Evaluating the food safety systems governing the production of pork and poultry meat and meat products for export to Canada
Annex 2: Greece

1. Introduction

The audit in Greece took place from February 23through 27, 2015. The CFIA audit team was accompanied throughout the audit by a representative from the CCA, the Directorate of Hygiene and Safety of Food of Animal Origin (DHSFAO) and the FVO. The team was also accompanied in part by a representative of DG SANTE, the Canadian Veterinary Counsellor in Brussels, and by representatives of the CCA, the Hellenic Food Authority (EFET).

An opening meeting was held on February 23, 2014 with the CCA in Athens. During this meeting, CFIA auditors confirmed the objectives of and itinerary for the audit, and requested additional information required for the satisfactory completion of the audit. The representative from the FVO gave a general presentation on the FVO, outlining its organization, the number and types of audits conducted per year, the follow-up to enforcement actions, and the power of the FVO. The CFIA was invited to the FVO office in Ireland in order to gather in-depth information about the FVO and its role.

2. Competent authority and official controls

Overall responsibility for the organization and operation of the control systems for food safety, animal health and animal welfare in Greece is shared between 2 ministries, the Ministry of Rural Development and Food (MRDF) and the Ministry of the Interior, Decentralization and E-Government (MIDE).

Under MRDF, the General Directorate of Sustainable Rural Development and Veterinary Medicine (DGSRPVS) is responsible for implementing legislation on the veterinary controls for live animals, animal products, animal diseases, zoonosis, food hygiene and safety and animal identification. It has 3 directorates, one of which is the DHSFAO which is the CCA in Greece responsible for the legislation covering animal products. The DHSFAO coordinates and monitors the implementation of the legislation by the regional authorities by issuing circulars, organizing meetings, working groups, and hosting seminars. It is also responsible for granting slaughterhouse approval numbers.  It has 3 departments: (1) the Department of Slaughterhouses and other Establishments, Meat and Meat Products, (2) the Department of Animal By-Products and (3) the Department of Fisheries, Milk, Eggs, Honey, and Other Products.

The EFET is also supervised by the MRDF, and is responsible for general foodstuffs and food hygiene controls. It is responsible for the organization of official controls and the hygiene of food after primary processing up to the final consumer.

Under MIDE, the local government comprises 7 Decentralized Administrations, 13 Regions, 74 Regional Units and 325 Municipalities. Each Region has a Directorate General of Regional Rural Economy and Veterinary Medicine (REVM) responsible for the implementation of the relevant controls. The REVM is divided into a number of Directorates. Each Regional Unit has a Directorate of REVM which includes 5 departments. The department dealing with meat inspection is the Department of Veterinary Medicine.

As described earlier, in the EU there is no prescribed procedure for the assigning approval numbers to the establishments. A facility may have multiple approval numbers according to the functions performed, i.e. slaughter, cutting and boning, meat processing. This presented issues during the audit where multiple establishments with different approval numbers were approved to function at a single location within the same building and under the same management, particularly as these establishments were found to have similar deficiencies. The auditors are not aware of any established mechanism whereby a CA is required to investigate the implication of findings in one section of the building on the other section(s) covered by different approval number(s). This situation becomes even more complex if such establishments are covered by different CAs within the MS as was experienced by auditors.

Significant weaknesses in supervisory oversight were observed during audit in Greece. The auditors identified several occasions where the CA did not take appropriate action. For example, when the auditors identified grease contamination on raw product in one establishment, neither the company nor the regional CA took any corrective action. However, the CCA representative directed the plant to take corrective action. The OV was not aware of the policy about movement of immobile pigs nor was she aware of the restriction on exports of carcasses from pigs that had undergone emergency slaughter. In another instance when the auditors noted product contamination due to dripping condensation from overhead structures, the representatives from the local CA did not take any action when the company failed to do so, and again, the representatives from the CCA and FVO took corrective action.

Inspection coverage at a processing establishment did not meet EC requirements. Inspection oversight requires a minimum of an audit one per year, involving a minimum of 2 CA staff and normally takes 2 days. However, the last audit was over 2 years ago. Another significant finding was lack of supervisory oversight of the official inspection staff by the CA. The onsite visit to a slaughter establishment in one region revealed that there is only one official veterinarian in the whole region. The OV is present only in the establishment during slaughter, i.e. Monday and Friday. She is responsible for five slaughter and four cutting establishments and dairy (cheese) processing establishments, and there is no one to replace her during her unscheduled absences. The OV was interviewed on ante-mortem and post-mortem inspection but was not available for follow up questions on official controls and export certification because she had to go to another establishment. She was contacted by the CA at auditor's request and was asked to be available for interview the next day but couldn't she as she fell ill. The situation was slightly better in the other region audited with the presence of two OVs.

3. Slaughter/processing controls

The review of the slaughter and processing procedures at the establishments audited identified instances of non-compliance with applicable EU legislation. However, since only one of the two slaughter plants audited was in operation the day of the audit, the comments regarding deficiencies in post-mortem inspection reflect what was seen at one establishment.

EC regulations require only visual inspection of the carcasses, and no incisions of viscera or lymph nodes are required unless the OV determines that incision is necessary based on ante-mortem findings, food chain information or other risk factors.

