Final report of an audit conducted in the United Kingdom to evaluate the meat inspection systems governing the production of meat and meat products intended for export to Canada

The UK is one of Canada's trading partners and currently exports bovine, swine, poultry, ovine and caprine meat and meat products to Canada. In 2023, the UK exported meat products to Canada with a total volume of approximately 1,340,175 kg.

The CFIA audited the UK's bovine, swine, poultry, ovine, and caprine meat inspection systems from September 16 to 26, 2024. The audit began with an opening meeting held virtually on September 10 and 11, 2024, with the participants from the UK's CCA, i.e., the Department for Environment, Food and Rural Affairs (DEFRA), CFIA auditors, and CFIA representative in the Mission of Canada to the European Union in the European Union.

In the opening meeting, the CFIA presented the scope, objectives, methodology, regulatory authorities, and logistics requirements for the onsite audit. DEFRA provided detailed information on various subjects of interest to the CFIA.

Prior to the on-site audit, the CFIA experts completed a document review of the UK's meat inspection systems. In preparation for this audit, the CFIA took a risk-based approach to determine the audit scope, factoring in the species, categories and volumes of imported meat products, recalls and Point-of-Entry violations. At the time of the audit, the following meat products could be exported from the UK to Canada:

• bovine-raw and processed
• swine- raw and processed
• poultry- raw and processed
• ovine and caprine- raw and processed
• natural salted casings
• broths/bouillon cubes, flavours and meat extracts

The representatives from the CCA accompanied the CFIA auditors throughout the audit. The audit was focused on government controls and oversight within the following areas of risk.

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

• regulatory framework
• supervisory oversight
• import and export controls
• laboratory framework
• ante-mortem, humane handling and animal welfare controls
• post-mortem and slaughter
• Trichinella spiralis controls
• processing controls
• preventive control plans
• microbiological controls
• chemical residue controls

Administrative functions were reviewed at Food Standards Scotland (FSS), Food Standards Agency (FSA), and Department of Agriculture, Environment and Rural Affairs in Northern Ireland (DAERA) headquarters, during which the auditors evaluated whether inspection, verification, and enforcement were being implemented as intended.

The CFIA auditors verified the system and its implementation via

• document review of the documents/directives/regulations
• onsite observations
• interviews

The CFIA audited the UK's meat inspection system under the specific provisions of the Canadian food safety and animal health laws and regulations, in particular:

• Safe Food for Canadians Act and Safe Food for Canadians Regulations
• Health of Animals Act and Health of Animals Regulations
• Food and Drug Act and Food and Drug Regulations

CFIA conducted the audit following standard program delivery practices with the aim to evaluate if the UK CCA's inspection activities can provide at least the same level of protection as provided by the Canadian laws.

The United Kingdom of Great Britain and Northern Ireland is commonly known as the United Kingdom or Britain. It comprises England, Scotland, Wales, and Northern Ireland. The United Kingdom (UK) left the European Union (EU) on January 31, 2020, but continues to follow food hygiene standards set by the European Commission under Retained Direct EU Legislation.

Alongside these EU Regulations, UK authorities enforce additional laws to ensure food safety, including meat inspection. As of 2023, these retained EU Law (Revocation and Reform) Acts were revoked and later became "assimilated law" in the UK. However, under the Northern Ireland Protocol, Northern Ireland continues to apply EU laws on animal health and public health controls, including food safety and hygiene standards.

England, Scotland, Wales, and Northern Ireland, differ in local government structures. England is divided into 9 regions for statistical purposes, while Scotland has 32 council areas, Wales has 22 sanitary authorities, and Northern Ireland comprises 11 district councils. Each local government and devolved administration serve as its region's Competent Authority (CA) for food legislation.

The FSA manages government inspection activities in approved slaughterhouses, stand-alone processing establishments, and cold storage facilities in England and Wales. FSS takes responsibility for government inspections in Scotland. In Northern Ireland, the DAERA conducts food safety-related official controls on behalf of the FSA, as outlined in a Service Level Agreement. Each Devolved Administration acts as the CA for food legislation, animal health, and animal welfare within its jurisdiction, ensuring that robust operational food safety, hygiene standards, and controls for meat production apply consistently across the entire United Kingdom and Northern Ireland.

The EU legislation, including legislation on animal health, food safety, and feed controls, as it was applied to the UK on 31 December 2020, became part of UK legislation under the European Union (Withdrawal) Act 2018 (EUWA).

Converted UK law is also called "retained European Union (EU) law". The relevant regulations are:

• Regulation (EU) No. 37/2010: pharmacological substances and their classification regarding maximum residue limits in foodstuffs of animal origin
• Regulation (EU) No. 101/2013: use of lactic acid to reduce microbiological surface contamination on bovine carcasses
• Regulation European Commission (EC) No.178/2002: general principles/requirements of food law
• Regulation (EC) No. 852/2004: hygiene of foodstuffs
• Regulation (EC) No. 853/2004: hygiene rules for food of animal origin
• Regulation (EC) No. 854/2004: rules for the organization of official controls
• Regulation (EU) No. 2023/915 on maximum levels for certain contaminants in food and repealing Regulation (EC) No 1881/2006
• Regulation (EC) No. 999/2001: prevention, control and eradication of certain transmissible spongiform encephalopathies
• Regulation (EC) No. 1069/2009: animal by-products and derived products not intended for human consumption
• Regulation (EU) No. 1169/2011 on the provision of food information to consumers
• Regulation (EU) No. 2015/1375: official controls for Trichinella spirals in meat
• Regulation (EC) No. 2015/1474: use of recycled hot water to remove microbiological surface contamination from carcasses
• Regulation (EU) No. 2017/1495: amending Regulation (EC) No. 2073/2005 as regards Campylobacter in broiler carcasses
• Regulation (EU) No. 2019/624: specific minimum training requirements for official veterinarians and other staff designated by competent authorities
• Regulation (EU) No. 2017/625: official controls and other official activities performed to ensure the application of food and feed law, rules on animal health and welfare, plant health and plant protection products
• Regulation (EU) No. 2019/2007: rules for the application of Regulation (EU) No. 2017/625 as regards the lists of animals, products of animal origin, germinal products, animal by-products and derived products and hay and straw subject to official controls at border control posts
• Regulation (EC) No. 2073/2005: establish the microbiological criteria for foodstuff
• Council Directive 96/23/EC: concerning measures to monitor certain substances and residues thereof in live animals and animal products
• Council Directive 64/432/EEC: concerning the conditions for trade in agricultural livestock from the European Union- for cattle and pigs

In addition to EU regulations, the UK authorities also develop and enforce laws and regulations to ensure food safety, including meat inspection, which occurs due to the enactment of devolved acts implemented in England, Wales, Scotland, and Northern Ireland. The UK's 3 devolved acts include:

• the Government of Wales Act of 1998
• the Scotland Act of 1998, and
• the Northern Ireland Act of 1998

DEFRA is the central government department of the United Kingdom. It serves as the CA for international trade negotiations related to all sanitary and phytosanitary matters and the trade of food of animal origin. Additionally, DEFRA oversees animal health and welfare across the UK for the Devolved Administrations in Wales, Scotland, and Northern Ireland.

