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Evaluating the food safety systems governing the production of pork and poultry meat and meat products for export to Canada
Annex 1: Summary of proposed action plans to CFIA's recommendations to the DG SANTE from the 2015 audit of four European Union Member States food safety systems governing the production of pork, poultry and processed meat products

No CFIA recommendations Proposed action plan
1.1 The EU should review the supervisory oversight in all 28 MS to ensure that all competent authorities have procedures in place to verify the effectiveness of official controls at a regular frequency as stipulated in article 8 of Regulation (EC) No 882/2004.

Response provided in May 2016:

All Member States are required to have systems in place to verify the effectiveness of their official controls (Article 8 of Regulation (EC) No. 882/2004).

This requirement is subject to audit during the majority of DG SANTE Directorate F: Health and Food Safety - audits and analysis (formerly FVO).
In addition, Directorate F produced and published an overview report on this topic (Report reference: 2014-7263).

Response provided in January 2017:

The Commission generally verifies the presence and the effectiveness of these supervisory oversight controls during its audits of the MSs, of which the results and follow up can be found in the Country profiles. DG SANTE also clarified that, additionally, it had produced an overview report on this topic: report reference 2014-7263. Follow-up by the MSs and the COM took place, in particular in the working groups of National Audit Systems (NAS) and the ones on the Multi-Annual Control Programmes (MANCP) and also that specific guidelines are being developed. Follow-up by individual MSs should be reflected in their MANCP. Moreover a series of audits of NAS is in progress. Further information on the official controls in the MSs, the way this has to be supervised by the national competent authorities and is overseen by the European Commission (actually three layers of controls and assurances) has been disseminated during your study visit in Grange following the JMC as well.

1.2 The EU should review the staffing situation and training of field staff in all 28 MS to ensure that adequate numbers of inspection personnel are deployed to deliver the inspection activities and that inspection staff understand the Regulations and their role in the daily operation of the establishment to ensure full compliance.

Response provided in May 2016:

It can be difficult to determine whether the numbers of staff available for particular tasks is adequate (due to the potential range of other tasks allocated to them).

When performing audits, Directorate F focuses on whether tasks are performed as required. Where this is not the case, auditors are instructed to attempt to find the underlying cause (e.g. deficiencies in training, staff qualifications, staff allocation) and to conclude and recommend accordingly.

Regulation (EC) No. 882/2004 (Article 6) lays down requirements in relation to staff training and qualifications. This issue is considered in all Directorate F reports, sometimes with a section of the report dedicated to staff training (more recently, this is less likely due to the focus on the correct performance of tasks - training will only be reported on where deficiencies in training systems can be demonstrated as a contributing factor to unsatisfactory controls)

1.3 The EU should develop a system to ensure that all CFIA requirements that are over and above EU requirements are available to the field staff and the establishments approved for export to Canada in all 28 MS, and that these requirements are verified by the CA when meat products are certified for export to Canada.

Response provided in May 2016:

Under the auspices of the Veterinary Agreement the EU and Canada have established equivalence for the largest parts of their food safety measures with respect to meat and meat products.

Additional import requirements are normally listed in the harmonised export certificates that apply to all MSs for their exports of the products concerned to Canada.

As indicated at the EU-Canada Veterinary JMC of November 2015, the EC is willing to consider developing an Export library as to make Canada's additional import requirements available to the EU MS as well. Some preparatory work on this has commenced.

However for this to be happen, Canada would have to share its additional applicable requirements with the EC first.

Response provided on January 2017:

EU is considering developing an export library which clarifies Canada's import requirements.

Response provided in June and July 2017:

DG Santé provided:

  • Commission Notice of 13.7.2017 relating to the provision of information on substances or products causing allergies or intolerances as listed in Annex II of Regulation (EU) No 1169/2011 on the provision of food information to consumers
  • Links to Regulation (EU) No 1169/2011, the Guidance on allergens- Food information to consumers - legislation - New EU law on food information to consumers
1.4 The EU must ensure that the FVO's authority and oversight is extended beyond verifying compliance with the EU regulations to also include verifying compliance with Canadian requirements that are over and above the EU regulations.

Response provided in May 2016:

Verification of compliance with Canada's import requirements that are agreed between the EU and Canada and stipulated in the harmonised export certificates will be included within the scope of the regular audits of the EU MS by DG SANTE, Directorate F.

In addition, DG SANTE is developing the capacity to evaluate and improve the export control systems in the EU.

Response provided in January 2017:

DG SANTE is not currently verifying, within the scope of Directorate F audit activities that those approved establishment's operators (FBO) are exporting in compliance with Canada's requirements. The harmonized certificates for fresh pork and beef containing Canada's additional import requirements are included in these certificates and provided equal guaranties.

Response provided in April 2017:

The two years since the audit was conducted in February/March 2015, have been very instrumental to exchange information between our experts on how EU legislation pertaining to the production and processing of meat is implemented and overseen by local, national and Commission officials. DG SANTE and the four EU member states concerned also have taken corrective actions to address CFIA's recommendations that emerged from the audit; these corrective actions have been shared with CFIA. CFIA's findings as well as the corrective actions will be exchanged with and presented to the Member States when the project has been concluded and before newly authorised or ‘activated' Member States may start to trade their meat to Canada, in compliance with item 4.5.1.c of the same Action item list. At that time Directorate F will be commencing to verifying compliance of the Member States with Canada' additional import requirements as stipulated by our reply to Recommendation 1.4 of the audit report.

1.5 The EU must demonstrate to the CFIA how it will ensure that meat and poultry products are produced under control programs that meet all Canadian food safety and product standards e.g. control of Listeria monocytogenes, cooling of heat processed meat products, thermal processing and incubation testing of canned meat products and poultry meat products.

