On this page
- Abbreviations and special terms used in the report
- Executive summary
- 1. Introduction
- 2. Competent authority and oversight
- 3. Ante-mortem, humane handling and animal welfare controls
- 4. Poultry slaughter and post-mortem
- 5. Antimicrobial controls
- 6. Chilling and freezing controls
- 7. Retained water control program
- 8. Allergen control
- 9. Processing control program
- 10. Preventive control plans
- 11. Microbiological controls
- 12. Chemical residue controls
- 13. Closing meeting
- 14. Conclusions
- 15. Recommendations
Abbreviations and special terms used in the report
- ACFS
- National Bureau of Agricultural Commodity and Food Standards, Thailand
- AM
- Ante-mortem
- BLSC
- Bureau of Livestock Standards and Certification
- BQCLP
- Bureau of Quality Control of Livestock Products
- CA
- Competent Authority
- CCA
- Central Competent Authority
- CCP
- Critical Control Point
- CFIA
- Canadian Food Inspection Agency
- DG
- Director General
- DLD
- Department of Livestock Development
- FBO
- Food business operator
- GAP
- Good Agricultural Practices
- GMP
- Good Manufacturing Practices
- HACCP
- Hazard Analysis and Critical Control Points
- MRL
- Maximum Residue Limit
- OV
- Official Veterinarian
- PM
- Post-mortem
- RTE
- Ready-to-Eat
Executive summary
This report describes the outcome of an on-site maintenance audit of the meat inspection systems governing the production of poultry meat and meat products in the Kingdom of Thailand (Thailand) intended for export to Canada. The Canadian Food Inspection Agency (CFIA) conducted this audit from August 1 to 10, 2022. The findings of this audit were based on an on-site visit, document reviews, and interviews of representatives from the Food Business Operator (FBO) and Thailand Department of Livestock Development (DLD).
The main objective of the audit was to verify if Thailand continues to implement a meat inspection system equivalent to that of Canada and if that system is capable of producing safe, unadulterated, and properly labelled meat products for export to Canada.
The audit scope included visits to the central competent authority headquarters and 6 establishments (2 chicken and 4 duck) located in different regions of Thailand. The audited activities included the following subject areas:
- competent authority and oversight
- ante-mortem (AM), humane handling, and animal welfare controls
- slaughter and post-mortem (PM) controls
- processing controls
- preventive control plan
- microbiological controls
- chemical residue controls
Overall, the audit results showed that the Thailand meat inspection system as audited continues to provide at least the same level of protection as 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 Thailand to address the deficiencies identified during the on-site audit.
1. Introduction
The purpose of this audit was to verify if Thailand continues to implement a poultry meat inspection system equivalent to that of Canada and if the system is capable of producing safe, unadulterated, and properly labelled meat products for export to Canada. The last audit was conducted in 2007 resulting in the approval of the meat inspection system. Thailand exported over 6.5 million kilograms of poultry and meat products in 2021.
1.1 Audit objective, scope, and methodology
The audit covered the verification of activities within the following subject areas:
- competent authority and oversight
- regulatory framework
- oversight framework
- training framework
- export controls
- import controls
- enforcement framework
- AM, humane handling, and animal welfare controls
- premises registration, animal movement, identification, and traceability
- animal movement controls
- AM inspection
- humane handling and animal welfare
- slaughter and PM controls
- processing controls
- chilling/freezing controls
- water retention control
- preventive control plans
- microbiological controls
- chemical residues controls
The CFIA auditors 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. The on-site visit to the establishments selected for this audit was completed with the review of the competent authority and FBO controls at each establishment.
Competent authority/establishment audit | Number of sites audited | Locations in Thailand |
---|---|---|
Opening meeting (including central and regional competent authorities) | 1 | Bangkok |
Chicken slaughter, cutting and processing establishments | 2 |
Nakhon Ratchasima Lopburi |
Duck slaughter, cutting, and processing establishment | 1 | Samutprakan |
Duck slaughter and cutting establishment | 2 |
Bangkok Sa kaeo |
Duck-cutting and processing establishments | 1 | Bangkok |
Closing meeting | 1 | Bangkok |
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:
- Safe Food for Canadian Act (SFCA) and Safe Food for Canadians Regulations (SFCR)
- Health of Animals Act (HAA) and Health of Animals Regulations (HAR)
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
2.1 Regulatory framework
The key relevant DLD legislations in Thailand are:
- B.E. 2546 (2003): Proclamation on Residues Control Measures on Poultry Standard Farms
- B.E. 2548 (2005): Poultry Meat and Poultry Products Inspection regulation and implementation of Hazard Analysis Critical Control Points (HACCP) systems for slaughterhouses and meat processing establishments
- B.E 2551 (2008): Microbiological Criteria for Water and Livestock Products for Export
- B.E. 2554 (2011): Protection of poultry at farm
- B.E. 2554 (2011): Protection of poultry during transport
- B.E. 2554 (2011): Protection of poultry during slaughtering process
- B.E. 2557 (2014): Cruelty Prevention and Welfare of Animal Act
- B.E. 2558 (2015): Animal Epidemics Act
- B.E. 2559 (2016): Control of Animal Slaughter for Distribution of Meat Act
for the roles and responsibilities of the Minister of Agriculture and Co-operatives - B.E. 2560 (2017): Notification of Ministry of Public health No. 383 – "Labelling on Packaging" the labelling of Pre-packaged Food manufactured
- B.E. 2564 (2021): regulation of the DLD regarding the application and issuing good hygiene practices and HACCP certificates to establishments for export
Conclusion
The competent authority has a regulatory framework for the planning, development, and implementation of meat inspection systems.