As the UK's CA, DEFRA is responsible for developing and implementing policies related to the certification of food exports to non-EU countries. It ensures that all exports comply with relevant import requirements. To achieve this, DEFRA delegates specific responsibilities to various agencies, ensuring that products meet the standards set by the importing country.

DEFRA works closely with the FSA, the regulatory authority for food hygiene compliance across the UK. The FSA oversees government inspection activities at approved slaughterhouses and non-slaughter processing establishments in England, Wales and Northern Ireland. The Official Feed and Food Controls regulations are enforced across the UK, with separate legislation for each nation: in England Statutory Instrument 2009/3255 (PDF) and Wales Statutory Instrument 2009/3376.

In Northern Ireland SR 2009/427, the DAERA Veterinary Public Health Program (VPHP) conducts food safety inspections and oversees the enforcement of feed and food legislation, including monitoring enforcement authorities and setting performance standards.

FSS is responsible for similar inspection activities in Scotland Statutory Instrument 2009/446. Additionally, the Food Scotland Act 2015 grants FSS the authority to oversee the enforcement of feed and food legislation, including monitoring enforcement authorities setting performance standards and ensuring the consistent application of food safety regulations in Scotland.

The FSA, FSS, and DAERA VPHP are responsible for assigning Official Veterinarians (OVs) and inspectors to slaughter and processing establishments. Inspection oversight is required and maintained at slaughter establishments throughout the entire shift. The regulations mandate a continuous presence of an OV during slaughter operations.

The oversight activities at DEFRA headquarters, regional offices, and local government offices demonstrate that the UK operates under rules with legal authority to enforce inspection regulations and provide at least the same level of protection for meat products exported to Canada as provided by Canadian regulations.

OVs and Meat inspectors are contracted employees or employed by the CA. They are paid by the government directly or through a third-party contractor to carry out official controls on behalf of the government in England, Scotland, and Wales. The CCA/CAs formally delegate the authority to contract employees to conduct government inspection activities and take enforcement actions when necessary to address violations of food safety measures. Contract employees undergo training and sign a conflict-of-interest declaration to ensure they comply with the official controls set by the UK regulations. They face enforcement actions if they fail to adhere to the rules.

The CAs supervise government and contract employees through ongoing, continuous supervision and official assessment and enforce consistency in performance standards across the UK. They conduct quarterly supervisory audits to verify the effectiveness of official controls at establishments. Additionally, FSA and FSS management evaluate the performance of contract OVs and Meat inspectors against key performance indicators monthly.

CFIA auditors noted that all the competent authorities (FSA, FSS, and DAERA VPHP) have adequate staffing levels and maintain effective oversight.

CFIA auditors observed the implementation of official controls, interviewed contract OV, reviewed audit reports, and found no issues with the oversight concerns with the use of third-party service delivery partners.

OV is designated as such under Regulations (EU) No. 2017/625 and No. 2019/624, with the FSA responsible for their authorization and designation. To qualify as an OV, candidates must hold a veterinary degree, be a member of the Royal College of Veterinary Surgeons, pass a theoretical exam at the end of an OV course, and complete a practical probationary period. Upon successful completion of these steps, they must pass a final assessment.

The competent authority may appoint veterinarians who meet the requirements of Regulation (EU) No. 2019/624, Annex II. After passing the theoretical exam, candidates must complete at least 200 hours of practical training. During the probationary period, new or Novice OVs (NOVs) must work under the supervision of a Supervisory OV (SOV) nominated by the veterinary contractor (Service Delivery Partner - SDP) employing the NOV. The OV course at the University of Bristol includes 73 hours of training.

Newly appointed veterinarians undergo a 12-month NOV training program consisting of 196 hours of theory and 200 hours of practical training. An SOV supervises NOVs during this period. Once the NOV completes the practical training and assessment within 12 months of the OV course, they can begin working independently as a veterinarian. They must participate in continuous training and accumulate 35 hours of Continuing Professional Development (CPD) annually. The FSA and the SDP (Eville and Jones) are responsible for arranging training and appointing training providers.

In accordance with Directive 89/48/EEC (Mutual Recognition of Professional Qualifications) and Section 1.2.2 of the Food Law Code of Practice, an OV from another EU member state may not need to complete the entire OV course or the 200 hours of practical training if they can demonstrate sufficient knowledge and experience of the requirements set out in the Regulation (EU) No. 2019/624, Annex II, and applicable national legislation and enforcement procedures. The OVs from third countries (outside the EU) must verify that their veterinary qualifications and OV designation meet the UK's equivalency standards.

Meat Hygiene Inspectors (MHIs) must have comprehensive knowledge in areas such as food safety legislation, good manufacturing practices, HACCP, risk analysis, and prevention of foodborne hazards. They also need to understand relevant aspects of transmissible spongiform encephalopathies, animal by-products, and enforcement procedures. After completing the classroom training, MHIs must pass assessments based on enforcement scenarios before beginning practical training under the supervision of a Food Veterinary Coordinator (FVC). They must successfully complete both the classroom enforcement scenario assessments and the FVC evaluation before they can carry out enforcement duties during Unannounced Inspections. During the probationary period, the MHI works under the supervision of the FVC, who ensures that at least 10 Unannounced Inspections, including 2 accompanied inspections, are conducted. Authorization for enforcement work will only be granted if the MHI completes all training and assessments within 3 attempts.

