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Final report of an audit conducted in Hungary to evaluate the meat inspection system governing the production of rabbit meat and meat products intended for export to Canada - October 2 and 10 to October 12, 2017

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Abbreviations and special terms used in the report

BIP
Border inspection post
CCA
Central Competent Authority
CFIA
Canadian Food Inspection Agency
CGO
County Government Office
CVED
Common veterinary entry document
DFCC
Ministry of Agriculture Department of Food Chain Control
ENAR
National Animal Identification and Registration System (translated to English)
FFSD
Food and Feed Safety Directorate
HACCP
Hazard analysis critical control points
NFCSO
National Food Chain Safety Office
NRCP
National residue control plan
MRL
Maximum residue limit
RSAFF
Rapid Alert System for Food and Feed
TIR
Animal Information System (translated to English)

Executive summary

This report describes the outcome of an on-site audit of the meat inspection system governing the production of rabbit meat and meat products intended for export to Canada. The audit was conducted by the Canadian Food Inspection Agency (CFIA) during the period of October 2 and 10 to 12, 2017.

The objective of the audit was to verify that the meat inspection system governing rabbit meat and meat products in Hungary are functioning in a manner determined to be equivalent to that of Canada as producing meat products that are safe, unadulterated, and properly labelled. More specifically, this audit focussed on establishment by establishment approval to establishment interested to export to Canada.The audit covered verification of activities within the following subject areas:

Overall, the audit results showed that rabbit meat inspection system in Hungary is performing as intended in an adequate manner and generally demonstrated an acceptable implementation of controls for all areas described above.

The rabbit establishment visited was under normal production status when observed. The establishment and competent authority provided sufficient written documents and records upon request to substantiate the implementation of rabbit meat inspection system. This establishment may be approved by CFIA for the export of rabbit meat and meat products to Canada upon finalization of this report and agreement on the text of the official meat inspection certificate for both animal and public health attestations.

Following the review of the action plan provided by NFCSO, the CFIA has determined that Hungary's rabbit meat inspection system for slaughter, cutting and deboning meets Canadian import requirements. Therefore, the 1 audited establishment will be able to export rabbit meat and meat products to Canada once the required steps regarding finalization of import requirements, official meat inspection certificate, and listing listing of the establishments on the CFIA website are completed.

1 Introduction

1.1 Audit objective, scope, and methodology

This audit was conducted in response to the request from competent authority that 1establishment is interested to export rabbit meat and meat products to Canada. As only 1 establishment was in scope of this audit, an establishment-by-establishment approval approach was selected. The audit covered verification of activities within the following subject areas:

Administrative functions were reviewed at Central Competent Authority (CCA) headquarters during which the auditor evaluated regulatory framework, oversight framework, enforcement framework, training framework, export controls and import controls. The CFIA auditor was accompanied throughout the audit by representatives from the CCA and county/district government offices.

Table 1: Summary of audit scope
Competent authority/establishment visits Number of sites visited Locations
Opening meeting N/A Budapest
CCA headquarters 1 Budapest
Laboratory responsible to conduct testing for microbiology and chemical residues 1 Budapest
Rabbit slaughter and processing (boning/cutting) establishment 1 Baja
Closing meeting N/A Budapest

1.2 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

The State Secretary for Food Chain Control of the Ministry of Agriculture is responsible for the animal health and veterinary public health in Hungary. The National Food Chain Safety Office (NFCSO), created in 2012, incorporated almost all aspects of the food chain safety supervision into a single authority. The state secretary for food chain control directs the NFCSO. At regional level, the administration consists of 19 County Government Offices (CGO) responsible for implementation and enforcement of the law. At county level, all authorities involved in official controls of the food chain have been merged and integrated into the CGOs. The CGOs are under administrative controls of the prime minister's office and receives functional direction from the NFCSO. Each CGO has district government offices and local offices to support implementation of official controls of the food chain.

The sources of Hungarian law are the acts of Parliament, governmental and ministerial decrees, and decrees of local governments. The acts assign the central administration tasks. The government decrees designate the competent authorities and specify the organization of controls, and the ministerial decrees contain the implementation procedures. Act number XLVI of 2008 on food chain and on the supervision of the food chain is the single framework for all relevant legislations. The implementation of official controls of the food chain is based on the relevant national and European Union legislations. The NFCSO Department of Food and Feed Chain Safety (FFSD) maintain a library of regulations about food and feed production which gets updated monthly. This collection of regulations is sent to the CGO and is also available to the public on the NFCSO's website.

Conclusion

The competent authority has organizational and regulatory framework to ensure the development, planning and implementation of the official controls of the food chain.

2.2 Oversight framework

Food business operator subject to authorization involves facilities that produce products of animal origin. Operation at these facilities can only begin after completion of authorization procedure. These facilities have to be in compliance with regulation number 852/2004/ EC annex II and, depending on the type of the facility; they also have to fulfill the requirements of regulation number 853/2004/EC annex III.