2.2 Oversight Framework
The Department of Livestock Development (DLD) under the Ministry of Agriculture and Cooperatives is a National Veterinary Authority of Thailand. The DLD Bureau of Livestock Standards and Certification (BLSC) and the Bureau of Quality Control of Livestock Products (BQCLP) are responsible for the official controls on and export certification of poultry meat and poultry meat products before their export to Canada. The Export Product Certification Section of the Certification Subdivision activities to assure compliance of establishments with importing countries' requirements.
The DLD includes officers from central, regional, provincial, and district levels who provide services on animal health controls and veterinary public health controls and undertake disease surveillance programs in the country. Each region has the Regional Livestock Office. The controls of the DLD headquarters to the regional and local offices guarantee a harmonized system in the whole country. The line of command goes from the Director General of the DLD down to District Livestock Office. Administratively, Thailand is divided into :
- 9 livestock regions (9 regional livestock offices)
- 77 provinces (77 provincial livestock offices)
- 946 districts (928 district livestock offices)
The DLD oversees the compliance and enforcement of national regulations and Canadian requirements by evaluating the performance at the regional level. Additionally, DLD has oversight over the chemical residues and microbiology sampling plan and the laboratories that analyze products eligible to be exported to Canada. The DLD develops a quality control system (QMS) annually to assess the quality of work carried out by the DLD personnel at the regional and establishment level.
Annual audits are performed and recorded by the DLD committee to verify the overall operator controls and the implementation of the export requirements. A DLD supervisor performed a minimum inspection frequency of once a month in slaughterhouses and once a month in poultry meat product establishments. The DLD supervisor follows BLSC instructions for documenting and reporting.
As described in regulation 2548 (2005), the meat inspection in Thailand is performed by an official veterinarian (OV) that carries out official meat hygiene activities with the inspectors appointed and paid by the DLD to inspect poultry and poultry products.
As audited, the official verification tasks in the slaughter are carried out by the full-time presence of OV and inspection staff. At the poultry meat slaughter establishment, the inspectors conduct the AM and PM inspections under the supervision of an OV. The DLD inspector also conducts meat product inspection, export certification tasks, and official sampling of poultry meat products.
The performance of the meat inspector for the AM or PM inspection tasks inspection tasks is performed by the OV on a daily basis, if the OV observed deficiencies in the performance of the meat inspectors, the meat inspectors will be retrained. The OV reviews the overall performance of the meat inspector every 6 months is documented. At Poultry Meat Processing Plant, the inspectors under the supervisor of a veterinarian conduct sanitation tasks, critical control points (CCP) monitoring, Personal hygiene verification (personal protection equipment, hand-washing, and good manufacturing practices (GMPs)), traceability tasks, and evaluation of operators' HACCP implementation
A DLD supervisor supervises with a minimum frequency of once a month in slaughterhouses and processing establishments. The OVs have to send a monthly summary report to the supervisor at the central level on the official controls carried out by the OV. These reports also include production figures, official verification, and official sampling data, deficiencies during the month, and any corrective action plan implemented by the FBO.
The OV compiles and sends a monthly supervisory report which is submitted to the supervisor at the headquarters. These reports also include production figures, FBO's self-control monitoring data, official sampling data, deficiencies detected during the month, and any corrective action plan. Compliance, corrective actions, and actions by an official OV (for example warning, holding product/export certificate, proposing to suspend/delist) are recorded and reported to the supervisor and BLSC.
As audited CFIA verified that the DLD officials conduct and document the inspection activities as per regulation B.E. 2548 (2005).
Conclusion
The competent authority has an appropriate structure to provide government oversight at the intended frequency to verify that food safety standards are met for exporting poultry and poultry meat products to Canada.
2.3 Training framework
The appointment of DLD official a Veterinarian must possess a professional degree in veterinary science and complete the training in the examination of animal diseases and the examination of meat under the training programs accredited by the DLD. The training includes meat hygiene, HACCP, AM and PM procedures, regulations, and importing country requirements.