Response provided in May 2016

Regulation (EC) No. 2073/2005 requires that FBOs should test against microbiological criteria for verification and validation of their HACCP and GHPs.

For Listeria monocytogenes for RTE there are two criteria:

  • absence in 25 grams: before the food have left the immediate control of the FBO that has produced it
  • <100 CFU/gram for products placed on the market during their shelf life: meaning that the FBO must be able to demonstrate that the limit is not exceeded during the shelf life with the results obtained after production for the verification and validation of their HACCP and GHP. For example if the FBO gets 10cfu/gram after production he/she has to demonstrate that this will not represent over 100 at the end of the shelf-life

Recognising that EU legislation and Canadian requirements result in similar food safety outcomes for Listeria monocytogenes in RTE food, the EU and Canada have agreed on equivalence which was confirmed by a CFIA letter in 2011 - attachment EC1.

Response provided in January 2017:

DG SANTE requests Canada to provide the link and information on the specific requirements for canning and cooling. In addition, Canada must assist EU for any other requirements that were identified during the systems audit conducted in 2015.

The commission would be ready to consider to including the references of the Chapter 15 and Chapter 4 of the MOP in the harmonised export certificates so as to require the OV to attest that the FBO is aware of these requirements and ensures that the products are produced according the procedures compliant or equivalent to these, when exporting canning and RTE foods to Canada

1.6

The competent authorities in all 4 MS must take appropriate actions to address all non-compliances identified in the establishments under their supervision during this audit.

For three establishments located in two MSs, where serious deficiencies were noted, CFIA requests the concerned CCAs follow up on all deficiencies and provide CFIA with corrective action plans developed and implemented by the FBOs. The CFIA also requests the CCAs verify that action plans have been implemented and are effective in addressing all deficiencies.

Response provided in May 2016:

The 4 MS have addressed the recommendations put forward by the draft report and brief on the corrective actions put in place in the parts of the report that subsequently apply to them.

As for the three establishments specified, DG SANTE advises that these will not be recommended by the MSs for listing by CFIA until the agency has accepted the implementation of the corrective action plans by evaluating the verifications by the CCAs.

1.7 The EU should inform the CFIA of the steps taken at their level to resolve all potential issues when more than one establishment is located at a single premise.

Response provided in May 2016:

The current situation is that it is up to the MS whether they give the same or different registration/approval numbers to different activities within an establishment, provided that traceability is ensured and the number is unique for each activity.

In addition, even if they are considered as different establishments - and have different approval numbers -, when they are managed by the same food business operator, Art. 54 of Regulation (EC) No. 882/2004 (Action in case of non-compliance) require him to remedy the situation without undue delay.

However, DG SANTE takes the CFIA recommendation into account and will be reflecting, in cooperation with the MS, whether additional measures are required and will inform CFIA about the outcome.

1.8 The EU must ensure that official veterinarians responsible for inspecting the establishments and certifying meat and meat products for Canada in all 28 MS have full inspectoral authority including the authority to seize and detain the non-compliant product and take enforcement actions, and that they are free from conflict of interest.

Response provided on May 2016:

The requirements in Regulations (EC) Nos. 854/2004 and 882/2004 ensure that the EU MS have to have official veterinary systems in place that have full inspectoral authority, including the authority to seize and detain the non-compliant product, and take enforcement actions where appropriate. The EU MS also have to make sure that the Official Veterinarians working in the framework of the system described above are free from any conflict of interest.

Regulation (EC) No. 854/2004 and, by doing so Regulation (EC) No. 882/2004 as well, have been recognised equivalent to Canada's Regulatory Acts and Regulations with respect to the public health requirements for fresh meat and meat products.

August 2017:

DG SANTE provided the CFIA with a document listing examples of actions taken in cases of non-compliances detected during ante mortem, post mortem and official controls by authorized veterinarians. The CFIA was also provided information about the official veterinary inspections in Croatian slaughterhouses, including the legislative framework for the official controls.

1.9 The EU must ensure that all competent authorities have the required laboratory capacity including the capacity to test for container integrity.

Response provided in May 2016:

Regulation (EC) No 852/2004, Annex II, Chapter X, point 3 specifies the EU requirements for canning. It states: 'wrapping and packaging operations are to be carried out so as to avoid contamination of the products. Where appropriate and in particular in the case of cans and glass jars, the integrity of the containers construction and its cleanliness is to be assured.'

The integrity controls have to be part of the HACCP controls and should consist of:

  • the verification of the seam of certain number of cans (through measurements)
  • incubation of also a predefined number of cans from each batch

The objective is that the FBO checks whether the process works - if the can integrity wouldn't be adequate one would also see growth. Also the can supplier must be approved and work according to certain specifications.

All these aspects have to be verified as part of the HACCP official control verifications.

1.10 The EU must ensure that poultry receive complete post mortem examination including examination of carcasses (internally and externally) and viscera.

Response provided in May 2016:

In the EU the meat inspection requirements are laid down in Regulation (EC) No 854/2004. Annex I, Section IV concerns the inspection for poultry. In Chapter V, para B on Post-mortem inspection it reads:

'1. All birds are to undergo post-mortem inspection in accordance with Sections I and III. In addition, the official veterinarian is personally to carry out the following checks:

  1. daily inspection of the viscera and body cavities of a representative sample of birds;
  2. a detailed inspection of a random sample, from each batch of birds having the same origin, of parts of birds or entire birds declared unfit for human consumption following post-mortem inspection;

    and

  3. Any further investigations necessary when there is reason to suspect that the meat from the birds concerned could be unfit for human consumption.'

    In 2007, Canada recognised the EU requirements with respect to post-mortem inspection of bird equivalent to its own rules and procedures.

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