Authorization procedures include the tasks for food business operator and the competent authority. The tasks of the food business operator include getting a building permit from the building control authority of the district. After this task is completed, an occupancy permit is needed for which the specialised authority holds an on-site inspection. Thereafter, the establishment can request an operating permit from the CGO.

Before granting the operating permit, the CGO shall conduct an on-site inspection. During the on-site inspection, the establishment has to be evaluated during operation and it can only get an operating permit for the activity which was evaluated during the on-site inspection. After the on-site inspection, the establishment gets a temporary permit for 3 months. If, during an inspection that is carried out after the temporary permit, the authority finds a non-compliance, then a second temporary licence can be granted for another 3 months. However, the whole procedure cannot take more than 6 months.

After a 3-month period and a successful inspection, the establishment can be provided a permanent operating permit. The operating permit includes the activity that the facility is entitled to carry out. Approval number for each operating permit is issued by the NFCSO-FFSD. The list of facilities owning an operating permit in Hungary is available on the NFCSO website (in Hungarian only).

The county and district government offices are responsible to provide the government oversight at slaughter, processing and storage establishments. At slaughter establishments, daily presence is maintained by the official veterinarians and official auxiliaries. In processing and storage establishments, government oversight is based on the risk and importing country requirements. However, all processing and storage establishment are required to develop and implement the HACCP plans. At slaughter establishments, government oversight includes daily hygiene inspection checklist, ante-mortem inspection, and post-mortem inspection. Animal welfare and HACCP checklists are completed multiple times (4 to 5 times a year) to ensure that all elements were completed over the period of 1 year. Additionally, yearly comprehensive review of each establishment is completed by the county/district government office. This comprehensive review also includes the review of work completed by the local staff. All inspection related data are stored in the electronic database called as national animal health information system. NFCSO has access to all inspections and supervisory oversights completed in each county. During the onsite audit, it was observed that some non-compliances and associated corrective actions and follow-ups were not recorded on the inspection verification report, and therefore not auditable. This is contrary to EC No 882/2004, article 8, paragraph 3:

Internal Audit Directorate of NFCSO is responsible to compile the internal audit report for NFCSO and report it to the prime minister's office. Based on the directions from Internal Audit Directorate, NFCSO completes the inspection of work conducted by the 5 to 6 CGOs per year, so that every CGO is checked every 3 to 4 years. County/district government office completes inspection of every local office once per year. All data is compiled by the Internal Audit Directorate and stored using an electronic platform. The auditor was informed that government oversight could be modified, based on the importing country's requirements.

Conclusion

Adequate government oversight was in place to ensure the delivery of official controls of food chain, as per council directive 854/2004.

Non-compliances and associated corrective actions and follow-ups were not always recorded and therefore not auditable. This is contrary to council directives No 882/2004, article 9.

2.3 Training framework

The delivery of training is completed by NFCSO and CGOs. On a yearly basis, a training plan is developed by NFCSO to deliver national level trainings in various counties. Furthermore, each CGO develops a training plan to deliver the trainings to district government offices and associated local offices. Training courses include, but are not limited to, official controls of approved food producing establishments, export certification and verification, ante-mortem and post-mortem inspection, animal welfare during slaughter HACCP and animal welfare inspection etc. The training needs are monitored and assessed through several tools including internal audit, technical audit, training sessions, evaluation of test results and discussion groups. The effectiveness of the training is evaluated through tests and questionnaires at the end of the training. Records of training are kept as hard copies at CGOs and NFCSO.

Additionally, all public administration employees are required to complete technical and non-technical trainings every year. Trainings are available as e-learning, in-class or combination. The National Public Service University is responsible to administer or recognize trainings. The training records are tracked using an electronic platform known as PROBONO.

Conclusion

The CCA possesses a training framework required to train human resources involved in planning, development and implementation of the official controls of the food chain.

2.4 Export controls

The establishment interested to export products of animal origin to a third country shall apply to the CGO. The CGO forwards the application of the establishment to the NFCSO-FFSD. After the evaluation of the received application and documents, the NFCSO-FFSD carries out an on-site inspection in the establishment with the co-operation of CGO and the official staff responsible for the direct supervision of the establishment. In case of any kind of deficiencies, the NFCSO-FFSD asks for an action plan. Once the deadline indicated in the action plan is passed, NFCSO officials from the county/district government office complete the follow-up inspection. After the establishment is approved, the NFCSO sends the application to the Ministry of Agriculture Department of Food Chain Control (DFCC) and the DFCC sends it to the competent authority of the importing country. A list of all establishments eligible to export to the EU and third countries is maintained by NFCSO and is updated as required.