All newly recruited OV and meat inspectors are required to be trained as per the government protocols by the Division of Personnel and on-the-job training by their respective affiliated divisions/bureaus as well as other special training as necessary. The training includes 1 month in-class training and 3months of job shadowing workshop sessions. The DLD inspectors at a slaughterhouse must complete these courses before being assigned to work at any establishment. The BLSC work instructions describing the inspection methods.
The refresher training program on meat inspection is organized at least once a year. This is to guarantee that trained veterinary inspectors can perform their tasks and ensure that they are aware of importing country regulations. At slaughter facilities and processing facilities, the OV provides continuous training to the inspectors, an on-site training is given by an OV and Area Supervisor at least once per month.
As audited, the training of inspectors and OVs was completed as per the annual training plan. The training records were kept at the establishment level.
Conclusion
The Central Competent Authority (CCA) possesses an adequate framework to train human resources involved in the planning, development, and implementation of meat inspection systems.
2.4 Export controls
As per regulations B.E. 2548 (2005) and B.E. 2564 (2021), the establishment of export of poultry meat and meat products establishments intended to produce for export must be approved by the DLD. The BLSC is responsible for the approval of establishments for export to Canada. The application includes a document review of the prerequisites and HACCP and an on-site visit of DLD. If the operator application and renewal process are accepted, the BLSC issues an Official Export Establishment Certificate valid for 3 years and assigns an approval number to the establishment.
The on-site audit at the slaughterhouse confirmed that only meat products that have been inspected and stamped with the health mark are allowed for loading in the container for export under the DLD supervision. BLSC 2 form is required for the movement of fresh poultry meat and offal and non-heat processed by-products in poultry slaughterhouses. During the export certification process, the DLD OV issues Form BLSC 1 certifying the products to be exported and meeting the importing countries requirements. The original form BLSC 1 is submitted to the DLD Quarantine Section at the port of exit to get export permission (Form R9).
The auditors noted that both OVs and inspectors are trained in the Canadian requirements. The verification is conducted by the OV to ensure that the establishments are eligible to export to Canada. The meat transfer certificate form (BLSC 2), BLSC 1, and visual inspection of the export consignment are completed by OV at both slaughter and processing facilities.
During the on-site audit, the CFIA auditors visited the Health Certification unit (HCU) at the DLD Head Quarters located in Bangkok. The BLSC form 1 and 2 are prepared, reviewed, signed, and stamped by OV at the exporting establishment. The FBO is responsible to bring these signed certificates to HCU. The DLD officer at HCU validates the information on the certificate and the BLCS certifier (a dedicated OV) authorizes and stamps the final export certificate. The FBO is responsible to bring the original authorized and signed certificate to the port to accompany the export shipment.
Conclusion
The CCA possesses adequate export controls and certification procedures for exporting only eligible meat and meat products to Canada.
2.5 Import controls
The Animal Epidemics Act B.E. 2558 (2015) chapter I, under the control of DLD, controls the importation of animals and animal products into Thailand to prevent any risks to human and animal health. Only animals or animal products originating from accredited establishments included in bilateral agreements with third countries are permitted for import into Thailand. The general and specific sanitary requirements must be met as per the health certificate issued by the country of origin. Eligible meat products can enter Thailand exclusively through the qualified ports (airport, seaport, land border crossing) under the oversight of the DLD.
Conclusion
Thailand has established regulatory import controls for animals and animal products imported or transitioned from any third country as the Animal Epidemics Act B.E. 2558 (2015).
No border control post was audited during this audit.
2.6 Enforcement framework
The regulations B.E 2558 (2015) and B.E. 2559 (2016) and Poultry Meat and Poultry products Inspection Regulation B.E. 2548 (2005) give powers to the DLD inspection personnel to enter the premises, performed document reviews retain products where there are reasonable grounds for suspicion of violation or non-compliance.
Enforcement actions are taken in response to related food safety and animal welfare non-compliances. The enforcement actions include product seizure, suspension of the activities and the export certification, fine, and removal of the establishment from the eligibility list.
As audited, DLD officials perform enforcement actions and follow-ups as per the official requirements described in the guidance on non-compliance "Guidelines for action in case of founding deficiencies in poultry slaughterhouses and poultry processing establishment for export".
The non-compliances are documented on the non-compliance report. These non-compliances are classified as minor (no food safety impact), major (food safety impact), and critical. For both major and critical the FBO have to submit a corrective action plan to the DLD. The OV is responsible to allow specific time for corrective actions. The DLD officials verified the corrective actions taken by the FBO. All the non-compliance reports are reviewed by the area supervisor and are kept on file for 2 years.