Under Regulation (EU) No. 2017/625, Member States can authorize slaughterhouse staff (Plant Inspection Assistant (PIA) to take over the tasks of Official Auxiliaries (OAs) for poultry and rabbit meat production, provided they complete specific training and pass a test as outlined in EU 2019/624, Annex II. The FSA is no longer responsible for PIA training but still plays a role in authorizing PIAs to be part of the independent inspection team under the supervision and responsibility of the OV. Regulations allow slaughterhouse staff to carry out OA tasks in establishments with a proven track record of effective food safety management based on HACCP principles, specifically for poultry meat production.

The UK regulates meat imports under Chapter III and Article 14 of specific legislation, ensuring that fresh meat can only be imported into Great Britain from third countries approved by the UK authorities. These imports require a veterinary certificate signed by an official veterinarian from the exporting country. Additional regulations outlined in Chapter II, Article 3 govern the import of poultry meat and related products, including poultry mince and mechanically separated poultry, from approved third countries. Article 6 sets out testing and sampling procedures for diseases such as Avian Influenza, Newcastle disease, and Salmonella. Furthermore, imports can only come from countries that notify UK authorities of any initial outbreaks of specific diseases within 24 hours and submit virus isolates to approved laboratories.

For live animal imports, Council Directive 64/432/EEC governs the trade of cattle and pigs, stipulating that these animals must undergo identity checks and clinical inspections within 24 hours of departure, with a health certificate accompanying them during transportation. The health certificate is valid for 10 days and must be issued in one of the official languages of the destination country. The legislation also ensures that suspected diseases are immediately reported to competent authorities. Similar health certification and inspection requirements apply for intra-community trade in ovine and caprine animals, with the movement of these animals recorded in the animal movement system.

Poultry imports to Great Britain are also subject to strict regulations, with a veterinary certificate required for all shipments. Importing countries must report any Avian Influenza or Newcastle disease outbreaks within 24 hours and submit virus isolates promptly for testing. The legislation sets specific conditions for these certificates, including compliance with other EU public health and animal welfare regulations.

If any consignment of animals or goods does not comply with UK import rules, the competent authorities will detain the shipment and refuse entry. The responsible operator may be instructed to destroy, return, or treat the consignment to bring it into compliance. In some cases, partial shipments may be accepted. Non-compliance can lead to enforcement actions, including financial penalties, as outlined in articles 137 to 139, which aim to ensure the penalties are effective, proportionate, and dissuasive.

The slaughter establishments audited in England and Wales did not process imported live animals. However, the Northern Island establishments audited received live swine and bovine imported from Ireland for slaughter. CFIA noticed segregation and traceability procedures were in place for animals imported from Republic of Ireland and slaughtered in NI. An establishment audited in Scotland received meat byproducts for further processing and exporting to Canada.

Article 12 of the legislation requires that food must comply with relevant food laws unless the importing country's authorities specify different requirements through laws, regulations, standards, codes of practice, or other legal procedures. Article 16 states that food labeling, advertising, and presentation, including shape, appearance, packaging material, and display setting, must not mislead consumers.

The Centre for International Trade in Carlise manages the issuance of export health certificates (EHCs) and is responsible for updating and generating them.

The process for generating an EHC involves several steps:

• the Food Business Operator (FBO) applies for the EHC through the Animal and Plant Health Agency (APHA), providing relevant trade-related information in Part 1 of the certificate
• the Centre for International Trade in Carlise, under APHA, generates the EHC and assigns an export certificate number in the electronic system, which the OV can access via secure login
• the OV, authorized by APHA, signs the certificate based on the health attestation for movement (form #ET-199), which the OV signs at the slaughter/processing establishment
• the generating the certificate, the OV prints the original document, applies the necessary seal or stamp, and ensures the container is sealed once loading is complete
• the FBO supplies the seals, and the OV supervises the application of shipping marks by the cold store. The OV takes photographs of the container before and after loading, including after applying the seal, for sanitation and integrity checks
• if the original OMIC is lost, the cold store notifies the OV and requests a replacement certificate from APHA. If approved, APHA issues the replacement, and the OV prints it

The OV inspects and occasionally opens boxes before shipment to verify the product type. Any opened boxes are deemed damaged, and the contents are classified as Category 3 waste and are not part of the exported shipment. The OV is also responsible for verifying temperatures and documenting all exports daily.

During the onsite audit, it was observed that some OVs at slaughterhouses were unsure where to find online information about foreign establishments eligible to export meat to Canada and the specific import conditions for Canada. There is a process to audit EHCs issued by the OVs. Additionally, the Notes for Guidance (NFG) used by export-certifying veterinarians were outdated and did not include current information. The NFG must be revised to contain correct and up-to-date export requirements.

Under the Food Standards Act 1999, the FSA is responsible for monitoring and reporting on the performance of local authority (LA) food law enforcement services in England, Northern Ireland, and Wales. The FSA collects data annually from LAs on-food law enforcement activity in food establishments. This data is gathered electronically through a web-based system called the Local Authority Enforcement Monitoring System (LAEMS). LAEMS records regulatory activities related to food hygiene (including microbiological quality and contamination by microorganisms or foreign matter) and food standards (such as composition, chemical contamination, adulteration, and labelling of food).

Article 31(3) of Regulation 625/2017 requires that staff directly employed by the FSA carry out enforcement actions. SDP staff are not permitted to serve Notices or escalate enforcement actions.

The enforcement actions taken by an Authorized Officer (AO) depend on the legislation contravened, the enforcement powers available, and the risk associated with the non-compliance. When AOs identify legislative contraventions, they verbally advise the FBO. If the FBO fails to implement corrective actions, enforcement is escalated.

While all AOs can provide verbal advice, decisions to escalate enforcement beyond verbal advice are made by the directly employed staff of the CA, such as the Veterinary Enforcement Delivery Manager (VEDM), FSA Unit Inspectors, Veterinary Auditors, Field Veterinary Coordinators/Leads. If the VEDM supports escalation, they send the enforcement decision to the OV, technical manager, or the Eville and Jones office. The OV is then responsible for posting the notice or delivering the letter to the FBO and updating the daybook and Chronos system.

An Advisory Letter is issued when the FBO fails to take corrective action after receiving verbal advice, and the contravention poses no immediate public health or animal welfare risk. A Remedial Action Notice is issued when the AO expects the FBO to take immediate action, such as prohibiting the use of certain equipment or parts of the establishment. A Hygiene Improvement Notice is issued when the AO observes noncompliance with hygiene regulations or failure to implement an effective HACCP system.

