Final Report of an Audit Conducted In Argentina September 9^th, through September 25^th, 2013
Evaluating the Food Safety Systems Governing the Production of Beef And Poultry Meat Products Intended for Export to Canada

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Abbreviations and Special Terms Used In the Report

APHIS

Animal and Plant Health Inspection Service – United States Department of Agriculture

CCA

Central Competent Authority: SENASA

CCP

Critical Control Point

CFIA

Canadian Food Inspection Agency

BSE

Bovine Spongiform Encephalopathy

E. coli

Escherichia coli

FMD

Foot and Mouth Disease

FSIS

Food Safety and Inspection Service – United States Department of Agriculture

GMP

Good Manufacturing Practices

HACCP

Hazard Analysis and Critical Control Point

WOAH

World Organization for Animal Health

MOP

Meat Hygiene Manual of Procedures

RTE

Ready-to-Eat

Salmonella

Salmonella spp.

SENASA

National Service for Animal Health and Agro-Food Quality (Servicio Nacional de Sanidad y Calidad Agroalimentario)

SRM

Specified Risk Material

SSOP

Sanitation Standard Operating Procedures

VIC

Veterinarian in Charge

Executive Summary

This report describes the outcome of an on-site audit of Argentina's poultry and beef inspection system that was conducted by the Canadian Food Inspection Agency (CFIA) from September 9 to 25, 2013.

This audit had three objectives:

1. To conduct a maintenance audit of the beef inspection system for the beef products that are currently allowed to be exported into Canada. The goal was to verify that Argentina continues to maintain a food safety system for beef that is equivalent to that of Canada with the capacity to produce products that are safe, unadulterated, and properly labelled in accordance with the Canadian meat inspection system. From January 1 to December 31, 2012, Argentina exported 815,167 kilograms of processed beef products to Canada.
2. To evaluate the programs and controls to determine if raw beef can be exported to Canada from the geographical regions of Argentina that the CFIA has determined to be free of Food and Mouth Disease (FMD) with and without vaccination.
3. To conduct an initial review of the poultry inspection system to assess its equivalence with the Canadian poultry inspection system with the intention to allow the export of poultry to Canada from Argentina.

Overall, the audit of the Central Competent Authority (CAA) indicated an effective organizational structure, facilities, equipment, transportation, communication, personnel, and training of the competent authority, to support the objectives of meat and meat product inspection and certification programs for export to Canada.

However, the following issues need to be addressed:

1. Beef inspection: not all the requirements of Chapter 4, Annex O of the CFIA Meat Hygiene Manual of Procedures (MOP) were being followed in all establishments. The Policy described in Annex O or equivalent must be implemented in order to allow the export of raw beef to Canada. The CFIA auditor determined that SENASA is not routinely incising the lateral retropharyngeal lymph node as required. SENASA followed up during the audit to remind field staff of this requirement. Beef grading was not evaluated during this audit.
2. Poultry Inspection: a major difference was identified during the audit related to the trimming of partially condemned portions. In Canada, all inedible portions are removed prior to the approved carcasses leaving the evisceration room, while in Argentina, carcasses with minor condemnable portions are allowed to leave the evisceration floor and pass into the chilling system where these portions are then removed and discarded. The CFIA desk review had already identified significant differences between the Argentina's and Canada's poultry grading programs, consequently, CFIA concluded that Argentina's poultry grading program is not equivalent, and therefore export of Argentinian poultry with a grade designation cannot be allowed. However, Canada does allow the imports of ungraded poultry if all other requirements are met. This program was not reviewed as part of the on-site audit. Similarly, product standards for poultry mechanically separated meat differ between Argentina and Canada, so companies that intend to export this product will need to meet the CFIA standards. Finally, control of evisceration may need to be standardized through all poultry establishment to ensure that contamination is effectively controlled in all poultry plants.
3. Compliance and Enforcement Issues: Although the CCA maintains the legal authority and the responsibility to enforce all applicable laws and regulations governing Argentina and third country requirements, the auditor found that these requirements were not consistently applied throughout the system. As such, oversight of the implementation of effective sanitation and establishment operations will need further improvement.

Following the review of the action plans provided by SENASA, Argentina's beef inspection system for slaughter, cutting and processing was determined to meet Canada's requirements and in addition to cooked boneless beef, raw fresh/frozen boneless beef is now approved for export to Canada.

However, based on audit observations and review of subsequent action plans from SENASA, Argentina's Poultry inspection system cannot be approved. See "Supplementary response" below-

Supplementary response based on the information received on April 15, 2016

Following the review of the action plans provided by SENASA, it was determined that Argentina's poultry meat inspection system for slaughtering, cutting, and processing meets Canadian requirements: in addition to cooked boneless chicken; fresh/frozen raw boneless chicken is now approved for export to Canada. However, the import of poultry feet is not allowed because the Canadian requirements for this product are not met.

Documents reviewed by CFIA confirm there are major differences between the Argentina and the Canadian grading poultry system. The CFIA had concluded that the poultry grading program in Argentina is not equivalent to Canada so the CFIA maintains the conclusion that the poultry grading program in Argentina is not equivalent. The import of poultry from Argentina cannot be authorized with a grade designation. Canada allows import of poultry without designation when all other requirements are met.

For mechanically separated poultry meat, the standards in Argentina and Canada are different, so the establishments that intend to export these products must meet Canadian standards.