In the event of repetitive non-compliances without effective corrective actions, the OV follows escalated enforcement actions by issuing a "memorandum for suspension of meat and animal products inspection certificates". The OV can issue a report which is then approved by the area supervisor and the report is sent to the Livestock Product Inspection and Certification Division and BLSC Directors.
Conclusion
The competent authority has an adequate risk-based enforcement framework and legal authority to carry out the necessary official controls of the meat inspection system in case of non-compliances as stipulated in regulations B.E 2558 (2015) and B.E 2559 (2016) and Poultry Meat and Poultry Products Inspection Regulation B.E. 2548 (2005).
3. Ante-mortem, humane handling, and animal welfare controls
- 3.1 Traceability and animal identification
- 3.2 Ante-mortem inspection
- 3.3 Humane handling and animal welfare
3.1 Traceability and animal identification
Only farms with a Good Agricultural Practices (GAP) certification under sectors 1 and 2 with a higher bio-security level of integrated cooperative poultry production and contracted farms can provide live birds to slaughterhouses dedicated to exports. GAP certificates are issued to the farmers by the provincial and regional livestock offices after verifying the conditions.
The regulation B.E. 2546 (2003) stipulates that the operators of animal feed production, livestock farms, slaughterhouses, and meat processing plants must establish a management and documentation system on raw material supplies, production process, and distribution as well as laboratory results to trace backward of livestock products. This traceability is part of the prevention and control of epidemics in Thailand. The DLD authorities are responsible to inspect the traceability system of the farmers and the slaughter establishments.
A movement permit from the DLD is required for the inter-provincial movement of live birds as per B.E 2558 (2015) under the DLD division of Veterinary Inspection and Quarantine.
Upon the arrival of live birds at the slaughterhouse, the DLD inspector checks the Poultry Inspection Report at Farm (Form BLSC 001) and the movement permit documents that accompanied the live birds. If documents are not available, birds are not accepted for slaughter.
At the audited establishments, the operator implemented a written program to adequately identify animals upon arrival at the slaughterhouse. All requisite forms including GAP certification, animal identification, and traceability controls are reviewed. The operators had a secure electronic system to maintain the food chain information.
Conclusion
Farm GAP certification, animal identification, and traceability controls are in place as stipulated in B.E. 2546 (2003).
3.2 Ante-mortem inspection
As stipulated in regulation B.E 2548 (2005), an AM inspection at the farm is first conducted by a certified DLD farm veterinarian 3 days before catching the birds. The results of the inspection and the permission of transportation at the farm are recorded in the Inspection Report at Poultry Farm (Form BLSC 001) by checking flock records, the health status of the flock, number of birds, mortality rate, feed consumption, vaccination, medication, history of sickness.
All the live birds (100%) undergo an AM inspection before slaughtering to determine their health status. The inspectors look for any clinical signs including abnormalities in breathing, behavior, gait, posture, and abnormal odour and discharges. The suspected flock with any disease or unsound condition like veterinary medicinal product treatments which may cause condemnation in whole or in part on PM inspection, are segregated from the other poultry and held for separate slaughter, evisceration, PM inspection and retained under the OV inspection. Results of AM inspection are recorded on the daily report on the AM inspection form (Form BLSC 004).
At the audited establishments, the operator implemented a written program to adequately conduct an AM examination of all birds upon arrival at the slaughterhouse.
Conclusion
On-farm AM examinations and AM s conducted by the DLD inspectors at slaughter establishments are performed as stipulated in B.E. 2548 (2005).
3.3 Humane handling and animal welfare
As stipulated in regulations in B.E. 2554 (2011) and B.E.2557 (2014) including raising animals in proper condition, providing, adequate food and water, and, maintaining good health. These regulations also include specific controls at the time of catching the birds and transportation of live birds from the farm to the slaughterhouse.
The DLD has not set the maximum allowed transport time for poultry. However, the amount of time for the transport of live birds must be kept to a minimum according to the regulations of the DLD on the Protection of Transport B.E. 2554 (2011). The slaughter facilities audited procure their live birds from vertically integrated systems of farming and these birds do not have to travel greater distances (less than 8 hours). The feed withdrawal is not more than 12 hours.
When the live birds arrived at the slaughterhouse, every truck is inspected by a DLD meat inspector. Maintenance of the truck and crates, bird density, and, the number of dead birds at the arrival are verified. The official control of animal welfare at the time of arrival is performed by DLD officials twice daily and is documented on the Poultry Welfare Inspection form.
As stipulated by regulation B.E. 2554 (2011), the operator has a trained poultry welfare officer (PWO) by DLD to monitor and supervise the operations relating to poultry welfare. The operator documents the monitoring activities of the equipment maintenance and the effectiveness of the stunning and bleeding. In the event of birds exhibiting welfare issues, an emergency killing is performed in an area with appropriate instruments, equipment, and facilities.
