not made corrections effectively or by a specific deadline. These include:
- directing the operator to trim or condemn parts of any carcass deemed not acceptable
- holding certain products
- seizing and detaining non-compliant products
- requiring the operator to correct issues or non-compliances in a specific time frame
- issuing a Corrective Action Request to the operator
- launching a food safety investigation to assess where a problem may have originated
- monitoring the effectiveness of a recall
- suspending the operating licence
- issuing an AMP
- recommending prosecution
2.4 Raw beef processing
Hazards
Beef can become contaminated during the processing stage, which includes de-boning, cutting of primal cuts such as steaks and roasts, and processing of trim and ground beef. Some of the hazards include:
- bacterial contamination of raw beef from the slaughter stage
- bacterial growth during processing and cooling of beef products
- bacterial growth during storage or transportation of finished product
Industry responsibilities
Each operator is responsible for managing hazards that may occur during the processing of raw beef. Some of the ways they do this are by:
- maintaining temperature of processing room to prevent bacterial growth
- sampling and testing beef products, including trim and ground beef
- implementing a detailed sanitation program, including employee/product traffic controls, employee hygiene and good manufacturing practices, and sanitizing processes
- conducting internal food safety verifications
- maintaining records for potential recall and traceability purposes
- managing contamination risks during storage and transportation of packaged products, including temperature controls
CFIA inspection
CFIA inspectors are present during the processing of raw beef to verify the effectiveness of the operator's controls. Some of the ways they do this are by:
- interviewing and observing plant personnel and processes
- sampling and testing products and food contact surfaces
- observing plant personnel sampling of product and food contact surfaces
- reviewing the operator's test results as well as corrective measures taken when positive results are identified
- reviewing operator documentation and records, such as:
- the PCP and supporting records, including procedures for sanitation, cooling and temperature controls, rendering, cooking and disposal
- monitoring records
- procedures for and records of steps taken when an issue is identified
Compliance and enforcement
CFIA can use a number of compliance and enforcement options if an operator is not complying with relevant laws or has not made corrections effectively or by a specific deadline. These include:
- holding certain products
- seizing and detaining non-compliant product
- requiring the operator to correct issues or non-compliances in a specific time frame
- issuing a Corrective Action Request to the operator
- launching a food safety investigation to assess where a problem may have originated
- monitoring the effectiveness of a recall
- suspending the plant's operating licence
- issuing AMPs
- recommending prosecution
2.5 Ready-to-eat beef processing
Hazards
Food can become contaminated during the processing of ready-to-eat products. Some of the hazards may include:
- cross-contamination on processing equipment/food contact surfaces
- Listeria monocytogenes growth during processing, including improper cooking, chilling, slicing and packaging
Industry responsibilities
Each operator is responsible for implementing control measures to manage hazards posed by processing ready-to-eat products. Some of the ways they do this are by:
- implementing a detailed sanitation program, including employee/product traffic controls, employee hygiene and good manufacturing practices, and sanitizing processes
- implementing procedures to effectively eliminate bacteria during processing (cooking, drying or canning)
- implementing procedures to effectively eliminate unsafe bacterial growth after the ready-to-eat beef products are packaged (antimicrobial agents, high-pressure pasteurization, etc.)
- sampling and testing ready-to-eat beef products and food contact surfaces for pathogens such as Listeria
- conducting internal food safety verifications
- maintaining procedures and records for potential recall and traceability purposes
- managing contamination risks during storage and transportation of packaged products, including temperature controls
CFIA inspection
CFIA inspectors verify the effectiveness of an operator's controls during the processing, storage and transportation of ready-to-eat products. Some of the ways they do this are by:
- interviewing and observing plant personnel and processes
- sampling and testing products and food contact surfaces
- observing plant personnel sampling of product and food contact surfaces
- reviewing the operator's test results as well as corrective measures taken when positive results are identified
- reviewing the operator's documentation and records, such as:
- the PCP and supporting records, including procedures for sanitation, cooling and temperature controls, rendering, cooking and disposal
- monitoring records
- procedures for and records of steps taken when an issue is identified
Compliance and enforcement
CFIA can use a number of compliance and enforcement options if an operator is not complying with relevant laws or has not made corrections effectively or by a specific deadline. These include:
- holding certain products
- seizing and detaining non-compliant product
- requiring the operator to correct issues or non-compliances in a specific time frame
- issuing a Corrective Action Request to the operator
- launching a food safety investigation to assess where a problem may have originated
- monitoring the effectiveness of a recall
- suspending the operating licence
- issuing AMPs
- recommending prosecution
2.6 Sampling and testing
Hazards
Sampling and testing is used by industry and CFIA as a method to verify that the operator's controls are working. Some of the hazards that testing can help identify include:
- bacterial contamination of products and food contact surfaces, such as:
- E. coli O157:H7 on carcasses, beef trim and other raw beef material used to produce ground beef
- Listeria monocytogenes on food contact surfaces or in ready-to-eat products
- chemical hazards, such as:
- agricultural and environmental contaminants
- veterinary drugs
Industry responsibilities
Each operator is responsible for implementing controls to manage the risks posed by bacterial and chemical hazards. Sampling and testing is an effective way to verify the effectiveness of those controls. Some of the ways they do this are by:
- sampling and testing beef trim and other raw beef material used to produce ground beef, to ensure the presence of E. coli O157:H7 is controlled (mandatory in beef slaughterhouses and beef processing plants)
- sampling and testing ready-to-eat products and food contact surfaces to verify the absence of Listeria monocytogenes (mandatory in plants producing ready-to-eat beef products)
- redirecting raw meat positive for E. coli O157:H7 to rendering, cooking or disposal
- tracking test results for possible trends and indication of a potential problem
- adjusting control measures throughout all stages of production when the number of positive E. coli O157:H7 results is higher than usual/expected
CFIA inspection
CFIA inspectors verify the effectiveness of the operator's controls through sampling and testing. Some of the ways they do this are by:
- sampling and testing beef trim and other raw beef material used to produce ground beef
- sampling and testing finished product before packaging
- sampling and testing food contact surfaces
- reviewing the operator's test results as well as corrective measures taken when positive results are identified
- verifying that the operator evaluates controls and procedures and takes corrective action (as necessary) when there is a higher-than-expected number of positive tests
- randomly sampling and testing for monitoring purposes (veterinary drugs, environmental contaminants, etc.)
Compliance and enforcement
CFIA can use a number of compliance and enforcement options if an operator is not complying with relevant laws or has not made corrections effectively or by a specific deadline. These include:
- holding certain product
- seizing and detaining non-compliant product
- requiring the operator to correct issues or non-compliances in a specific time frame
- issuing a Corrective Action Request to the operator
- launching a food safety investigation to assess where a problem may have originated
- monitoring the effectiveness of a recall
- suspending the operating licence
- issuing AMPs
- recommending prosecution
3.0 Risk-based strategy
The Canadian food supply is one of the safest in the world. However, because it is impossible to inspect every single food item that enters the marketplace, CFIA focuses its inspection activities in areas where risks are highest.
CFIA determines areas of highest risk based on a number of factors, including:
- scientific analysis of potential hazards that can occur at particular points in production
- previously identified risks associated with specific products
- a company's compliance history
- random sampling and testing that identifies levels of bacterial or chemical hazards in specific products
In addition to industry controls, CFIA oversight helps to manage potential risks. Consumers also play an important role in protecting themselves and their families by signing up on the CFIA website to receive food recall and allergy alert emails. Consumers should also follow safe food handling practices at home, including proper cooking, cleaning, chilling and separating practices.