Annex D-2: CFIA risk-based Shiga toxin-producing E. coli verification sampling of beef trimmings for abattoirs eligible for export to the USA
1. Purpose and scope
This verification sampling has been designed by the Canadian Food Inspection Agency (CFIA) for abattoirs producing raw beef manufacturing trimmings for the export to the USA. The participation in this program is mandatory for abattoirs in order to maintain their eligibility for export to the USA. The samples will be collected by the operators under the supervision of CFIA Veterinarian in Charge (VIC) and submitted by the operators to private laboratories for the analysis of Shiga toxins-producing Escherichia coli (STEC) O26, O103, O111, O121, O45, O145.
2. Products targeted for sampling
Products targeted for sampling under this program are raw boneless beef manufacturing trimmings, for example, pieces of meat remaining after steaks, roasts and other intact cuts are removed.
3. Frequency of sampling
The normal sampling frequency under this new program will match the frequency under the existing monitoring sampling plan M218 that was determined on the basis of risk considering the following 4 factors:
- production volume
- compliance history
- E. coli O157:H7 robust testing employed by the establishment
the seasonal variations in STEC prevalence
On the basis of production volume the establishments have been divided into 4 categories (as defined in M218): extra large, large, medium and small. The positive E. coli O157:H7 results obtained over the last 120 days under the CFIA monitoring program for E. coli O157:H7 (M201) should be used for the assessment of compliance history. The O157:H7 data is used since the sources of contamination for all 7 STEC are thought to be similar and the interventions employed by operators under their Hazard Analysis and Critical Control Point (HACCP) system are believed to exert a similar protection against O157 and the 6 other STEC.
The number of samples to be collected under the plan will be based on Table 1.
|Establishment size (production volume per year)||Normal frequency Table note 1||Enhanced frequency Table note 3|
|Sampling frequency October to March||Sampling frequency April to September Table note 2||Number of samples per year per establishment||Sampling frequency October to March||Sampling frequency April to September Table note 2|
|1 per month||1 per month||12||2 per month||2 per month|
(25K to 400K kg)
|1 per month||3 per 2 months||15||2 per month||3 per month|
(400K to 40M kg)
|3 per 2 months||2 per month||21||3 per month||4 per month|
|2 per month||4 per month||36||4 per month||8 per month|
- Table Note 1
Generally, all establishments will be sampled at a normal frequency.
- Table Note 2
Includes additional samples taken at each establishment during the high prevalence period of April to September.
- Table Note 3
Enhanced frequency – A compliance history including a positive E. coli O157 result from M218 testing of precursor material or M201 testing of the product downstream will be taken into account when placing an establishment on enhanced frequency of testing for the next 120 days. As well High Event Period (HEP) will be taken into consideration when determining frequency of sampling. HEP is a situation in which an establishment experiences a high number or rate of positive results for E. coli O157. Such a decision will be made by the Area Program Specialist.
4. Procedure for collecting and submitting samples for the analysis
Operators are responsible for collection of samples from the lot that has been selected by the CFIA inspector under sampling plan M218. The operator's written procedure for the collection and submission of samples for analysis will be approved by the VIC. The following steps are to be followed:
4.1. A lot of beef trimmings assembled for sampling under M218 will be concurrently sampled by the operator. A designated employee trained in the N60 sampling procedure will collect samples according to plan M218 at the time when sampling is accomplished by a CFIA inspector and under his or her supervision. The inspector notifies the establishment management 24 hours before the planned sampling. This will provide establishments enough time to hold the entire lot from which the samples are collected pending the result of analysis. The CFIA strongly recommends holding the entire lot pending the result of analysis. The signing official shall review the test results for the product being exported to the United States to ensure that the results are satisfactory before signing the health certificate.
4.2 A random sample will be collected after a lot has been assembled as per the operator's lot definition.
4.3 A sample will be collected aseptically by using N60 method as described in section 5.
4.4 Immediately after sampling the inspector will check and record the product temperature from 1 of the sampled containers (do not take the temperature of the sample). When the temperature of the product is higher than 4°C (40°F), the bag containing the sample will be placed in a cooler to chill before shipping.