The DLD officials are responsible to train the poultry welfare officers to ensure that they continue to comply with the requirement stipulated by regulations B.E 2548 (2005) and B.E 2554 (2011).
At the audited establishments, the FBO follows ritual slaughter (halal) which is certified by the local Halal certification authorities. The electric stunning process precedes the ritual bleeding step. As audited, only a multiple-bird electrical stunning system with a water bath single-phase stunner is used at the establishments.
At PM, if the meat inspector detects birds with a high number of wing and leg fractures, the poultry welfare officers will be informed and root causes analysis and corrective actions will be done at the farm of origin.
Conclusion
Adequate animal welfare controls are implemented by the operators and verified by DLD as stipulated in the B.E. 2554 (2011).
4. Poultry slaughter and post-mortem
As described in B.E. 2548 (2005), the traditional PM inspection in Thailand is conducted on all poultry eviscerated by a DLD meat inspector under the direct supervision of a veterinary inspector. Each carcass to be eviscerated is opened to expose the organs and the body cavity for proper examination by the inspector and involves the use of a mirror. The PM inspection includes the visual inspection of the slaughtered animal, where necessary, palpation and incision of the slaughtered animal, and the investigation of abnormalities, inconsistency, color, and smell.
Carcasses of birds showing signs of systemic disease are condemned. Viscera and/or parts of carcass showing signs of non-systemic disease or blemishes are removed and condemned and the remainder is used for human consumption. The meat inspector is allowed to condemn the carcasses with systemic conditions under the direct supervision of the OV. The records of the results of the PM inspection are documented in the Daily Report on PM Inspection as prescribed by regulation B.E. 2548 (2005). All the inspected poultry meat products are identified by an official inspection legend on containers of inspected poultry products prepared in the establishment.
Viscera like the trachea, lungs, esophagus, crop, intestine, and gallbladder are excluded from use for human consumption. The meat inspector verifies and documents (BLSC 007) the removal of the uropygial gland before the final carcass wash.
The FBO has an identified inside and outside wash as a CCP (includes the pressure and volume of portable water per bird)
As audited, the fecal and ingesta contaminated carcasses are removed by the meat inspector for the Partial Condemn Staff to trim the contaminated part and these carcasses should be washed immediately. The trimmed part shall be condemned and the rest shall be put into the rejected carcass tank.
PM inspection is recorded on Form BLSC 005, which includes the condemnation number and type of condemnation (total) or rejected carcass (partial).
DLD authorities do not have national guidance and standards regarding poultry carcass presentation and evisceration in traditional poultry inspection. It is the responsibility of the FBO to establish these standards under the supervision of the local OV. In Canada, CFIA establishes these standards for the FBO to meet.
Conclusion
The PM inspection is conducted by a DLD inspector under the supervision of an official veterinarian as per B.E. 2548 (2005). However, DLD does not have national guidelines for presentation and evisceration standards for a consistent PM inspection for all classes of poultry as required per Canadian requirements Traditional poultry inspection presentation standards.
5. Antimicrobial controls
The use of antimicrobials/chemicals is not permitted on poultry carcasses and parts. Only water and ice are allowed to use in a slaughterhouse on poultry carcasses and parts in Thailand. The potable water contains free residue chlorine at a concentration of a maximum of 1 ppm. Audited poultry establishments do not use antimicrobials on carcasses and their parts.
Conclusion
Antimicrobials are not used and permitted on poultry carcasses and parts.
6. Chilling and freezing controls
As described in section 4 of B.E. 2548 (2005), all poultry that is slaughtered and eviscerated in the establishment shall be chilled immediately after processing so that the internal temperature is reduced to 4°C or less. Poultry carcasses and carcasses parts as defined are to be chilled to 4°C or lower within the times specified
- carcasses under 1.8 kg under 4 hours
- carcasses 1.8 to 3.5 kg under 6 hours
- carcasses over 3.5 kg under 8 hours
Giblets are chilled to 4°C or below within 1 hour of their removal from the viscera. In continuous giblet or neck chillers, the temperature of the chilling medium shall not exceed 2°C in the warmest part of the system.
The cutting, deboning, and processing room temperatures were adjustable and maintained at a temperature of 12°C. or lower as required by the B.E. 2548 (2005). Chilled room temperature must be maintained between 0 and 4°C. The loading dock shall be capable of being maintained at a temperature of not more than 10°C. Cold storage are maintained at a temperature lower than -20°C.
As audited, the operator controlled the chilling of carcasses and the cooling of the processed poultry meat products with a Critical Control Point (CCP). The competent authority verified the implementation of chilling controls for both carcasses and processed poultry meat products which meet Canadian requirements.
Conclusion
Chilling and freezing controls are implemented as prescribed in the regulation B.E. 2548 and meet the Canadian requirements for both carcasses and processed poultry meat products.