A Welfare of animals at the time of killing (WATOK) Enforcement Notice (WEN) may be served on an operator or person to require immediate rectification of an animal welfare risk or to address systemic issues, such as Standard Operating Procedures (SOPs) or staff training.

Contracted Official Veterinarians (COVs) in slaughterhouses also verify FBO compliance through various official controls. When COVs identify legislative contraventions, they provide verbal advice and request corrective action from the FBO. If the FBO fails to act after receiving verbal advice from a COV, the decision to escalate enforcement will be referred to an FSA VEDM. The FSA Veterinary Enforcement Delivery Team consults the FSA legal team to determine whether the enforcement action is supportable.

CFIA auditors found the enforcement processes working well with appropriate record keeping in paper and electronic format.

In UK, the Regulation (EU) No. 2017/625 lays down the requirements to designate the National Reference Laboratories (NRLs) for official control of feed and food. The FSA and FSS are responsible for designating the feed and food NRLs to comply with Regulation (EU) No. 2017/625. The NRLs support official laboratories (OLs) that test food samples for the Local Authorities (LAs) to monitor official controls and enforce the Food Safety Act (1990). The OLs also test the samples for official controls of food and feed. The FSA-designated food and feed NRLs provide specific Northern Ireland (NI) EU requirements. In addition, DEFRA and DAERA also designate NRLs for animal health and live animals in Great Britain and NI, respectively.

The NRLs operate as per articles 100 and 101 of the Regulation (EU) No. 2017/625 and coordinate the networks of official food safety and animal health laboratories across the UK. The NRLs are responsible for accreditation, auditing and monitoring of OLs used for testing of animal health and food safety by the International Standardization Organization (ISO/IEC) 17025 standard as per agreement between NRLs and FSS/FSA. The NRLs also oversee the calibration of equipment, proficiency testing, knowledge exchange and training, development of novel detection methods, and validation reagents and references. In addition, the NRLs must comply with Article 38 of the Regulation (EU) No. 2017/625 to maintain the designation of an OL. The OL must have suitably qualified staff, equipment and infrastructure to conduct required analyses.

There are 33 FSA/FSS designated NRLs in UK and EU Member States that conduct official testing for microbes and chemical residues in food. Currently, there are no private laboratories that perform testing of official food samples. However, there are FSA-approved in-house laboratories for testing Trichinella spiralis and microbes in animal slaughterhouses and salt and moisture content testing at meat processing establishments. The CA also designate OL for analysing samples obtained from LAs for official controls.

The United Kingdom Accreditation Service (UKAS) is the National Accreditation Body that accredits the laboratories as required in Regulation (EC) No 765/2008. The UKAS assesses and accredits organizations that provide services, including certification, testing, inspection, and calibration against national and international standards. The UKAS conducts annual surveillance assessments of all accredited organisations and a complete reassessment every 4 years. It also provides assessment reports to FSA/FSS. The CFIA did not visit any laboratories that perform testing of official samples for microbiology and chemical residue controls. However, the CFIA reviewed the UK's documents for laboratory infrastructure and testing results and observed that only accredited laboratories analysed the food safety control samples for chemical residues and microbiology.

The CFIA visited the in-house laboratories in hog slaughter and meat processing establishments and assessed the management and technical requirements for quality control. Management requirements included organization, quality management, document controls, control of non-conforming testing, and internal audit. Technical requirements included personnel, environmental conditions, test methods and methods for validation, handling of test items, quality of test methods and reporting of results. The visited laboratories had a system in place to track samples, ensure accurate identification and results reporting, and share information in a timely manner with management and industry for decision-making.

Based on EU and national laws, animal identification and traceability are regulated across England, Scotland, Wales, and Northern Ireland. Key EU regulations, such as Regulation (EC) No. 1760/2000 for cattle, No. 21/2004 for sheep and goats, and No. 911/2000, set requirements for animal identification, including passports and ear tags. Slaughterhouses must receive Food Chain Information (FCI) under Regulation (EC) No. 853/2004 to trace livestock and poultry from farm to table.

Livestock farmers must receive an annual veterinary visit under DEFRA's Animal Health and Welfare Review Pathway Scheme. A 20-digit Veterinary Attestation Number confirms farm compliance with health and biosecurity standards. All livestock premises in the UK must register with veterinary authorities and be assigned a unique County/Parish/Holding/Herd number. Livestock data is managed in operational databases like SAM in Great Britain and Northern Ireland Food Animal Information System Online in Northern Ireland. The Rural Payments Agency and the British Cattle Movement Service track cattle and animal movements in Great Britain. In contrast, DAERA's Veterinary Service tracks cattle, sheep, pigs, and goats in Northern Ireland using the Animal and Public Health Information System.

Animal identification is done through ear tags and radio frequency devices, linking each animal to specific information such as sex, breed, and birth date, ensuring full traceability.

As audited in all slaughter establishments, the UK demonstrated adequate traceability controls from farm to slaughter and further to processing.

In the UK, the ante-mortem (AM) inspection of red meat animal species and poultry is governed by Commission Implementing Regulation (EU) 2019/627. Additional regulations such as (EC) No. 2017/625 and No. 2019/624 also apply to the AM inspection of animals intended for slaughter. Furthermore, different regions of the UK implement their requirements through the Fresh Meat Hygiene and Inspection Regulations 1995 and Fresh Meat Hygiene and Inspection Regulations 1997 Northern Ireland. The Poultry Meat, Farmed Game Bird Meat, and Rabbit Meat (Hygiene and Inspection) Regulations 1995 and the FSA and FSS instructions further support the AM process.

Animals presented for slaughter must have accompanying FCI, which the official veterinarian (OV) reviews and verifies. This includes assessing the animals at rest and in motion. Upon arrival, the operator checks the veterinary health certificate, farmer's declaration, and FCI from primary production. The contract meat inspectors assist the OV by conducting an initial check, ensuring the animals are adequately identified. Operators must assess the FCI to identify potential hazards that could affect food safety, as per the HACCP-based food safety management systems. They must act on the information provided in the FCI to decide whether to accept animals or implement special processing measures, such as altered slaughter schedules or additional processing steps, to prevent harmful animals or veterinary medicines from entering the food chain. The OV relies on the FCI to determine inspection procedures and must review the FCI before conducting the AM inspection.