4.5 The CFIA inspector will oversee the preparation of sample for shipping as per CFIA standards (tamper evident) using sufficient ice packs and ensure that the sample integrity will be maintained from the collection to shipping.
5. N60 method of sample collection
Samples of beef trimmings will be collected using the N60 method as described below.
5.1 Use the table 2 below for sampling. If a specific production lot is composed of more than 5 containers of raw beef trimmings, randomly select 5 containers for sampling.
|Number of containers in a specific production lot||Number of sample pieces to select from each combo (container)|
5.2 Aseptically collect the appropriate number of pieces as indicated in table 2. The sample is comprised of 60 pieces.
5.3 Using a sanitized knife, cut off a thin slice that is approximately 50 cm2 for each of the 60 pieces [for example 10 cm (4") × 5 cm (2") × 0.3 cm (1/8")]. Collect as much of the beef trimmings outer surface as possible. The priority is to collect samples from pieces of product taken from the original surface of the beef carcass.
5.4 Place the sampled slices into the sterile sampling bag. Weigh the sample to ensure that approximately 1 kg (2 pounds) was collected.
6. Lot definition
A lot is defined as for the sampling under M218. It can consist of 1 to 5 combos.
7. Target organisms
The samples will be analysed for the presence of 6 STECs, namely O26, O103, O111, O121, O45, O145. Some Food Safety and Inspection Services (FSIS) testing methods include the detection of O157. If this is a method of choice, the results obtained on a sample will also include the O157 serotype.
8. Method of analysis
8.1 United States Department of Agriculture/Food Safety and Inspection Service (USDA/FSIS) Microbiology Laboratory Guidebook (MLG) method 5C.03, including previously accepted MLG method 5B.05, can be used for this analysis.
Other methods of analysis may be accepted by FSIS. An establishment may select from the methods list provided in Foodborne Pathogen Test Kits Validated by Independent Organizations, under the STEC tab. However, to be considered acceptable, the method must be:
- Validated for testing relevant foods by:
- a recognized independent body (that is, Association of Official Agricultural Chemists (AOAC), Association Française de Normalisation(AFNOR), MicroVal, NordVal), or
- a U.S. regulatory body (that is FSIS MLG or Food and Drug Administration Bacteriological Analytical Manual (FDA BAM)), or
- an International Organization for Standardization (ISO) method
- The validated method should be:
- fit for the intended purpose and application, and
- performed under validated conditions by a laboratory that assures the quality of the analytical results
The CFIA signing official shall review the test results for the product being exported to the United States to ensure that the results are satisfactory and the correct methodology was used before signing the health certificate.
8.2 It is the operator's responsibility to verify before shipping samples for the analysis that the laboratory: 1) has on their scope of accreditation any of the applicable testing methods described above for analysing raw beef trimmings for the STECs of interest or 2) has initiated the application process with the Standards Council of Canada or the Canadian Association for Laboratory Accreditation to add any of these methods to their scope of accreditation and the laboratory has previously been accredited for at least 1 testing method for other micro-organisms (for example, Salmonella, Listeria monocytogenes, E. coli O157, etc.) in food.
9. Reporting of the results
Operators are required to convey Annex D-2 attachment 1 (STEC in beef trimmings verification sampling template) and Annex D-2 attachment 2 (Instructions for completion of STEC in beef trimmings verification sampling template) to the private laboratories they contract testing to, which include specific instructions for reporting test results to the CFIA.
All results obtained under this program, for example, negative, presumptive positive and culturally confirmed positives will be reported by the operator's contracted laboratory to the CFIA's Food Safety Division for the maintenance of a database and the analysis of results. The results will be entered into the template by the private laboratory and sent along with the supportive Record/Certificate of Analysis to the following address email@example.com.