7. Retained water control program
As described in section 4 of B.E. 2548 (2005), random sampling of poultry carcasses before and after passing through a screw chiller is conducted for the calculation of carcass water absorption. Water absorption in poultry production must be verified and reliable methods for the determination of the content of water added post-evisceration method. The calculation of water absorption in the carcass is done by random sampling of poultry carcasses before and after passing through the chilling process. The water retention was validated for each shift on 20 carcasses. The standard for water absorption by the chilling method is as follows:
- air chilling: 0%
- air spray chilling: 2%
- immersion chilling: 4.5%
- other 0%
However, there are no standards for retained water for poultry parts and giblets. Therefore audited slaughter establishments didn't implement retained water controls for poultry parts and giblets as described in the Canadian Poultry Water Retention Control Program.
Conclusion
The Retained water control program is implemented for carcasses at the poultry establishments as described in the B.E. 2548 (2005). However, audited poultry slaughter establishments did not implement a written water retention control program for poultry parts and giblets as per the Canadian requirements detailed in the Canadian Poultry Water Retention Control Program.
8. Allergens controls
Processing establishments of poultry meat products in Thailand must comply with the requirements of B.E. 2560 (2017) on Labelling on Packaging" requirements. If the FBOs use allergens on site, they must implement an allergen control program. The list of allergens in Thailand are
- cereals containing gluten, for example, wheat, rye, barley, oat, spelled, or their hybridized strains and their products
- crustacean, for example, crab, shrimp, mantis shrimp, lobster, and their product
- egg and egg products
- fish and fish products
- peanut and their products
- soybeans and their products
- milk and dairy products including lactose
- tree nuts and their products, that is almond, walnut, pecan, etc.
- sulfite at level 10 milligram per kilogram or more
The FBOs are responsible for developing and implementing written allergen control programs at the poultry slaughter and meat processing establishments as per Canadian requirements. The DLD officials verify the implementation of the allergen control program.
The CFIA verified that the audited establishments in Thailand developed and implemented the allergen control program. Additionally, the meat processing establishment has developed and implemented a written allergen control program that included all Canadian-priority allergens in its program.
Conclusion
Thailand developed and implemented allergen control programs as required and in compliance with the requirements of regulation B.E. 2560 (2017) and Canadian requirements of Preventive controls for food allergens, gluten and added sulphites.
9. Processing control programs
Thailand is currently allowed to export only fully cooked poultry products to Canada. According to the Poultry Meat and Poultry Products Inspection regulation B.E. 2548 (2005) article 37, the poultry products that are heat processed in any manner shall reach an internal temperature of at least 80°C before being removed from the cooking medium, or heat-processed to an internal temperature as required by the importing countries for products manufactured for export such as cooking poultry products' temperature for export to Canada is about 80°C for 1 minute. After the cooking process, the product must be cooled with the internal temperature of poultry meat products below -18°C or below within 72 hours from the time of entering the freezer.
As audited, fully cooked poultry products go through a heat treatment to produce fully cooked frozen non-shelf stable products was completed by using cooker, oven, and grills. The calibration of the equipment was performed every year. Furthermore, validation of the capacity of the oven to achieve the time/temperature standards.
The heat treatment for duck-cooked meat would reach an internal temperature of greater than 85°C and higher for an average of 200 to 240 minutes. The cooking steps include blanching roasting and steam boiling at greater than 85°C for 96 to 98 minutes which is followed by freezing at reaching -18°C. Thereafter, the product cooled and then frozen at -18°C.
The heat treatment for cooked chicken products would reach an internal temperature of greater than 80°C and higher for an average of 65 minutes. The cooking steps include steam boiling oven roasting and charcoal grill and are followed by freezing at reaching -18°C. Thereafter, the product cooled and then frozen at -18°C.
The time-temperature combination employed at the audited establishments in the heat treatment and cooking process would be sufficient to inactivate Avian Influenza and Duck Tembusu Virus (DTMUV) in chicken and duck cooked meat, respectively.
The monitoring and verification of the heat treatment were completed via a CCP for every batch of heat treatment cycle for each oven. However, the log reduction validation for Salmonella was not calculated in all of the processing plants audited. The shelf life of fully cooked frozen non-shelf stable products is 18 months and 24 months, respectively.
The operator monitored the container integrity by visual examination and a squeeze test of the package after the sealing operation. The container integrity was also monitored by conducting a leak test that is applying external pressure on 1 immersed pouch in a water basin. These tests were recorded in the associated monitoring documents.
10. Preventive control plans
The regulation B.E 2548 (2005) section 4 describes the standards regarding the pre-requisites controls to be followed by each establishment slaughtering, processing, and storing livestock products intended for human consumption and must develop and implement a quality assurance system based on the HACCP principles.