The OV must complete the AM inspection within 24 hours of an animal's arrival and no later than 24 hours before slaughter. This inspection includes checking the animal's identification, welfare, and health. Based on this, the OV or an authorized meat inspector approves or rejects the animal or batch for slaughter. If an animal is identified as needing further investigation, it is detained for closer examination. The OV also inspects all dead animals arriving during the day or overnight. The meat inspectors may perform the AM inspection under the OV's supervision. Suspect animals identified in the FCI or during the inspection are detained for detailed examination by OV.

The CA records AM inspection tasks on official forms, and operators may request automated records and analyze data from food control activities, including AM inspection. All animals entering a slaughterhouse undergo an ante-mortem inspection. The animals must originate from registered and licensed premises and be accompanied by a transport permit issued by the CA.

If an animal is condemned during the AM inspection, it must be marked as condemned until its final destruction. Only the competent health authority can remove this mark after supervising the destruction and disposal process.

As audited in all slaughter establishments, the UK demonstrated acceptable antemortem inspection before slaughtering animals.

The Animal and Plant Health Agency (APHA) oversee animal health and welfare in England, Wales, and Scotland. At the same time, the DAERA manages this responsibility in Northern Ireland. The UK follows assimilated EU regulations, including those on animal transport and welfare at slaughter, with guidance provided in the UK Manual for Official Controls – Animal Welfare chapter. OVs ensure humane handling and slaughter in certified establishments, which aligns with DEFRA guidelines. In Northern Ireland, DAERA oversees the welfare of farmed animals, and local District Councils handle non-farmed animals.

UK-specific rules supplement EU regulations, requiring slaughterhouses to implement SOPs for processes like lairage, restraint, stunning, and bleeding. These SOPs define roles, responsibilities, and procedures for monitoring and correcting welfare issues. The FSA and FSS enforce these regulations, with OVs conducting inspections and recording daily welfare verifications in slaughterhouses to ensure compliance. Corrective action is administered if violations occur and may include formal notices if necessary.

Adequate welfare procedures are followed during unloading and mobilization to ensure the safe handling of animals. This includes checking that animals are healthy, non-ambulatory animals are handled appropriately, and all identification and documentation (e.g., mobilization permits and batch numbers) are correct.

In the UK, MHIs perform post-mortem inspection of bovine, swine, ovine, and caprine at the carcass, head, and viscera inspection stations. OVs supervise the post-mortem inspection and complete the post-mortem inspection of suspect/railed-out animals at the antemortem and post-mortem.

The identification and maintenance of the correlation between carcasses, parts, and meat by-products are performed using tags. This correlation during evisceration is monitored before and during the slaughter operations by the operators under the supervision of the competent authorities. The offline MHI performs the daily zero-tolerance verification task before the final wash. All bovine, ovine/caprine and swine slaughter operators visited also monitor the fecal, ingesta and milk contamination via a critical control point (CCP) or a control point (CP) after the inspection final station.

However, CFIA auditors observed in England that the head inspection was not included as part of the post-mortem inspection in the ovine slaughterhouse by the FSA competent authorities. In addition, the MOC chapter 2.4 does not contain detailed information about the ovine head inspection as per the Regulation (EU) 2019/627 article 20.

As per Canadian requirements, the standards for post-mortem evaluation procedures of food animal carcasses include the incision of retropharyngeal lymph nodes.

As audited, the FSA MI and OV recorded the post-mortem results in electronic databases as the Inter-System IRIS. Like FSA, FSS in Scotland uses the IT system to record, analyze, and share the data collected during food controls and surveillance, including sampling, in the Operations Workflow System.

As per the WOAH recognition, the UK has a zone with a negligible BSE risk and has 2 different Bovine Spongiform Encephalopathy (BSE) statuses. As such, England, Wales and Scotland have a controlled risk status, and Northern Ireland has had a negligible BSE status since 2021, as described in the Decision (EU) 2021/1321. UK follows the Specified Risk Material (SRM) definition described in Annex V of Regulation (EC) No. 999/2001, laying down rules for preventing, controlling and eradicating certain transmissible spongiform encephalopathies.

As audited, SRM controls are in place to identify and manage animals over 30 months (OTM) at arrival, during evisceration, and cutting. Proper segregation of OTM carcasses, along with identification tags, is maintained. The audited operators also demonstrated correct SRM removal techniques, using dedicated tools and trained staff.

The FSA enforces the operator SRM controls in approved slaughterhouses and cutting plants in England and Wales, FSS in Scotland and DAERA on behalf of the FSA in Northern Ireland. The operators had written SRM procedures and implemented controls in the evisceration and cutting areas. However, the operators' written procedure outlining the removal of dorsal root ganglia (DRG) with the vertebral column from OTM carcasses needs a more precise description and detailed instructions. The Guide to SRM removal should describe the best practices in line with the Canadian guideline, to ensure consistent removal of DRG.

The health mark is proof that the animals and the resulting carcasses have undergone ante and post-mortem inspection by (EU) 2019/624 and (EU) 2019/627. The OV is responsible for ensuring the correct application of the health mark. As observed, the actual application of the health mark after the post-mortem is delegated to an MHI or an FBO staff member under the OV's adequate supervision. The health mark stays under the sole responsibilities of the competent authorities.

As per the FSA MOC Chapter 2.4 section 12, the competent authorities verify the operator's practices to prevent contamination of carcasses and parts and comply with microbiological criteria. FSA OV and AO perform the slaughter hygiene verification.

Furthermore, all poultry slaughter establishments must develop, implement, and maintain written procedures to ensure that poultry carcasses contaminated with visible fecal material do not enter the chiller. These procedures prevent contamination with enteric pathogens and feces throughout the slaughter process. The UK official performed the post-mortem inspection at the audited poultry slaughter establishments.

However, CFIA auditors observed in the poultry slaughter establishments that the uropygial glands were not completely removed from the carcasses as described in the Canadian SFCR article 145.

As described in Regulations (EC) No. 2017/625 and No. 101/2013, establishments can use antimicrobial aids such as steam vacuum or lactic acid to reduce microbiological surface contamination on bovine, swine, ovine, and caprine carcasses. The lactic acid solution must be between 2% and 5% lactic acid in potable water applied as spray or misting at temperatures of up to a maximum of 55°C (MOC Chapter 4.3).

