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Final Report of an Audit Conducted in the People's Republic of China to Evaluate Poultry Meat Inspection System and Establishments Producing Stuffed Grain Products

Table of Contents

Abbreviations and Special Terms Used In the Report

AAFC
Agriculture and Agri-Food Canada
AM
Ante-mortem
AQSIQ
General Administration of Quality of Supervision, Inspection and Quarantine of the People's Republic of China
CCA
Central Competent Authority
CPP
Critical Control Point
CFDA
China Food and Drug Administration
CFIA
Canadian Food Inspection Agency
CIQ
Local Entry and Exit Inspection and Quarantine Bureaus/Authorities
CNCA
Certification and Accreditation Administration of the People's Republic of China
DOA
Dead on Arrival
DVM
Doctor of Veterinary Medicine
EOS
Export Oriented Scheme
FS
Food safety
GMP
Good Manufacturing Practices
HACCP
Hazard Analysis and Critical Control Point
MOA
Ministry of Agriculture
NC
Non Compliance
POE
Port of Entry
PM
Post-mortem
SOP
Standard Operating Procedure
SSOP
Sanitation Standard Operating Procedure

Executive Summary

This report describes the outcome of an on-site maintenance audit of the poultry meat inspection system and the assessment of five establishments producing grain products stuffed with ingredients (dumplings) based on the protocol (Importing and Exporting Grain Products Stuffed with Ingredients between China and Canada) between the General Administration of Quality Supervision, Inspection and Quarantine of the People's Republic of China and the Canadian Food Inspection Agency. The audit was conducted from September 11th to 20th, 2017 in the People's Republic of China.

The main objective of the audit was to verify that the food safety systems governing meat products in the People's Republic of China are functioning in a manner determined to be equivalent to that of Canada i.e. producing meat products that are safe, unadulterated, and properly labelled.

The scope of assessment focused on verification of activities within the following areas:

Overall, the audit results showed that poultry meat inspection system in the People's Republic of China is performing as intended in an adequate manner and generally demonstrated an acceptable implementation of controls for all areas described above.

All five dumpling establishments were under normal production status on the auditing day and no major food safety issues were observed.

The CFIA has concluded that the inspection oversight and production system of the five dumpling establishments was adequate, and implementation of controls was acceptable. The five audited establishments will be able to export meat products to Canada once the required steps regarding finalization of import requirements, official meat inspection certificate, and listing of the establishments on the CFIA website are completed.

1 Introduction

1.1 Background

In January 2007, the Canadian Food Inspection Agency (CFIA) conducted a preliminary mission to assess poultry meat inspection system, rabbit meat inspection system and chemical residue monitoring program in the People's Republic of China. In January 2010, a follow-up mission was conducted to assess the inspection system for poultry meat and meat products.

In September 2016, the CFIA and the General Administration of Quality of Supervision, Inspection and Quarantine of the People's Republic of China (AQSIQ) signed the Protocol on Importing and Exporting Grain Products Stuffed with Ingredients between China And Canada ("the Protocol") to facilitate the bilateral trade of certain processed products wrapped in a grain-based shell and stuffed with meat, fish, vegetables and/or eggs. Implementation of this protocol required development of import/export program elements and audits/inspection of establishments in China and Canada.

The CFIA performed an audit in the People's Republic of China from September 11th to 20th, 2017. In this report, hereafter, grain products stuffed with ingredients will be referred as "dumplings"; the establishments producing grain products stuffed with ingredients will be referred as dumpling establishments.

1.2 Audit Objective, Scope, and Methodology

In preparation for this audit, the CFIA used a risk-based procedure to determine the audit scope, which included an analysis of the types of products.

Program effectiveness determination focused on the government controls and oversight. The scope of assessment focused on verification of activities within the following areas:

Administrative functions were reviewed at the Central Competent Authority (CCA) headquarters, Local Entry and Exit Inspection and Quarantine Bureaus/Authorities (CIQ) and branch offices, during which the auditors evaluated that inspection, verification, and enforcement activities, were being implemented as intended. The CFIA auditors verified the meat inspection system and its implementation via a review of documents/directives/regulations used during this audit.

Representatives from the AQSIQ and CIQ accompanied the four CFIA auditors (split into two teams) throughout the audit. Counselors from the Canadian Embassy, one representing the CFIA and the other representing Agriculture and Agri-Food Canada (AAFC) also accompanied the audit teams.

Table 1 Summary of Audit Activities
Competent Authority/Establishment Visits Number of Sites Visited Locations
Headquarter- AQSIQ 1 Beijing
Regional office- CIQ 2

Shanghai

Hebei

Branch Office- CIQ 1 Yangshan
CIQ Technical Centre laboratory 1 Shijiazhuang
Port of Entry Inspection station 1 Yang Shan
Dumpling establishments 5

Qinhuangdao

Zhucheng

Anqiu

Canning establishment 1 Shanghai
slaughter establishment - Poultry 2

Qingdao

Liaocheng

Processing Cooked Poultry Meat establishment 1 Anqiu
Cold Storage 2

Zhucheng

Anqiu

1.3 Legal Basis for the Audit and Audit Standards

The audit was undertaken under the specific provisions of Canadian laws and regulations, in particular:

The audit was conducted in a manner consistent with conventional program delivery audit standards, and was intended to assess the degree to which inspection activities performed by the CCA were consistent with the regulatory and procedural requirements and specifications.

2 Competent Authority and Oversight

2.1 Regulatory Framework

Multiple laws are adopted by People's Republic of China for establishing, designing and implementing the control procedures of the meat inspection system. These laws are supported by administrative measures, specifications and standards.

The four principle laws are:

Conclusion:

The People's Republic of China has the required regulatory framework for designing, establishing and implementing the control procedures of the meat inspection system.