As audited, all establishments implemented a HACCP plan and pre-requisite program. The DLD certifies that the HACCP controls are implemented at slaughter and processing establishments. DLD examine the HACCP system as the criteria set by DLD and issue non-compliance report and enforcement actions in case of non-compliance related to the HACCP. The certification of the HACCP is delivered by the DLD Office for system development and certification of livestock goods. The HACCP certificate is valid for 3 years with the requirement of an annual surveillance audit.
The monitoring and verification of their CCP are completed daily and also verified by the FBO and the DLD officials. However, CFIA auditors found some discrepancies in the monitoring of CCP.
Conclusion
HACCP and prerequisite programs are implemented as stipulated in the B.E 2548 (2005) section 4. However, monitoring, verification, and preventive procedures for CCPs were not consistently documented and completed as per the written program and Canadian requirements Preventive control plan.
11. Microbiological controls
11.1 DLD official microbiological controls
The DLD has developed a microbiological control program to confirm the competence of the operator's quality assurance system to prevent contamination during slaughtering which is applied to every slaughterhouse registered on the official list of export establishments of livestock products. The DLD collects official samples through the evaluation of the microbiological performance of the establishment and the compliance with the import countries requirements.
B.E. 2551 (2008), the products from slaughterhouses for export will be analyzed for Aerobic Plate Count, Coliform, Escherichia coli, Enterococcus spp., Staphylococcus aureus, Salmonella spp., yeast, and molds.
The raw poultry meat are examined by collecting 5 samples per week to monitor production hygiene. For products from processing plants for export will be analyzed for Aerobic Plate Count, Coliform, Escherichia coli, Enterococcus spp., Staphylococcus aureus, Salmonella spp., Clostridium perfringens, Listeria monocytogenes, yeast, and molds.
The cooked poultry meat products are examined by collecting 5 samples per month to monitor production hygiene. For raw meat, the samples are taken after the chilling step and for cooked meat, the samples are taken on fully cooked frozen products. DLD officers collect samples by themselves and send these for analysis to the DLD laboratory.
11.2 Operator microbiological controls
All slaughter establishments implemented the microbiological control program for Salmonella, Campylobacter, and generic E. coli as per the Thailand requirements.
However, 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
As audited, DLD officials performed the verification to ensure that establishments implemented a microbiological control program as per the domestic, but some importing countries' requirements like the program for Listeria monocytogenes, Salmonella was not implemented, Please find below some of the findings.
As audited CFIA observed the following deficiencies regarding the Listeria sampling program:
- DLD does not have guidance for FBO and DLD inspectors regarding Listeria sampling for food contact surfaces (number of samples, sample size, list of food contact surfaces in a piece of equipment to be sampled, etc.) and product as per Canadian requirements
- DLD does not conduct linked sampling of the food contact surface and end-product testing as part of the official High-risk sampling plan (combination of environmental sampling and end-product testing to verify control of Listeria monocytogenes in ready-to-eat (RTE foods)
- DLD does not conduct any independent official verification sampling of the food contact surface or meat product to verify the FBO corrective actions in the event of a positive sample for Listeria spp.
- FBO's product sampling site should be reflective of the complete process which includes packaging in the ready-to-eat environment for Listeria spp. and Listeria monocytogenes
On-site audit findings concluded that the time and temperature combination in the lethality step/heat step would achieve a 7-log reduction for Salmonella which is described in Canadian requirements. However, FBO documents and validation studies did not explicitly conclude that the time and temperature combination would render Salmonella as part of the lethality step.
Conclusion
The DLD has developed a microbiological control program as per the regulation B.E. 2551 (2008) requirements. However, the official audit for the Canadian export requirements did not include the verification of sampling and testing of Listeria sampling and testing of meat at processing establishments. The deficiencies related to the implementation of the microbiological control program were noted at some audited establishments as identified in the report. Furthermore, the poultry processing establishment's written sampling program for Listeria didn't reflect that sampling and verification as per the Canadian requirements.
12. Chemical residue controls
Thailand implemented the Official National Plan of Surveillance to monitor the illegal use of substances, misuse of authorized veterinary medicines, and minimize residue recurrence in live birds and animal products by regulation B.E. 2548 (2005). The DLD is responsible for implementing the national residue control program to monitor the residue in food chain production in poultry (chicken and duck).
The samples are collected by DLD personnel and submitted to the Bureau of Quality Control of Livestock Product (BQCLP under DLD) for laboratory analysis. The National Reference Laboratory is the laboratory of the Bureau of Quality Control of Livestock Products. All responsible laboratories are accredited by the National accreditation body of Thailand. There is 1 official laboratory at the central level that is accredited with International Organization for Standardization ISO 17025 and is responsible to carry out analyses of samples from the national residue monitoring plan in poultry farms and slaughterhouses during official controls.