Additionally, the operators can develop and implement non-chemical microbial control interventions, such as hot water and steam vacuum, in their preventive control plan to reduce bacterial loads from carcass surfaces, as per Canadian requirements.

England, Wales and NI implemented antimicrobial intervention as described in the FSA MOC Chapter 4.3. In England, FBOs used steam vacuum on beef carcasses as per Regulation (EC) No. 2015/1474. In Scotland and NI, none of the audited bovine and swine slaughter establishments used antimicrobials during the evisceration process. They relied on control points to prevent contamination of the carcasses and parts.

In poultry slaughter establishment, the operators used a validated rapid chilling system to reduce Campylobacter surface contamination by exposing the poultry carcasses to -90 °C for 40 seconds.

The UK countries implement chilling and cooling controls as per Regulation (EC) No. 853/2004 and National Food Hygiene Regulations 2006 (Scotland, Wales and NI) and 2013 (England) for food of animal origin. These regulations lay down specific hygiene rules for food and chilling requirements for domestic ungulates and poultry. During cutting, boning, trimming, slicing, dicing, wrapping and packaging, the FBO ensures the maintenance of meat at not more than 3°C for meat by-products and 7°C for ungulates meat and parts using an ambient temperature of 12°C.

Similarly, for poultry meat, the FBO also ensures the maintenance of the temperature of the meat at not more than 4°C using an ambient temperature of 12°C. The FBO can have an alternative system having an equivalent effect, and meat may be boned and cut prior to reaching the temperature mentioned above when the cutting room is on the same site as the slaughter premises. The operator must transfer meat to the cutting room directly from the slaughter premises or after the waiting period in a chilling room. The regulations also require the FBOs to ensure frozen food storage at least -18°C or colder.

As audited, the slaughter, meat processing establishments, and cold storage maintained chilling and freezing controls using a CCP or CP. The operators ensured that the temperature of meat during cutting, boning, trimming, wrapping, and packaging was not more than 3°C for meat by-products and 7°C for ungulate carcasses and parts by maintaining the production areas' ambient temperature at less than 12°C. The CA verified the implementation of chilling and freezing controls at each audited establishment.

However, the CFIA auditors noticed discrepancies in the CCP monitoring and verification controls related to the temperature of incoming and the freezer temperature controls for the frozen meat products at the audited cold storage in Scotland. The acceptance limit was -17°C against -18°C as per the operator's written procedure. The UK must store the frozen poultry at - 18°C or less as per Canadian requirements.

Lethality treatments refer to the treatment applied to meat products to achieve a reduction in viable pathogenic organisms. The Regulation (EC) No. 852/2004 Annex II, Chapter 11 on heat treatment describes the requirements that apply only to the continuous use of traditional methods at any stage of production, processing or distribution of food. These requirements relate to any heat treatment process used to process an unprocessed product and prevent the product from becoming contaminated. Additional requirements are temperature control, sealing, and microbes as per international standards.

The CFIA audited an establishment in Scotland producing non-ready-to-eat haggis products to be exported to Canada. The haggis products were cooked at over 70°C for 3 minutes in a plastic tube and were not exposed after the lethality treatment during the cooling and packaging steps. The CFIA observed that the operator controls and monitors the heat treatment and the cooling process, meeting the Canadian cooling control requirements described in the Canadian preventive control recommendations for cooling heat-processed meat products.

In Canada, the operators are responsible for developing and implementing written retained water control programs for carcasses, parts, and meat by-products as per the Canadian requirements prescribed in the Canadian control programs: water retention in edible raw red meat products.

There are no regulatory requirements for implementing a retained water control program for bovine and swine meat and meat products in the UK. As audited, the FBOs did not implement the retained water control program in the swine and bovine slaughter establishments, where water is used in the slaughter and processing processes.

The Regulation (EC) No. 543/2008 lays down detailed rules regarding the marketing standards for poultry meat. The operators have an obligation to carry out regular checks on water absorption by poultry carcasses only (excluding poultry by-products like gizzard, heart, liver)_ during evisceration and cooling processes, similar to the Canadian Poultry water retention control program.

In addition, the FSS, FSA, and DAERA did not perform any official verification task to verify the implementation of the operator water retention program in the red meat and poultry slaughter establishments.

In the UK, Article 31 of Regulation (EU) No. 2019/627 mandates the examination of carcasses of certain animals, including Suidae, solipeds, and other susceptible species, for Trichinella spiralis. This aligns with Regulation (EU) No. 2015/1375, which establishes specific rules for Trichinella testing, exemptions, and controlled housing conditions (CHCs). Domestic swine are exempt from testing if they undergo freezing treatment, are from CHCs, or are under 5 weeks old. Pigs from CHCs are housed without exposure to wild animals and regulated feed to minimize infection risks, though outdoor access is allowed if it doesn't pose a risk.

In contrast, the Republic of Ireland lacks a mechanism to certify CHCs, meaning pigs from Ireland, even if raised under CHCs, must be tested when slaughtered in the UK. The UK's official Trichinella testing is managed by agencies like the APHA and NRLs, which also handle proficiency testing and diagnostics. The FSA/FSS designates NRLs.

The UK government oversees Trichinella controls, with the help of veterinarians and trained staff handling slaughterhouse sampling and testing. Despite CHC pigs being exempt from testing, risk-based surveillance was conducted, with 300 hogs tested annually at one audited slaughterhouse.

No positive Trichinella samples were found during the audit, and carcasses were held until satisfactory test results were received. However, one FSA-certified in-house laboratory showed deficiencies, such as failure to specify sample criteria, unauthorized personnel performing tests, lack of participation in proficiency testing, and inadequate equipment calibration. The laboratory had not yet performed proficiency testing or inter-laboratory comparisons with the FSA's approved NRL.

The laboratory did not document non-conformities, and a supervisor or quality assurance personnel did not verify the results. The laboratory had only been operating since April 2024 and had not been internally or externally audited until the CFIA audit in September 2024.

As per Regulation (EU) No. 1169/2011 and FSA and FSS food allergen technical guidance, the UK priority food allergens include celery, cereal (gluten), crustaceans, molluscs, eggs, mustard, fish, peanuts, milk, tree nuts, soybeans and sesame seeds. The FBOs followed the allergen labelling requirements as per Regulation 1169/2011 regarding substances or products causing allergies or intolerances equivalent to the Canadian food allergen labelling guideline.