2.2 Oversight Framework

AQSIQ develops the annual plan to audit the regional CIQs. Selection of regional CIQ is based on the risk (type of product, export/import volume, non-compliances history etc.). Additionally, the regional CIQs have a Supervision and Monitoring Branch, which is responsible to develop the annual plan to audit the branches within each CIQ. Selection of branches for audits is based on risk and is determined by type of product, export/import volume and non-compliance history.

Frequency of oversight is based on the risk and importing country requirements. For slaughter establishments, daily presence is required. CIQ oversight is provided whenever there is slaughter. CIQ and Ministry of Agriculture veterinarian work jointly and maintain a daily presence. CIQ officials verify the food safety controls and Ministry of Agriculture (MOA) officials are responsible for the oversight of the ante and post-mortem inspections. Only CIQ officials overview the activities in the processing plants. It must be noted that all CIQ and MOA officials referred to in this text are qualified veterinarians.

Regional CIQs is responsible to provide direct oversight of processing establishments, and develop annual site inspection plans for registered establishments under their jurisdiction based on risk assessment and review of establishment reports. In the establishments audited, monthly or quarterly site inspection visits were scheduled for those who had been registered abroad (outside China) and were based on regulations and technical requirements of relevant exporting countries. Risk assessments are completed for each establishment and frequency of oversight is determined accordingly. Regional CIQs are responsible to develop the plan and complete the risk assessment of the establishments. The risk assessment considers factors such as, but not limited to, AQSIQ alert system, domestic food safety events, quarantine and inspection results, non-compliances, surveillance and product sample testing, unsatisfactory products.

The local CIQ supervisor must perform one visit per year to assess the effectiveness of the establishment's quality management system. This visit is also an opportunity to evaluate the quality of the verification skills of the CIQ officials and to identify the additional necessary training to carry out the inspection functions and duties. The CIQ officials use an internal website which functions as a communication platform with secure access for administrative matters, internal management issues and leave applications.

During the audit, the CIQ verifies different aspects of the meat inspection system. For example, the scope includes verification of HACCP, SSOP, QMS, sampling program, formulation, labelling, follow-up of non-compliance, etc. However, the meat inspection system does not set the specific prescribed verification frequency of the tasks. The prioritization and the verification frequency of the tasks are decided by the CIQ supervisor and the designated official together. The site inspection frequencies could be increased or decreased based on their risk assessment. Factors like potential risks, type of commodities, non-compliance history and the previous tasks completed during the year in the establishment are taken into account.

The pre-operational verification task includes the visit of the establishment and equipment before production. The monthly operational visit includes the verification of the implementation of HACCP and an inspection of production rooms. When the visit is completed, the CIQ official fills out a monthly supervision report. The term supervision is used because the establishment is registered under the "supervision" of the CIQ. This supervision report serves as evidence of the CIQ visit. The monthly supervision report includes the following information:

In all establishments audited, verification report didn't include records of the verification activities details, such as information about the area visited, name and title of the personnel interviewed, the equipment selected, the name of the records and Critical Control Points (CCP) reviewed during the task etc The report is printed out and a copy is given to the operator. Only the paper form of this report is kept in the CIQ local office. The MOA and CIQ supervisory reports and the verification reports are kept for two years.

Conclusion:

Based on the document review the inspection was completed as per Chinese regulatory requirements. However, all the details of verification activities such as information about the area visited, name and title of the personnel interviewed, the equipment selected, the name of the records and CCP reviewed during the task etc., were not recorded in the verification report, which is not aligned to Canadian requirements, as described in the CFIA's Meat Hygiene Manual of Procedures, Chapter 18.7.2.5.

2.3 Training Framework

The Civil Servant Law of the People's Republic of China Chapter X specifies that Veterinarians from official agencies should be trained. The competent authority should carry out training based on the functions and duties of civil servants and for those newly-employed civil servants who assume their posts for the first time.

All the CIQ officials and supervisors interviewed during the audit have a major degree in DVM. Veterinarians to be recruited should have more than two years of grass-roots working experience in relevant specialties. After the recruitment, the veterinarian has to enroll in one year of internship including training about administrative tasks, China's laws and regulations, food safety controls and exportation requirements. An entrance examination has to be successfully completed after a year of internship.

The CIQ officials receive both a basic and continuing training. Both in class and electronic platforms are used for training. This continuing training includes training session about export requirements and the use of new technologies. AQSIQ requires veterinarians to complete a certain amount of hours of professional training. On an ongoing basis, training is completed by the AQSIQ and regional CIQ's. On a yearly basis, a training plan is developed to ensure that all mandatory training is covered for all inspectors within certain time frame. All training records are kept electronically. The CIQ supervisors have to receive both continuing on-line training and the training sessions from provincial CIQ offices and AQSIQ.

Conclusion:

CIQ officials and supervisors have received a basic and continuing training in accordance with Civil Servant Law of People's Republic of China.

2.4 Export Controls

The Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products specifies that Inspection and Quarantine establishments should review inspection reports and loading & transportation records related to meat products intended to be exported and submitted for inspection, and conduct evaluation based on daily inspection, monitoring and spot-inspection. If relevant requirements are met, the inspection and quarantine certificates are issued.

A CIQ designated official of the processing establishment is responsible for overviewing the export controls. The monthly CIQ visit includes the verification of the operator exports controls and document review. Records are kept at the local CIQ office. The preparatory phase and the visual verification of the shipment of the product to be exported is the responsibility of the operator's designated employee.

During the preparatory phase of exportation, the operator's designated employee has the control and the authority to pre-stamp the container (carton box) with the CIQ stamp. The CIQ export stamp doesn't bear the registration number of the establishment and the number of the associated export certificate. The operator also gathers the following export related information, which is kept in the operator's office:

Eight to ten days before the intended export date, the operator fills out an application form, issues the export certificate and sends it with all the documents to the responsible CIQ office. The CIQ designated official can schedule a visit if necessary. The CIQ officials are responsible for reviewing the application, the certificate and the documentation. If the documentation package is complete and the products are eligible to export, the CIQ official signs the export certificate (veterinary health/hygiene certificate). Export is allowed only after the food to be exported passes inspection and quarantine.

