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
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:

• Law of the People's Republic of China on the Import and Export Commodity Inspection
• The Animal Epidemic Prevention Law of the People's Republic of China
• Law of the People's Republic of China on the Entry and Exit Animal and Plant Quarantine
• Food Safety Law of the People's Republic of China

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:

• Name of the establishment,
• Date of the visit
• Fields of scope verified
• Description of the non-compliance if applicable, the operator corrective/preventive actions and the follow-up.
• Signatures of the CIQ official and operator

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.

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.

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:

• Detailed list and amount of products to export
• List of ingredients, source of the meat and records
• Production dates and labels
• Production processing records
• Sampling program results
• Contract with the broker and shipping manifest
• Operator pre-shipment inspection form

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.

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.

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.