Annex Q: Compliance guideline on pre-shipment review and on eligibility of incoming meat products
1. Pre-shipment review
(i) Requirements applicable to operators
Prior to shipping any meat product from the establishment, the operator shall review all the Critical Control Points (CCP) records associated with the production of that product to ensure completeness, that is:
- CCPs were monitored and documented as required
- the determination that all critical limits were met and
- if appropriate, corrective actions were taken, including the proper disposition of product
This review shall be conducted, where practicable, by an individual who did not produce the record(s) or by the responsible establishment official. That person shall be trained in accordance with Food Safety Enhancement Program (FSEP) prerequisite program (technical training, sub-element D 1.2).
Pre-shipment records must be signed and dated by the designated plant employee.
Pre-shipment review can be done as part of the Hazard Analysis Critical Control Point (HACCP) system verification procedures as long as this is defined in the establishment's HACCP written program and that all pre-shipment (see above) and FSEP requirements are being met; otherwise, the operator will have to develop a written auditable protocol specifically for pre-shipment review.
In any case, frequency of pre-shipment review and deviation procedures to initiate whenever pre-shipment requirements are not being met need to be specified for each HACCP plan.
The frequency of pre-shipment review should prevent the shipment of products prior to completion of the review of required records. It is strongly suggested to adapt the frequency based on the establishment production context (for example, continuous production, multiple lines, product flow, etc.).
Pre-shipment review can be accomplished at a location other than the producing establishment for products being sent to storage when:
- the written procedures developed by the operator are acceptable to the responsible inspector at the producing establishment and a copy of these procedures are available to the inspector at the shipping establishment
- the procedures implemented by the operator at both establishments are being followed and are effective
- the review of appropriate documents and compliance with pre-shipment review requirements occur before the product leaves the control of the operator of the producing establishment and
- the establishment where the product is stored is part of the same company as the producing establishment in order to ensure appropriate controls
(ii) Verification of compliance with pre-shipment review requirements by the CFIA
Verifying that the establishment has completed pre-shipment review enables inspection program personnel to know whether the company has taken full and final responsibility for applying its HACCP controls to the product that it has produced. The responsible inspector shall perform a verification check by doing, in addition to the record review, on-site observations. The on-site observations do not involve the actual audit of the CCPs; the purpose of these observations is to confirm that the CCPs are monitored, that appropriate corrective actions are taken by the operator whenever critical limits are not met, that pre-shipment procedures are being followed and that pre-shipment review is completed prior to shipping any meat product from the establishment (unless provisions as per above are met). Pre-shipment requirements are verified through the applicable CVS verification task (task 3101).
When verifying an establishment's pre-shipment review the inspector should verify:
- that the operator has reviewed all the CCP records associated with the production of the product, prior to shipment (the CCPs were monitored and documented as required, all critical limits were met and, corrective actions were taken, including the proper disposition of product, when applicable) and
- that the pre-shipment review has been signed and dated by an establishment employee
2. Controls over incoming meat products
(i) Operators of each establishment listed in Annex W must, during the period of time it is considered eligible for export, include in their receiving procedures, traceability controls that will demonstrate that all US eligible production is composed only of US eligible meat. The control programs must ensure that eligible products can be distinguished from those that are not eligible through receiving, processing, packaging and shipping. The control programs must be auditable and include monitoring, verification, deviation and record keeping procedures. Receiving procedures should include how the eligibility of the meat products received is determined (for example, copy of the Official Meat Inspection Certificate (OMIC), additional attestation and shipping marks in the case of imported products; letters of guarantee from suppliers in case of domestic products, etc.,).
(ii) Imported meat products
Imported meat products used to manufacture products intended for export to the USA must meet all applicable USDA requirements (APHIS and FSIS, as applicable). Canada and the USA may differ regarding the countries that are permitted to export into the respective country, so it must never be assumed that because meat is legally imported into Canada that it can be used as such in the production of meat products for the USA.
The eligibility of imported meat will be established on the basis of official attestation of compliance with USDA (APHIS and FSIS, as applicable) requirements provided by the competent authorities (CA)Footnote 1 of the country of origin of the products. It is important to note that the compliance attestation will be provided by the CA on a voluntary basis and at the request of trade parties, as such compliance attestation is not a Canadian import requirement. Operators are responsible to obtain and provide the required proof of compliance to the CFIA inspector for every import shipment from which meat products will be used in production destined to the USA.
When imported meat products are used in production destined to the USA, the signing official can consult the Food Safety and Inspection Service, Import and Export Library for eligible countries and products.
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