AQSIQ maintains the requirements for importing countries electronically by using the system called AQSIQ Import and Export food Safety System. The CIQ officials have access to the export requirements of the foreign country and the list of establishments eligible to export via the CIQ internal website.

The CIQ supervisor and the designated CIQ official perform the verification of all the associated export controls of the establishment, the HACCP and pre-requisite program controls and an on-site visit of the establishment at least once a year. An additional supervisory visit is required to be performed every time by the local CIQ if the establishment wants to expand exportation to a new country.

The CIQ supervisor records the findings in the report named "Exporting Food Production Establishment". This report is sent to CIQ senior management and the CCA AQSIQ via the CIQ internal electronic system. Every four years, CIQ supervisors perform a detailed audit based on document review and an on-site visit to verify the up keeping of the export eligibility of the establishment and the results are sent to AQSIQ electronically.

Conclusion:

Canadian export controls are adequately verified in the establishments eligible to export, as per the People Republic of China's Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products (Article 36).

2.5 Enforcement Framework

As per article 49 of the Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products, where meat products intended for export may cause or have caused damage to human health, producers should take measures to avoid or reduce damage and immediately report the situation to the local inspection and quarantine authorities. As per article 34 of the Administrative Measures for Import and Export Food Safety, if the meat and meat products fail inspection and quarantine, the inspection and quarantine authority will issue a certificate of failure. Corrective actions will then be used to make the export product safe and eligible to export. Meat and meat products will be allowed for export only after the products pass inspection and quarantine. If corrective actions cannot be undertaken to make the product safe according to the law and it still fails to pass inspection and quarantine, export will not be allowed.

In the slaughter establishments, both MOA and CIQ are responsible for taking regulatory enforcement actions if non-compliance is observed. Under the Meat Dressing Enterprise Sanitation Registration Specification, the official veterinarians have the right to slow or stop the evisceration line. During the ante-mortem and post-mortem inspection, the MOA and CIQ officials have the power to stop the slaughter and evisceration, seize, detain and condemn the birds or meat products. If the humane transportation, humane handling of the birds, or the food safety of the meat products is compromised, MOA and CIQ requests the operator to take immediate actions to correct the non-compliances.

The non-compliances and the corrective/preventive actions are recorded in the monthly supervision report. The monthly report is printed out, given to the operator and discussed during a meeting between CIQ and the operator. The operator is required to provide corrective and preventive actions in a written plan (rectification reports) to CIQ the following week.

Conclusion:

An enforcement framework is in place and it appropriately addresses the non-compliances related to food safety, animal welfare and food fraud, as per the Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products.

2.6 Laboratory Infrastructure

There are three national veterinary reference laboratories, four national veterinary diagnosis laboratories, four national veterinary drug residue benchmark laboratories and eight national-level veterinary drug safety assessment laboratories. The national reference laboratories are responsible for confirmatory diagnosis of relevant epidemics.

AQSIQ has set up a total of 452 laboratories at its direct-controlled inspection and quarantine bureaus and their branches and sub-branches, of which 110 food testing laboratories are responsible for inspection and quarantine of import/export animals and animal products. Chinese National Accreditation Services (CNAS) is responsible for the accreditation of laboratories involved in the microbiological and chemical residue testing. ISO 17025:2005 standards are being used by the CNAS. Accreditation was completed every three years with a one mid-year review. In the laboratory visited during this audit, management and technical requirements were assessed. Management requirements included organization, quality management, document controls, control of non-conforming testing, and internal audit. Technical requirements included personnel, accommodation and environmental conditions, test methods and methods validation, equipment, material used in testing, handling of test items, quality of test methods and reporting of results. Test methodology was selected based on national standards (CNAS standards) or provincial standards. Validation was completed prior to using the test based on national/provincial standards. No deficiency was noted during on-site audit.

Conclusion:

AQSIQ has an appropriate laboratory infrastructure to perform the microbiological and chemical residue testing for meat and meat products.

3 Ante-Mortem, Humane Handling and Animal Welfare Controls

The two slaughter establishments audited are owned and operated by their respective parent company. These establishments are parts of an export-oriented system (EOS) called the "Unification Five" in Chinese, where the parent company controls the breeders' farms, the broilers farms, the feed mills, the slaughter establishments and the processing establishments. Only birds originating from the identified and registered farms are allowed to be slaughtered in the poultry slaughter establishments.

3.1 Traceability and Animal Identification

In the poultry meat inspection system, the MOA veterinarians perform two ante-mortem inspections: one at the farm and one at the slaughter establishment. The Animal Epidemic Prevention Law of the People's Republic of China ensures that animals and animal products to be sold or transported are allowed to leave the places of origin only after they have passed official veterinary quarantine by local county-level animal health supervision authorities and the Animal Quarantine Conformity Certificate has been obtained. This certificate is valid for 24 hours within the province.

The groups of poultry are raised, fed and receive the same treatments and shipped to slaughter establishment from approved, identified farms. The MOA veterinarian at the farm supervises the apposition of a seal after the ante-mortem inspection. The seal is inviolable and have an individual identification code of 4 letters and 7 numbers indicating the location of the farm. The seal sequence is specific to the one MOA farm veterinarian and the colour of the seals changes during the year to prevent falsification. The purpose of the seal is to control any illegal unloading of birds during the transportation.

The Animal Quarantine Conformity Certificate included the following information as:

Both audited slaughter establishments identified the live bird receiving inspection as a Critical Control Point (CCP) in their HACCP plan. The criteria of this CCP include the verification of farm of origin, the Animal Quarantine Conformity Certificate, the birds monitoring records, the raising records and the verification of the medication withdrawal period. If the review of these documents shows non-compliance, the employee at the live receiving must communicate with MOA.