Positive (present) results should be classified as High Priority or Urgent, and submitted within 1 business day. Negative (absent) results may be combined into 1 template and submitted within the last week of each month.
10. Follow-up on positive results
10.1 Trimmings that tested presumptive positive (that do not confirm as negative if confirmation methods are performed), and/or confirmed positive for any of the 7 STEC of interest must not be exported to the USA also will not be released into domestic market.
10.2 The operator may choose to confirm culturally the presumptive positive results or treat presumptive positives as confirmed positives and as such can only dispose of these trimmings as per requirements outlined in the Preventive controls for E. coli O157/NM in raw beef products the guidance for E. coli O157:H7. Presumptive positive results that confirm culturally to be negative (for example, the screen method gave a false positive result), may be considered suitable for sale on the market place.
The operator will notify the CFIA inspector within 24 hours of negative and presumptive positive results. Upon receiving a presumptive positive result, the inspector will immediately ensure that the implicated trimmings are on hold. In the case that the implicated trimmings were distributed, the inspector will immediately notify the Area Meat Program Specialist and Area Recall Coordinator.
STEC in beef trimmings verification sampling template sample information
List of US eligible beef slaughter establishments required to report Shiga toxin-producing E. coli (STEC) verification laboratory test results in raw beef manufacturing trimmings in slaughter establishments eligible for export to the USA
011, 038, 051, 058, 076, 093,183, 431, 443, 454, 466, 506, 657, 663, 763, 794, 902
Instructions for completion of STEC in beef trimmings verification sampling template
Color coding of the template
- Peach cells: data needs to be entered by the lab,
- Yellow cells: drop-down menus provide the data options to be entered by the lab,
- Blue cells: the data auto populates and is dependent on information entered in other cells,
- Laboratory information: enter the laboratory name and city information at the top of the template using the following format: laboratory name, city
- Completion and verification of sample information:
- enter unique job/project number as found on record/certificate of analysis
This number is issued by the lab for internal tracking purposes
- verify the lab name, city (column C) and enter the province (column D)
- select the appropriate registered establishment number, of the meat establishment for whom the samples have been analyzed, from the drop-down menu
The establishment name and province will auto populate based on the registered establishment number entered
- verify the establishment name and province
If this information is not correct, re-check the registered establishment number that was entered. If the establishment you are searching is not available please contact CIFA at: firstname.lastname@example.org
- enter the unique sample ID as assigned by the laboratory for tracking purposes
- enter the product name and a brief description of the product which was analyzed
- select the appropriate temperature range from the drop-down menu which encompasses the temperature of the product upon reception at the lab
- enter the following dates: the date sampled, date received at lab, and date analysis was completed
- from the drop-down menu select the screening method used
- from the drop-down menu, identify the analytical result of the screening method
If a presumptive positive is being reported as a confirmed positive, and no confirmatory method is being performed, go directly to step 2.
- if the screening method was positive, use the drop-down menu to identify the confirmatory method used
- identify the analytical result of the confirmatory method from the drop-down menu
- identify which E. coli serotype was identified, using the drop-down menu
If more than 1 serotype is identified separate lines of data entry are required for each positive. If a presumptive positive is being reported as a confirmed positive, select "presumptive positive" from the menu
- enter unique job/project number as found on record/certificate of analysis
Please note if, for whatever reason, the laboratory is unable to analyse the sample submitted for analysis, the operator is expected to submit a replacement sample as soon as possible.
- All results must be reported to the Operator as soon as they are available
- Results entered into the template along with the supporting record/certificate of analysis must be reported to the Food Safety Division, CFIA through the dedicated email account: BT-PDB@inspection.gc.ca
- The subject line of the e-mail should be of the format: Lab name – Job number
- Emails reporting positive (present) results should be classified as high priority or urgent, and submitted within 1 business day.
- Negative (absent) results may be combined into 1 template and submitted within the last week of each month
- Please do not report confirmation of sample receipt through this email account
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