The CFIA observed deficiencies in the implementation and the operators' written allergen control programs in the cold storage and processing establishments audited in Scotland and NI. For example, some operator's written allergen procedures didn't include all the Canadian common food allergens such as pine nuts. In some establishments, the allergen control procedures were not effective to minimize cross-contamination between products potentially containing allergens and other products.

The UK follows multiple regulations to ensure food safety through microbiological sampling and testing meat and meat products. Regulation (EC) No. 2073/2005 sets microbiological criteria, and Regulation (EC) No. 2017/625 ensures compliance with these criteria. Regulation (EC) No. 2019/627 outlines practical arrangements for official controls on products of animal origin. The DEFRA oversees the implementation of microbiological sampling plans coordinated by the FSA, FSS, and the DAERA. These plans are risk-based and monitor food safety and hygiene, considering data from previous years.

Key microbiological criteria include Salmonella as a process hygiene criterion for various animals (cattle, sheep, goats, pigs, etc.) and a food safety criterion for raw minced meat. Escherichia coli (E. coli) testing is conducted for minced meat, meat preparations, and mechanically separated meat. At the same time, Listeria monocytogenes is a food safety criterion for ready-to-eat products and related environments. FBOs ensure compliance with these criteria and develop risk-based sampling plans. OVs conduct verifications and validations to ensure proper sampling and testing.

Audits of FBOs revealed that the microbiological sampling plans for 2023 and 2024 were implemented correctly at cattle, swine, and poultry slaughterhouses. Testing for Salmonella, E. coli, Campylobacter, and Listeria was performed at appropriate frequencies. Environmental testing for coliforms and total viable counts was also performed. All audited establishments had a 100% compliance rate for microbiological sampling in 2023, with up-to-date sampling in 2024. The OVs also conducted official sampling for Salmonella and Campylobacter. UKAS-accredited laboratories carried out testing.

A system of regulatory corrective actions and verification was in place to address non-compliance, and the CFIA auditors observed that the OVs verified FBO sampling procedures regularly, including during audit of establishments eligible to export to Canada. No concerns were noted with the UK's microbiological sampling and testing.

There is no regulatory requirement for testing E. coli O157/NM in raw beef in the UK. However, establishments intending to export raw beef to Canada must follow Canadian requirements, including a testing plan for E. coli O157:H7/NM. FBOs implemented a sampling procedure using the N60 method at an accredited laboratory, and the OV verified sampling weekly. If E. coli O157:H7/NM contamination was found, corrective actions were taken, including withdrawing contaminated lots from export. The CFIA auditors reviewed relevant documents and records for verification, training, and auditing of the E. coli testing process.

However, at one of the bovine slaughter establishments, FBO's N60 written procedure for E.coli O157:H7 did not include the most updated reference of the Canadian guideline and the description and evaluation of the high event periods as described in the Canadian Preventive controls for E. coli O157/NM in raw beef products. At another bovine slaughter establishment, where operator tested 3 samples of the beef trims per day for E. coli 0157:H7/NM as a client requirement, the in-house laboratory was not ISO accredited. This establishment did not export beef trims or ground meat to Canada.

The CFIA requests that DEFRA and CAs verify the implementation of corrective actions regarding the establishment's specific findings listed in the document CFIA findings at the establishments visited during the audit of the United Kingdom Meat Inspection Systems.

DEFRA has collaborated with the UK Food Safety Competent Authorities (FSCAs) to distribute and review Corrective and Preventative Action (CAPA) forms for each Food Business Operator (FBO). These forms detail the findings from the audit in September 2024 and require that FBOs provide evidence to demonstrate how they have taken action to address each problem and are verified by the OV and signed off by an employee of the FSCA.

DEFRA can confirm that all FBOs have sufficiently undertaken the corrective and preventative actions to address the problems found according to UK rules and regulations. A summary of actions has been provided to CFIA.

Findings where Canadian rules and regulations differed from those of the UK have been addressed as part of Defra's response to these recommendations.

DEFRA notified the Food Safety Competent Authorities (FSCAs) of further actions. FSCAs worked with the operators to address these issues. The follow up on the corrective and preventative actions has been provided.

The CFIA requests that the Notes for Guidance (NFG) for the issuance of EHCs be updated in consultation with the CFIA.

DEFRA has updated the outdated Note for Guidance (NFGs) with up-to-date links to the CFIA website and relevant Canadian rules and regulations. Typically, Defra creates these NFGs as a guide to UK exporters and certifying officers, without the input of trading partners.

References to Canadian regulations and organisations have been updated in the NFG.

Should the CFIA wish to view the NFGs they can be accessed at:

• 7068EHC-guidance (lamb, goat, pork, beef, bird)
• 7644EHC-guidance (fresh pork)
• 7833EHC-guidance (fresh beef)

The CFIA requests to DEFRA

• To include the head inspection as part of the post-mortem inspection procedure in the ovine slaughterhouse as described in the Canadian post-mortem evaluation procedures.
• The operators' trimming procedure for removing dorsal root ganglia (DRG) from OTM carcasses should clearly describe the process, including detailed instructions based on the Guide to SRM removal. It should include the 2.5 cm standard from the Canadian guideline, with proper validation to ensure consistent removal.

DEFRA implement:

• If intended for human consumption, visual inspection of the head after flaying and examination of the throat, mouth, tongue and retropharyngeal and parotid lymph nodes will occur as per assimilated EU regulation 2019/627.

  If an ovine head is not intended for human consumption, applicable UK legislation does not require the head to be subjected to visual inspection. Excluding the heads from inspection if not intended for human consumption is seen to reduce risk of cross-contamination of meat

  It is considered that inspection of a sheep head at routine post-mortem inspection (PMI) does not contribute anything significant to the ultimate judgement on whether the rest of the carcase is fit for human consumption.

  DEFRA would like to share the scientific risk assessment of the European Food Safety Authority (EFSA) on inspection of meat from sheep and goats (PDF) which supports the UK approach of excluding routine sheep head inspection.

  Post-mortem inspection cannot reliably catch either of the main biological hazards identified in small ruminants, namely T. Gondii and verocytotoxin producing E. coli (page 22). Palpation and incision of organs and carcase parts can cause cross-contamination, and it is therefore recommended that the two processes are omitted during routine slaughter. The safety considerations offered by visual inspection, such as the detection of gross deformations (page 115), would not be considered necessary when the inspected part is not intended for human consumption. A visual-only inspection procedure was therefore recommended, with the head only subject to visual inspection if intended for human consumption.