Conclusion:

The control over the identification of the birds was found to be delivered as described in The Animal Epidemic Prevention Law of the People's Republic of China.

3.2 Ante-mortem Inspection

According to the Administrative Measures for Animal Quarantine, Article 22, the official veterinarians should check the Animal Quarantine Conformity Certificate and livestock/poultry signs relevant to animals to be slaughtered, inspect their health condition, and isolate those suspected of suffering from epidemics for observation. The ante-mortem inspection is performed at the slaughter establishment by another MOA official veterinarian at each arrival of a truck with birds. The ante-mortem inspection includes:

If the operator and MOA inspection is compliant and the birds are accompanied by documents, the seal is removed and the slaughtering of the birds is approved by the MOA. If the inspection reveals non-compliance (no/incomplete accompanying documents, epidemics, pesticide & veterinary drug), the MOA disapproves the slaughtering of the birds, initiates an investigation and informs the operator about the situation.

In accordance with the Animal Epidemic Prevention Law of the People's Republic of China, Regulation on Emergency Response to Major Animal Epidemics, Administrative Measures for Reporting of Animal Epidemics and Procedure for Safe Biological Disposal of Diseased Animals and Their Products (GB16548), if the inspection reveals the presence of notifiable diseases and high DOA, the MOA official veterinarian initiates the segregation of the suspect birds, informs senior management and conducts sampling for laboratory analysis.

Conclusion:

The ante-mortem inspection was completed as described in the Animal Epidemic Prevention Law of the People's Republic of China.

3.3 Humane Handling and Animal Welfare Controls

The MOA official veterinarian is responsible for verifying the humane handling and the animal welfare control at the ante-mortem inspection according to the Good Manufacturing Practices (GB/T 20575-2006). The cleaning and disinfection of the vehicles transporting the animals is monitored. Animals suffering from any disease or defect that may affect public health are separated from other animals.

The DOA level is verified according to the GMP procedure of the operator. For example, the limit of the DOA in the GMP is 0.5%, and if the rate is higher, then the correctives actions have to be implemented. If the condition of transportation is determined as non-compliant, the MOA official informs the operator, and the MOA veterinarian at the farm has to analyse the root causes. If long delays between the arrival of the birds and the slaughter operations are observed, the birds are re-oriented to another slaughtering facility.

The effectiveness of the stunning is verified by MOA officials at the minimal frequency of once per day. The MOA officials visually verify the stunned birds (sign of any recovery of the sensibility). The verification of the control panel indicating the amperage and the voltage is completed by MOA officials. The voltage verified varied between 35 and 80 Volts during this audit.

Conclusion:

Birds were subject to an appropriate humane handling and stunning before slaughtering, as described in China Specification of Good Manufacturing Practices for Chicken Slaughtering GB/T 19478-2004 and GB/T 20575-2006.

4 Slaughter and Post-Mortem

The article 33 of the Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products (Order of AQSIQ No. 136) specify that the Inspection and Quarantine Authorities may send official veterinarians to perform supervision management of export meat producers. The auditors observed all carcasses were subjected to official inspection.

MOA and CIQ are responsible for the inspection and the verification tasks in the slaughter establishments. MOA officials' responsibilities are essentially oriented towards performing the inspection of the carcasses and the parts. CIQ officials complete all food safety related tasks to verify operator's control of the HACCP plan and pre-requisite programs. According to interviewed officials, MOA and CIQ communicate and work together in case of non-compliant situations.

In both slaughter establishments audited, MOA veterinarians were responsible to perform a complete post-mortem inspection of all the carcass exterior, abdominal cavity and corresponding viscera. The operators provide competent plant employees as helpers. A carcass-by-carcass inspection is performed at the inspection station. MOA officials verify the exterior carcass surface and the corresponding viscera. If abnormal localized and generalized conditions are detected, the MOA officials can seize, condemn or remove the carcass/viscera from the evisceration line for further inspection by the MOA supervisor or off-line reprocessing.

As described in Specification of Good Manufacture Practice for Fresh and Frozen Meat Processing (GB/T 20575-2006, part 9.2.11 g), the operator promptly removes carcass faeces and other contaminants during slaughtering. One of the slaughter establishments audited first trimmed the contamination then rinsed the carcass with water. The other only rinsed immediately the contaminated carcass with water. If the contamination is judged severe by the MOA official, the carcass and its parts are condemned. During the audit, it was observed that the contamination of the carcasses was minimal and the off-line reprocessing was immediately performed with no accumulation of carcasses at the reprocessing station.

An MOA official inspects the abdominal cavity at the second inspection station. If abnormal localized and generalized conditions are detected, the MOA officials can seize, condemn or remove the carcass from the evisceration line for further inspection by the MOA supervisor.

The inspection of the Finished Product Standards (FPS) is performed by the designated operator employees at the pre-chiller inspection station. The FPS includes the inspection of the carcass dressing defects as the fecal and ingesta contamination, the general disease abnormalities and other carcass defects (bruising, blood, feather pins). This inspection station is identified as a CCP by the operator with the criteria to check every carcass for zero tolerance for fecal and ingesta contamination before the carcasses enter the chiller.

Conclusion:

The post-mortem inspection was completed as described in the Poultry Slaughter Quarantine Procedure (Nong Yi Fa [2010] No. 27).

5 Processing

5.1 Thermal Processing

Appropriate heating, cooling, freezing and temperature monitoring devices should be provided based on food production characteristics. The steaming process for dumplings varies by establishment. Poultry meat is cooked in steaming chambers with internal temperature ≥ 75°C for five minutes. All establishments have temperature automatically controlled and displayed on the panel. Manual verifications are conducted after the cooking process.