All samples are analysed at laboratories accredited by the DLD official laboratory. Thailand has a laboratory structure and the NRL reference laboratory. The Accreditation ISO 17025:2017 is given by the Accreditation by the Ministry of Department of Medical Sciences.
At all audited establishments, the annually planned samples were collected by the DLD officials. Thailand follows and meets the requirement for poultry meat products (chicken and duck) of the Council Directive 96/23/EC annex IV regarding the calculation of the number of samples by commodities. The compliance rate for poultry commodities between 2018 and 2021 is higher than 99% as required by the Codex Alimentarius.
The Thailand authorities demonstrated having a clear procedure regarding the controls, follow-up, investigation procedures, and communication lines in case of non-compliant chemical residue results. Thailand demonstrated having a monitoring (random) sampling but didn't provide any information about targeted sampling when a suspect animal is detected at AM or PM inspection.
In Canada, imported meat products are subjected to routine monitoring for chemical residues. The results are assessed and must comply with Canadian maximum residue limits. The maximum residue limits for the veterinary drug in food are established by Health Canada.
Conclusion
Thailand has implemented a residue control program (NRP) with B.E. 2548 (2005). Thailand demonstrated having a monitoring sampling but didn't provide any information about targeted sampling when a suspect lot of birds having chemical residue noncompliance is detected at AM or PM inspection.
13. Closing meeting
The closing meeting was held with representatives from Thailand on August 10, 2022, at the DLD headquarters. At the meeting, the CFIA lead auditor presented a summary of the preliminary findings.
14. Conclusions
Overall, the audit results showed that the meat inspection system as audited continues to provide at least the same level of protection as provided under the SFCA and SFCR. The audit report includes conclusions and recommendations for DLD officials in Thailand to address the deficiencies identified during the audit.
15. Recommendations
The recommendations are linked to the specific conclusions made during this report. Therefore, the competent authority should interpret each recommendation in conjunction with the recommendations.
CFIA recommendation 1
The CFIA recommends that all establishment-specific findings listed be corrected and verified in a timely fashion.
DLD action plans/comment 1
DLD has supervised and review the corrective actions from all establishments.
CFIA recommendation 2
The CFIA recommends that the competent authority establish national presentation and evisceration standards as described in the Canadian Traditional Poultry Inspection Presentation Standards.
DLD action plans/comment 2
DLD has work instructions for the assessment for poultry inspection presentation at post mortem station.
CFIA recommendation 3
The CFIA recommends that monitoring, verification, and preventative procedures for CCPs be consistently documented and completed as per the written program and Canadian requirements Preventive Control Plan.
DLD action plans/comment 3
The monitoring and verification for CCPs were not consistently documented was an establishment-specific error. This establishment did the corrective action and implemented the preventive measures.
CFIA recommendation 4
The CFIA recommends that all poultry establishments eligible to export meat and meat products to Canada have a written and validated retained water control program for carcass parts, and offal as described in the Canadian requirements Canadian Poultry Water Retention Control Program.
DLD action plans/comment 4
DLD has informed the operators should implement retained water control program in both poultry carcasses, parts and giblets as requirements detailed in the Canadian Poultry Water Retention Control Program since 15 March 2023.
CFIA recommendation 5
The CFIA recommends that the operators include in their written manufacturing process the validation of the 7-log reduction in Salmonella spp. in meat products containing poultry as per described in Preventive control recommendations for manufacturing cooked ready-to-eat meat products.
The CFIA recommends that the operators and DLD develop Listeria sampling plans as described in section 11.2 for the export of meat products to Canada as described in the Canadian Listeria control measures for ready-to-eat foods.
DLD action plans/comment 5
DLD has informed the operators to do the validation studies for Salmonella and log reduction and verification of sampling and testing of Listeria sampling that was started since March 15 2023.
CFIA recommendation 6
The CFIA recommends that DLD has a program in place for targeted sampling when a suspect lot of birds with chemical residue non-compliance is detected at AM or PM inspection.
DLD action plans/comment 6
DLD has mentioned in Poultry Meat And Poultry Products Inspection regulation B.E. 2548 (2005), article 18, 1.15 as follows: When any poultry at an export-approved establishment is suspected of having been treated with or exposed to any substance that may impart a chemical residue that would make their edible tissues adulterated, they shall, at the option of the veterinary inspector, be processed at the establishment and the carcasses and all parts thereof retained under the supervision of the veterinary inspector pending final disposition or they shall be slaughtered at the establishment and buried or incinerated in a manner satisfactory to the veterinary inspector.
Alternatively, such poultry may be returned to the grower if further holding is likely to result in their not being adulterated by reason of any residue. The Veterinary Inspection Service will notify the other Department of Livestock Development units concerned of such action. To aid in determining the amount of residue present in the poultry, veterinary inspector may permit the slaughter of any such poultry for the purpose of collecting tissues for analysis of the residue.