DEFRA implement:

• DEFRA has written to all FBOs registered to export to Canada to remind them of the Canadian guidelines and the 2.5 cm standard. The Canadian guideline has also been added to the official guidance for the OVs certifying exports to Canada.

  Note that as of June 2025, all zones of the UK are recognised by WOAH as having negligible risk for BSE. CFIA contacts have informed Defra that SRM requirements are applicable only to controlled risk countries. We have submitted revised Export Health Certification for approval to reflect this.

The CFIA requests that the uropygial glands be completely removed from slaughterhouse poultry carcasses, as described in Canadian SFCR article 145.

The UK Food Safety Competent Authorities (FSCAs) do not consider a carcase with uropygial gland to be a food safety concern or to hinder the PMI process. Therefore, the glands are not removed by UK FBOs before presentation for PMI and on the final whole carcass. We note that Canadian guidance similarly seems to allow for uropygial glands to be left on partially dressed carcasses before presentation for PMI and on the final product, and SFCR section 145.2 allows for authorisation of partially dressed carcases provided there is a market and that the carcase is sufficiently dressed to allow for PMI.

See the following links:

1. Procedures for preparation of feet or paws (poultry), head and feet-on carcasses (poultry), head-on (rabbits) for edible purposes
2. Safe Food for Canadians Regulations

DEFRA therefore believes that Canadian regulations can allow for carcasses that include the uropygial gland to be presented for PMI. Defra requests CFIA's confirmation that continuing the export of whole carcasses with the uropygial glands would be permissible within the bounds of Canadian law but welcomes any further guidance that CFIA might deem necessary.

DEFRA is aware of the Canadian requirements on this matter and has added this information to the guidance for exporters and official veterinarians.

DEFRA will act in accordance with the requirements laid out in the dressing procedures. This is regarding "Specific dressing procedures for poultry and rabbits" and specifically "Partial dressing for poultry". Here there is a requirement that "carcasses with oil glands will be appropriately labelled", and that "Partially dressed poultry carcasses must have oil gland removed prior to use for MSM (Mechanically separated meat) or FTM (finely textured meat)".

The CFIA requests that DEFRA and CAs verify that all the FBO's meet the EU freezing requirements.

Assimilated EU Regulation (EC) No. 853/2004 sets the temperature requirements for meat and other meat derived products during storage and transport. The general requirement is that meat intended for freezing must be frozen without undue delay. There are specific freezing temperature requirements of not more than -18 °C for minced meat, meat preparations, mechanically separated meat (MSM), greaves and fishery products. The FBOs' procedures are verified by the Competent Authorities during the delivery of official controls. Defra can confirm that FBOs have addressed the findings related to freezing requirements.

The CFIA requests that red meat establishments that export meat products to Canada implement validated written water retention controls and procedures for the carcasses, parts, and meat by-products when their post-evisceration processing causes excess water retention as specified in the Canadian Control Programs: water retention in edible raw red meat products.

Water retention requirements are only considered applicable where UK FBOs use spray chilling, as this is the only process which could possibly add excess water to the meat.

UK establishments do not carry out pathogen reduction treatments such as chlorine washing. Some FBOs monitor the Chlorine levels, when water is used, to verify the residual chlorine from the treatment of the water.'

DEFRA has written to all FBOs registered to export to Canada to remind them that if they carry out spray chilling then they should implement written water retention controls and procedures as specified in the Canadian Control Programs.

This guidance has also been added to the guidance for OVs certifying export of meat to Canada.

DEFRA has amended guidance for export certification of red meat products from Canada to include a verification before each export that the plant meets this Canadian requirement. The certifying OV must confirm that the FBO either has a written water retention control plan validated by the local OV within the last year or that the plant does not carry out processes which could add additional water to the meat. The local slaughterhouse OVs of sites registered for export to Canada have been made aware of the requirement that they verify these control plans annually or upon a change in processes and communicate this to the certifying OV upon export.

As this is now part of the regular process for certification of export of red meat to Canada, there will be regular official oversight and verification undertaken by APHA.

The CFIA recommends that the operator of in-house laboratories used for trichinella spiralis testing develop and implement documented procedures to ensure reliable testing results, with verification tasks carried out by the CCA to maintain regulatory oversight.

DEFRA has written to all FBOs registered to export to Canada to remind them that if they have an in-house Trichinella laboratory then it should develop and implement documented procedures to ensure reliable testing results.

This guidance has also been added to the guidance for OVs certifying export of meat to Canada.

DEFRA has recently completed a questionnaire to help CFIA determine the equivalency of the UK's Trichinella control program to that of Canada. Defra looks forward to any further collaboration with CFIA on this subject.

The CFIA requests that DEFRA and CAs verify that all the establishments eligible to export meat products to Canada implement a written allergen control procedure that includes all the Canadian common food allergens.

During the audit only one case was found of an allergen that is required to be controlled and declared in Canada but not in the UK. Both UK and Canadian allergen lists contain tree nuts, but only the Canadian list classifies pine nuts as a tree nut.

DEFRA has written to all FBOs registered to export to Canada to inform them that they should include all Canadian allergens in their allergen control plans, including pine nuts.

This guidance has also been added to the guidance for OVs certifying export of meat to Canada.

The CFIA recommends DEFRA and CAs to strengthen the official oversight and enforcement activities considering multiple audit observations regarding Operators' preventive control plans.

The issues identified with FBOs' control plans have been addressed through the corrective action process, OVs have taken enforcement actions to ensure that FBOs address the specific issues. Details of this can be found in Defra's response to CFIAs plant findings.

The need for proactive and preventative maintenance plans has been reinforced through the direct communication with local slaughterhouse OVs. Defra and UK FSCAs have also been working to ensure preventative actions for site findings from the audit where necessary.

The CFIA recommends that FBO's N60 written procedure for E.coli O157H7 must include the most updated reference of the Canadian reference guideline and the description and evaluation of the high event periods as described in the Canadian Preventive controls for E. coli O157/NM in raw beef products.

DEFRA has written to all FBOs registered to export to Canada to inform them that they should include the most updated reference of the Canadian reference guidelines, and the descriptions and evaluations provided in the Canadian preventive controls for E. coli.

This guidance has also been added to the guidance for OVs certifying export of meat to Canada.