There are three thermal processes observed from this audit for dumplings:

  1. Single layer tunnel steamer: Dumplings are steamed individually in the closed tunnel on the conveyor, with only one layer inside the steamer. The temperature of the steam is set at 100°C. Time and temperature are controlled and displayed on the control panel outside of the steaming tunnel. The whole enclosed tunnel is divided into three parts, the first two parts are for proofing and the third part is for steaming. Quality and the internal temperature of buns are verified manually after the process.
  2. Steaming chambers: Products are loaded into carts on trays with identification attached on the carts. One chamber can fit in two carts. Each chamber has a probe attached. The probe is inserted into the cold spot of that specific chamber, which is determined by using a Heat Distribution Detector. Internal temperature of products holds at 80°C for three and a half minutes or 75°C for 5 and half minutes depending on the size of the product.
  3. Oil Fryer: Spring rolls are deep fried by going through the heated oil tank at 155°C to reach an internal temperature of higher than 70°C. There is no fixed cooking time for the frying process and the employee judges by observing the colour change. Manual temperature check after frying is conducted per hour. During the audit, internal temperature was recorded at 83°C.

Conclusion

Cooking of poultry meat and dumplings was adequately completed as per requirements prescribed in the Meat Hygiene Manual of Procedures, Chapter 10. Annex A: Conditions for importation of meat products from China (the People's Republic of China).

5.2 Chilling/Freezing Controls

As specified in the Specification for Livestock and Poultry Dressing Sanitation (GB 12694-2016), as required by process, post-slaughter carcass and edible by-products should be pre-cooled immediately. After cooling, central temperature should be kept below 4°C for poultry and 3°C for offal products. The chilling temperature of the poultry carcasses was controlled and verified via a CCP immediately after their exit from the chiller. The core temperature of carcasses has to reach less than 4°C in a period of time of 60 to 70 minutes. No chilling controls were present for poultry giblets and feet. These two products are immediately shipped to an external contractor and are not exported to Canada.

It was observed at the audited establishments that both cooked poultry meat and dumpling products are cooled down in the chilling room before freezing. After taking out from steaming chambers, products are pushed into the chilling room displaying a temperature of 8.3°C for about half an hour to let internal temperature reach below 50°C.

All steamed or fried dumpling, go through a spiral or flat Quick Freezer to reach internal temperatures of −18°C within 30 to 90 minutes, depending on the size and shape of the product. Temperatures and time are controlled and displayed on the panel outside of the freezer. The acquired freezing time for the specific product is adjusted by controlling the speed of the conveyor. Temperature verification is conducted manually by inserting a probe into the product after freezing. The temperature of the frozen product is verified automatically controlled and also verified manually every hour.

Conclusion:

The inspection oversight for chilling/freezing controls was found to be adequately delivered, as detailed in the Specification for Livestock and Poultry Dressing Sanitation (GB 12694-2016).

5.3 Water Retention

In the two slaughter establishments audited, the water retention control program of the poultry meat is validated every year by the operator. It can also be re-validated when any change occurs regarding the equipment used during the evisceration or post-evisceration process. The number of carcasses used during the validation is twenty. The water retention tolerated limit is less than 8%, which meets Canadian requirements. The water retention results audited in one of the slaughter establishment was 6.9%. No water retention validation was completed for offals which are not eligible to export to Canada.

Conclusion:

The water retention control program audited for poultry meat products meets the Canadian requirements on retained water control programs described in the Meat Hygiene Manual of Procedures Chapter 19.8.3.

5.4 Allergen Control Program

National Food Safety Standard - General Rules for the Labeling of Prepackaged Food (GB7718-2011) lists the following allergens:

  1. Crustacea and crustacean products (such as shrimp, lobster and crab);
  2. Fish and fish products;
  3. Egg and egg products;
  4. Peanut and peanut products;
  5. Soybean and soybean products;
  6. Dairy and dairy products (including lactose);
  7. Nut and nut meat products;
  8. Cereals and cereal products containing gluten (such as wheat, barley, oat, spelt or their hybrids).

All audited establishments have written allergen program in place. All materials used in the product are in compliance with Chinese regulations which require verification of the supplier's analysis report. Allergen control programs listed major allergens depending on the exporting countries and regions' requirements. Canada's main allergens are included in the written program. During daily production, establishments have identified allergens of concern for that production day in the dry ingredients room.

Conclusion Dumpling Establishments:

All establishments audited had an adequate allergen and labelling control program as per the National Food Safety Standard - General Rules for the Labeling of Prepackaged Food (GB7718-2011).

6 Pre-requisite Programs and HACCP Plans

Chapter I General Provisions of the Administrative Provisions on the Filing of Export Food Producers specifies that producers exporting food products should establish and implement food safety and sanitation control systems with hazard analysis and preventive control measures as the core, and ensure effective system operations, so as to ensure continuous compliance of export food production, processing and storage with the statutory requirements of China, laws and regulations of relevant import countries (regions), and safety and sanitation requirements on export food producers.

6.1 Pre-requisite Programs

6.1.1 General Construction Requirements

The National Standard for Food Safety Specification for Livestock and Poultry Dressing Sanitation (GB 12694-2016) specifies that, water should be in compliance with the Standards for Drinking Water Quality (GB5749-2006). Water for production in slaughtering and processing establishments should be in compliance with GB5749.

All establishments visited during this audit use municipal water. Establishments conduct total plate count once per week; limit is less than 100 CFU/ml. Establishments send water sample to provincial CIQ lab once per year. Records are kept in the establishment. Another government organization named Disease Control Centre also takes its own water sample from the facility once per year, but records were not audited.

6.1.2 Premises

All facilities are built in an open area surrounded with fences. Roads were well paved and neighbourhood environment were relatively clean, without visible garbage or dumpsters around. All facilities have separate entrances for raw and cooked areas. All entrances had a small room attached to the entrance which only allowed certain amount of personnel in before opening the entrance door. All the entrance doors are blocked by a stainless steel board with 1.5 to 2 feet high to prevent rodents.