At one pork slaughter establishment, the OV's work station did not allow proper post-mortem inspection. In addition, because of the time requirements related to the post-mortem inspection, the OV was not available to monitor other critical aspects such as animal welfare, stunning, and to complete the post-mortem examination.

The OV station at this establishment is located at the beginning of the slaughter line, where the OV incised livers, kidneys and hearts, and the only subsequent inspection was a verification of Trichinella results. There was no inspection of the whole carcass to verify the absence of pathological defects (e.g. abscesses) or processing defects (e.g. fecal, ingesta or contamination).

4. HACCP plan and prerequisite programs controls

Traceability was well documented, starting with the use of the food chain information that was presented either with the animals if they all came from one source or up to 24 hours in advance. The recall programs were well documented and practiced on a regular basis.

However, following deficiencies identified by the auditors need attention:

1. HACCP systems design and maintenance

   At one facility the company had a good training program and monitoring the employees good manufacturing practices (GMPs) but no written records are generated. At another establishment, the company was unable to supply the reference to support the rationale for calculating the score for hazards during risk. This was their alternate to the use of the decision tree to determine CCP's.

   The FBO in charge of the establishment in which multiple maintenance issues were found indicated that the building maintenance is reviewed on a weekly basis. However, the audit findings indicate that the frequency and the quality of this review are not effective.

2. Sanitation

   The overall sanitation at one slaughter establishment was inadequate. For instance, the exit door of the carcass wash cabinet had an obvious accumulation of debris at the beginning of the production. The establishment also had a large accumulation of dirt, hair and debris on the overhead rails that transport the carcasses.

   The auditors identified numerous non-compliances at the processing establishment that physically adjoins the slaughter plant audited, including a general lack of maintenance and basic sanitation. This was indicated by extensive rust on overhead structures, dripping water and condensation from overhead structures, poor sealing of outside doors with potential for entry of pests, extensive rust on racks in the spice mixing areas, and poor sanitation of tow motors used in the processing and spice mixing areas.

   Minor deficiencies found on pre-operation inspection at another slaughter plant included debris on the rails, contamination on a food contact surface (viscera hook), and a live insect in a tray for edible product on the slaughter floor. In addition, there was some condensation on the walls of cooler, and a piece of fat on the pulling cable in cooler. The operations did not begin in this establishment because malfunctioning of the boiler that affected the water temperature in the sanitizers.

   Unlike the Canadian program, the EC regulations do not require a pre-operational inspection to be performed by the CA. The pre-operation inspection that was performed as part of this audit was determined to be acceptable.

3. Good hygiene practices

   During the onsite inspection on the cooler, the auditors noticed grease contamination of the product. The company did not take any corrective action until directed to do so by the CCA. At the same facility, the auditors noted direct product contamination from dripping condensation from overhead structures which was only corrected after the intervention of CCA and FVO. On the other hand, at another processing plant, only minor items were identified during the establishment tour, which were immediately corrected by the company. These included: a tote liner was in contact with a non-food contact surface, bags were in contact with a garbage container, and non-food ingredients were in a tote directly on the floor. In one processing establishment, auditors noticed that allergens were not segregated in the spice mixing room, and the company labels the products with "may contain soya, celery" or the other potential allergens in order to address the potential cross contamination.

4. Ventilation

   Ventilation related issues were detected in two establishments as noted by the finding of condensation in the cooler at the slaughter plant and excessive and sometimes dripping condensation in the processing areas of an RTE processing plant. There was direct contamination of product from dripping condensation at one RTE establishment.

5. Building design, construction and maintenance

   Construction of the barn at one slaughter establishment did not allow for the smooth movement of pigs from barn to the stunning station. Therefore, establishment employees who were moving the pigs had to use electric prod on almost every pig to get them to move forward. Additionally, metal structures were found protruding from the wall and could potentially injure animals.

   One establishment was not well maintained. The rails were in the cooler were rusty, and there was an accumulation of hair, dirt, debris and excessive grease on the rails, and peeling paint throughout the plant. In addition, the walls and floors were not in good repair. There was peeling paint and rust on the ceilings in the product storage areas (coolers). The door at the shipping dock did not close properly, although the FBO said they had noticed it that morning and were working on it. There was a gap observed in another door leading to the cutting floor. The establishment's response was that they had noticed it but it was not part of the establishment currently being audited. No records were available to prove that monitoring had noticed these and corrective actions have been initiated.

5. Microbiological controls

At the slaughter establishments, both FBO's were conducting the carcass sampling according to the EU requirements including trend analysis. Salmonella results had been negative at one establishment for many years (more than nine). No issues were identified.

All hog carcasses are subjected to Trichinella testing, and the carcasses are held until the receipt of satisfactory results.

At one plant, there was a single positive case reported in 2013 that was in a wild boar, not a market hog. No issues were found with the Trichinella testing.

It is important to note that Greece is conducting official microbiological sampling at slaughter plants following a recent ministerial decision. Because this is a recent change there are not results available for analysis, although there have been no positive Salmonella results.

6. Chemical residues controls

Implementation of residues monitoring programs complies with the relevant EU regulations.

7. Recommendations to the CCA of Greece Director General of Veterinary Services