Buildings were maintained and designed to allow proper traffic flow for both material and personnel to prevent any cross contaminations. Lightings were protected and sufficient for all work stations.

The temperature control during processing was respected as described in the Food Safety Management System Requirements for Meat and Meat Product Establishments (GBT 27301-2008). Pre-cooling facility temperature is controlled in the range of 0°C −4°C. Temperature of cutting/boning and meat product processing establishments should not exceed more than 12°C (except for heating process). Freezing temperature should be no more than −18°C. Temperature control panels are visible throughout the facility, temperatures are displayed for all the rooms and storage places.

Appropriate ventilation systems in the facilities were observed. No major ventilation issues were noted during the audit except for condensation in the food production, processing and storage areas in the canning establishment. However, food safety was not compromised at that point in time.

6.1.4 Equipment

All facilities were in regular production status when audited. All equipment is functioning reasonably well without any major interruptions. Thermometers are calibrated at the beginning of production by using ice water, and are cleaned and sanitized in hot water > 82°C after each use.

6.1.5 Transportation, Receiving, Storage and Shipping

6.1.5.1 Slaughter establishments

The operator is responsible for transportation controls of chicken. Veterinarians from MOA are responsible for inspection of the birds and the truck at the farm and also signing the inspection and quarantine declaration.

As per the Safety and Sanitation Requirements on Export Food Producers (No. 23 Announcement of Certification and Accreditation Administration of the People's Republic of China in 2011), export food producers should take effective measures to ensure safety of raw and supplementary materials, food additives and food-related products. It was observed raw and supplementary materials had been adequately protected from being contaminated by environmental contaminants, agricultural inputs, chemicals, pests and animal/plant diseases in the storage area before production.

6.1.5.2 Dumpling establishments

Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products (Order of AQSIQ No. 136) requires that the pre-cooling warehouses, the quick-freezing warehouses and the cold storages should meet product temperature and humidity control requirements and should be equipped with automatic temperature recording devices which should be regularly calibrated.

Local inspection and quarantine authorities are responsible for the supervision of incoming meat products. The inspection personnel verified the inspection and quarantine certificates issued by local inspection and quarantine authorities of slaughter establishment and port of entry inspection. The storage warehouses visited were found to be clean, regularly disinfected and free of mildew, rats, flies and insects.

At all dumpling establishments, receiving and shipping docks are physically separated. At the receiving dock, meat and vegetables have their designated dock. Chemicals are ordered and delivered separately from the food material.

Receiving is a CCP in the HACCP for all audited establishments to ensure that the received ingredients meet the prescribed criteria. The receiving staff checks and records the temperature of meat product. For imported meat, receiving records include quarantine declaration, custom declaration form with country of origin, quantity, establishment code and product identification, temperature and sampling amount. All facilities have a separate storage freezer for imported meat only. Packages (plastic bags and cardboard boxed) are delivered on a daily basis according to the production volume. Other ingredients are clearly identified in the storage area with production coding.

Transportation is controlled at the receiving points by checking and verifying temperature, the conditions of outside package, records, etc. Any shipments that do not meet the criteria would be rejected.

All finished products destined for export are clearly identified in the freezer used for exported products only in order to separate from domestic products.

6.1.6 Personal Hygiene

General training is normally conducted once per month by selecting certain areas of concern. Records are kept with employees' signature and indication of pass/fail.

All facilities have strict dressing procedures by using masks, hair covers, neck hair covers, laboratory coats, gloves, rubber boots and leg bands. Designated employees roll over the laboratory coats and head covers before entering into production area. Foot bath (200 ppm Chlorine) and wind tunnel are used at a majority of facilities. Hand washing procedures are posted on the wall: soap-rinse-sanitize (30 s, 100 to 200 ppm)-rinse-dry. No jewellery, paper clip/stapler, capped pens, etc. is allowed in production area. All washing stations are designed as hands-free stations. Garbage cans are clearly marked for condemned material and for garbage. Some facilities used racks for garbage-only cans to avoid floor contact.

All employees must have annual medical check-up for 6 diseases (e.g.: Hepatitis A, Tuberculosis, intestine related diseases, skin diseases, etc.). All health certificates have a one year expiry date and are kept at the establishment.

6.1.7 Sanitation and Pest Control

As described in the Safety and Sanitation Requirements on Export Food Producers (No. 23- Article 12), the enterprises take care to prevent chemicals from contaminating products. Also, chemicals for temporary use in production and processing areas are stored and identified cabinets kept locked by the designated personnel. Contamination of food, food contact surfaces and food packaging materials is forbidden.

Pre-operational sanitation checks are conducted daily by the operator and non-satisfactory observations are documented and corrected before the beginning of operations.

Operational sanitation frequencies vary by establishment, according to their production needs. All facilities demonstrated that Standard Sanitary Operational Procedures are followed. The sanitation room has two exits to allow one-way-traffic in order to prevent re-contamination.

Pest control is normally contracted out to a third party. The pest control company visits the establishment at least once a month. The frequency can be adjusted if an increase of rodent activities is observed.

6.1.8 Recall Procedures, Distribution Records and Complaints

Article 49 of the Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products and the Article 63 of the Food Safety Law states that the state should establish the food recall system. In the event that a food producer finds that the food being produced does not comply with food safety standards or is proven to likely endanger human health, the food producer should immediately stop production of the food, recall the food distributed in the market, notify relevant producers, dealers and consumers, and keep records of recalls and notifications.

A recall plan is in place for the establishments audited. The onus is on the company to make a recall decision, regardless of the cause. The recalling company notifies the local CIQ which in turns report to higher level accordingly. The CIQ oversees the investigation of the root cause analysis of the recall, but does not conduct risk assessment to classify the potential risks of the recall.

After CIQ identifies non-compliance in exported food, it should immediately issue a notification of recall to the dealer and release the export suspension announcement according to Article 34 of the Administrative Measures for Import and Export Food Safety. The product identification codes are used to trace each link ranging from finished product to ingredient. In the slaughter establishments, the meat products are labelled with the production date, two letters of identification of the region, plant registration number and the identified farm number. In the dumpling establishments, the meat received from the slaughter establishments has the same identification codes. All products has coding on the labels which can be used to trace the product to the slaughter establishment and the farm of origin.

6.1.9 Foreign Material Control Program

All facilities are equipped with metal detector as a CCP. Metal detector is checked before production and verified every hour during the production. All checks are logged in and signed by responsible employees. Some facilities are also equipped with X-ray machines to detect glass, wires, etc. These are also checked before production and once every hour during production.

Conclusion

Slaughter establishments audited have appropriate control over the transportation and the receiving of the birds from the designated farm.

Dumpling establishments appropriately segregate all ingredients from receiving to shipping, for all exported products.

The audit team observed multiple findings regarding the pre-requisite programs such as the building maintenance, sanitation and ventilation (presence of condensation) during the on-site visit of one canning establishment. However, food safety was not compromised at that point in time. At the closing meeting, CFIA requested AQSIQ to follow-up with this particular canning facility.

6.2 HACCP Plan

All facilities have HACCP plan in place. The CIQ audits the HACCP plan annually as a mandatory requirement. CCPs (receiving, cooking and metal detecting) are identified and critical limits are set in the HACCP plan. CCP details are posted on the wall in the specific work station to remind employees. All the changes including product information, processing procedures and other requirements, are updated in the HACCP plan, verified and signed by CIQ. On-going validation and verification is conducted by both the establishment and CIQ, and changes are made accordingly.

Conclusion

All audited slaughter establishments and dumpling establishments have developed and implemented HACCP in accordance with Chapter I General Provisions of the Administrative Provisions on the Filing of Export Food Producers, which meets Canadian requirements.

7 Microbiological Controls

7.1 Microbial Intervention

In the two poultry slaughter establishments audited, only chlorine is used in the water as a microbiological intervention system. During the off-line reprocessing, the contaminated carcasses and parts are rinsed with water with no addition of microbial intervention agents. In the poultry slaughter establishment audited, a level of 50 to 100 ppm of chlorine is added to the water in the chiller, during the chilling process. CIQ officials perform task to verify the chlorine level in the chiller tank once per hour. Only microbial control interventions approved by Health Canada can be used to treat raw carcasses and their parts in establishments registered under the Meat Inspection Regulations, 1990.

Conclusion:

Chlorine level of 50 to 100 ppm is permitted in the water chiller for poultry in contrast to the the approved limit of chlorine (up to 50 ppm) as per Health Canada standards as listed in Meat Hygiene Manual of Procedures Ch. 5.2.17

7.2 Slaughter Establishments (Product and Environmental Sampling)

In the slaughter establishments audited, the sampling plan is based on the exporting countries' requirements. The testing of generic E. coli, Salmonella and Campylobacter on carcasses was completed using the same sampling frequency, sampling techniques and process verification criteria as used in Canada. The frequency for generic E. coli is one per 22,000 carcasses and for Salmonella and Campylobacter, the frequency is 51 consecutive tests. The results of the product sampling program audited reflected the conditions and the controls on the evisceration floor.

All product and environmental samplings are conducted by the trained personnel of the establishment under CIQ inspector's supervision. CIQ does not take separate samples. All samples go to the ISO 17025 accredited laboratory within the establishment.

Conclusion:

The product and environmental sampling is implemented as described in the Meat Hygiene Manual of Procedures, Chapter 11, annexes T, U and U-1.

7.3 Processing Establishments (Product and Environmental Sampling)

The Food Safety Law of the People's Republic of China (Order of President No. 21 adopted at the 12th Standing Committee of the National People's Congress) requests that food and drug supervision administrations of the People's Republic of China should conduct the sampling and release results as specified. AQSIQ is responsible for the general planning of annual export-oriented microbiological sampling plan. AQSIQ provides the CIQs their attributed number of samples to be taken annually. The CIQ organizes and assigns the sampling plan to the establishments. The microbiological sampling plan for the domestic market is organised by and is under the responsibility of the China Food and Drug Administration (CFDA).

In the processing establishments audited, CIQ performs an export related finished product sampling program. One sample of a product per month is taken and will happen concurrently on the same production line, and on the same day of production. From the selected lot, the CIQ designated official will randomly collect a sample consisting of five sample units. These samples are sent to the Official Technical Center laboratory for analysis. The microbiological analysis includes total bacteria count, Salmonella, E. coli. Staphylococcus and Listeria monocytogenes.

The results of these tests are sent back via the information technology tool called E-lab (electronic laboratory) directly to the CIQ designated official. If the results are non-compliant and there is a food safety issue, the operator is informed and a recall must be initiated. A risk analysis is done and the frequency of the test is increased to once a week for a period of several weeks based on the operator's risk analysis. The designated CIQ official and the supervisor have the support of CIQ's provincial level for the overview of the situation. The CIQ provincial office provides technical resources for the analysis of the non-compliance.

The establishments are conducting domestic product microbiological sampling for every lot. However, establishments do not hold the finished products while waiting for the microbiological test results.

For the audited dumpling establishments, control panels are considered as possible direct contact surfaces and were sampled for microorganisms. Both product and environment samples are analyzed individually by the laboratory instead of composing all samples together.

Conclusion:

Product and environmental sampling in the processing establishments is adequately conducted according to the Food Safety Law of the People's Republic of China.

8 Chemical Residue Control

As described in the Administrative Measures for Supervision of Inspection and Quarantine of Import and Export Meat Products (Order of AQSIQ No. 136) Article 31, on the basis of risk analysis, inspection and quarantine authorities should conduct sampling for toxic and hazardous substances (such as pathogenic microorganism, pesticide & veterinary drug residues and environmental contaminants) in export meat products, and verify and supervise the quality safety control system for the entire process of export meat production and processing.

The control system is such that the production of meat and meat products is clearly separated in terms of domestic and export markets. The implementation of the chemical residue plan follows the domestic legislation, while taking into account the requirements of importing countries. AQSIQ is responsible for issuing the plan for monitoring chemical residues nationwide in imported animal derived foods and foods produced for export. Generally, AQSIQ issues the plan to inspection and quarantine bureaus under its direct control in the form of document every March/April. The plan breaks down residue monitoring tasks to locations based on residue monitoring suggestions given by local domestic, and local import and export of animal derived foods. Based on the review of information provided by the AQSIQ, it was highlighted that some banned drugs (cimaterol, nifurstyrenate sodium, methaqualone, sodium nitrophenolate, nitrovin, camahechlor, chlordimeform, amitraz, antimony potassium tartarate, tryparsamile, malachite green, calomel) and approved drugs/drugs with Maximum Residue Limits in China (colistin, destomycin, diclorvos, ethopabate, fention, fluvalinate, halofuginone, kitasamycin, malathion, narasin, oxacillin, robenidine, semduramicin, spectinomycin, trimethoprim, zoalene, dimeteridazole, estradiol benzoate, hygromycin B, metronidazole, nitromidazoles) were not monitored by the chemical residue program. The People's Republic of China is encouraged to further improve their monitoring program based on the above findings.

In Canada, the selection of substances for inclusion in the National Chemical Residue Monitoring Program depends on many factors, including: the toxicity of the substance, historical prevalence and compliance data, availability of a suitable analytical method, laboratory capacity, importance of the compound in human medicine, intelligence about abuse or misuse of compounds and additional considerations such as access to foreign markets. Furthermore, the sampling and testing frequency of different foods is determined by the importance of the food in the diet, the volume of the food produced domestically or imported, and the compliance history. Further details about Canada's National Chemical Residue Monitoring Program can be accessed at www.inspection.gc.ca/eng/1472776535969/1472776559235.

Non-compliant results are reported by the laboratories within 24 hours to the client that has submitted the samples, who will in turn notify local competent administrative authorities, including the operator of the farm or establishment where the sample was collected within 24 hours. Follow-up investigations and necessary measures (including the suspension of the exporting activity of the establishment involved) are taken to control the farm or establishment involved. Products for export from the related establishment (s) or the whole area will be inspected lot-by-lot when applicable. Only those with compliant results would be allowed for export. Non-compliant products are sealed and they are either:

The monitoring testing laboratory should be involved in the research or exposure assessment of the non-compliant sample, and put forward the corresponding corrective measures when applicable.

Conclusion:

The People's Republic of China has infrastructure in place to develop and implement the chemical residue program as per article 31 of Order No. 136 of AQSIQ. The People's Republic of China is encouraged to further improve their monitoring program based on the above findings.

9 Closing Meeting

The closing meeting was held in Beijing headquarters on September 20th, 2017 with AQSIQ, CIQ and CNCA representatives. At the meeting, a summary of the systemic findings and preliminary establishment findings from the audit were presented by the CFIA.

10 Conclusions

Overall, the audit results showed that poultry meat inspection system in the People's Republic of China is performing as intended in an adequate manner and generally demonstrated an acceptable implementation of controls for all areas described above.

All five dumpling establishments were under normal production status on the auditing day and no major food safety issues were observed.

Following the review of the action plan provided by AQSIQ, the CFIA has concluded that the inspection oversight, production system, and implementation of controls at five dumpling establishments were adequate and acceptable. The five audited establishments will be able to export meat products (dumplings) to Canada once the required steps regarding finalization of import requirements and official meat inspection certificate, and listing of the establishments on the CFIA website are completed.

11 Annex

Annex 1: Summary of the AQSIQ Action Plan in response to the CFIA Recommendations of the audit completed to Evaluate Poultry Meat Inspection System and Establishments Producing Stuffed Grain Products.

No CFIA Recommendations AQSIQ Actions plans/Comments
1 CFIA recommends that verification report captures all details of verification activity conducted to assess the compliance as per Meat Hygiene Manual of Procedures, Chapter 18.7.2.5.

In this regard, and monitoring of the action list sent with a letter of December 29th 2017, AQSIQ advises that these actions will be implemented immediately as soon as trade for these products is established between People's Republic of China and Canada.

According to CFIA's recommendation, AQSIQ revised the existing form for "Verification Record of the Establishments for Food Export production", which includes now clear items such as the place of verification, the positions and names of inspectors, equipment verified and critical control points verified. This revised form will be used in the verification of enterprises for exportation to Canada.

2 CFIA recommends the competent authority to provide assurance in writing that an appropriate follow-up to the identified establishment specific findings as indicated in the closing meeting at each establishment.

In this regard, and monitoring of the action list sent with a letter of December 29th 2017, AQSIQ advises that these actions will be implemented immediately as soon as trade for these products is established between People's Republic of China and Canada.

According to CFIA's recommendation, AQSIQ followed up with the identified establishment, who did the correction regarding all the findings and submitted their rectification report to the provincial CIQ. The actions to correct the findings were submit by written to CIQ and were verified on site by CIQ.

3 CFIA recommends that the level of chlorine (up to 50 ppm) used as antimicrobial intervention for poultry meet Canadian requirements, as per Health Canada standards.

In this regard, and monitoring of the action list sent with a letter of December 29th 2017, AQSIQ advises that these actions will be implemented immediately as soon as trade for these products is established between People's Republic of China and Canada.

AQSIQ has notified the relevant establishment about Canadian's requirement of the level of chlorine used in the cooling water for slaughter (up to 50 ppm). The establishment confirms that the level of chlorine can be controlled at up to 50 ppm according to Canadian requirements, and CIQ will conduct verification on it.

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