Export verification and certification is completed by the official veterinarian. For each shipment, an official veterinarian is responsible to check the condition of trailer, the condition of product to be exported and associated documents. An official veterinarian signs the certificate after confirming that the products meet the importing country requirements. There is no electronic platform in place to store the signed export certificates: therefore, export certificates are stored onsite at each establishment. During an interview with the official veterinarian and CGO, it was observed that no clear process is in place to inform official veterinarians responsible for signing the export certificates on the foreign country's import requirements for which he/she is attesting to.

Conclusion

Adequate export controls were in place to ensure that only eligible establishments are approved to export to Canada. However, there was no clear process in place to inform official veterinarians responsible for signing the export certificates on the foreign country's import requirements for which he/she was attesting to.

2.5 Import controls

The main legislation on border import controls concerning public and animal health are Council directive 91/496/EEC for live animals, and Council directive 97/78/EC for products of animal origin. Hungarian national implementing regulation is 53/2004 [decree of the Ministry of Agriculture and Rural Development (for the import of products of animal origin)]. These pieces of legislation set out the veterinary legislative requirements for the import into or the transit of live animals and products of animal origin through Hungary.

All live animals and products of animal origin (as defined in the annex to Commission decision 2007/275/EC) must be presented at an approved and correctly designated community border inspection post (BIP) to undergo specific veterinary import controls prior to entry or transit through Hungary.

The latest list of BIPs (including Hungary's BIPs) is set out in Commission decision 2009/821/EC and is available on the European Commission's website.

Prior notification of the arrival of the products at the BIP must be given to Hungary in accordance with the rules in Article 3 (1) a of directive 91/496/EEC. Data are usually entered in the Trade Control and Expert System (TRACES), which contains all the information regarding the movement of the consignment, therefore making it traceable to/from destination. The consignments must be presented at the BIP accompanied by all the relevant health certification required in union veterinary legislation.

Consignments will only be accepted if the animals or products are derived from approved countries, regions and establishments, as appropriate, and where the EU approved veterinary residues plan is in place for the specific product group to be exported. In certain cases, safeguard measures introducing additional import conditions or restrictions may apply.

All consignments must undergo documentary, identity and physical checks before being considered cleared for animal and public health purposes. All consignments must be issued with a correctly completed common veterinary entry document (CVED). Sampling can be performed as part of the physical checks and can be performed according to the national monitoring plan or randomly. Sampling is undertaken with a view to check compliance with the health requirements laid down in the accompanying veterinary certificate. Samples are sent to accredited laboratories. If there is a suspicion that the samples will be positive, than the consignment is kept at the BIP, isolated till the results are received. Where and when appropriate, the frequency of the physical check can be reduced. In accordance with animal and public health legislation, consignments that do not follow the above procedures should not be allowed to enter Hungary.

Conclusion

Adequate import controls were implemented to ensure the importation of only eligible meat and meat products, as per Hungarian national implementing regulation 53/2004 [decree of the Ministry of Agriculture and Rural Development (for the import of products of animal origin)] and Council directive 97/78/EC for products of animal origin.

2.6 Enforcement framework

Legal powers to take measures or to impose sanctions in a case where deficiencies or infringements are identified are mainly laid down in:

The NFCSO has set sectorial guidelines and documented procedures on the use of legal powers and common operating procedures describing enforcement measures in most sectors of food safety. The range of actions varies according to the severity of the deficiency or infringement as per example the request for corrective action, the setting deadlines, the fines, the suspension of activities and the suspension of approval or withdrawal of approval.

Conclusion

Policies and procedures were in place to ensure that enforcement action is taken in response to non-compliances related to food safety, animal welfare and food fraud as per council directive 882/2004 and Hungarian acts and regulations.

2.7 Laboratory infrastructure

The NFCSO-FFSD has 4 central and 9 regional laboratories related to food chain safety. The NFCSO-FFSD is also responsible for licensing and registration of private laboratories engaged in food and feed testing. All laboratories are accredited by the national accreditation board according to MSZ EN ISO/IEC 17025:2005. 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 methodologies are selected based on the EU and/or national standards. Validation is completed prior to using the test based on the EU and/or national standards. No deficiency was noted during on-site audit.

Conclusion

The competent authority has an appropriate laboratory infrastructure to complete the microbiological and chemical residue testing for meat and meat products.

3 Ante-mortem, humane handling and animal welfare controls

3.1 Traceability and animal identification

The NFCSO's Directorate of Animal Health and Animal Welfare and the Animal Breeding Directorate are responsible for registration of the holdings, animal identification and movement controls. The central database of the national animal identification and registration system (ENAR) is operated by the animal breeding directorate. Rabbits raised for slaughter are considered raised for commercial purposes and all commercial farms are required to be registered in the animal information system (TIR). Each farm has a unique identifier to ensure the traceability. Individual animals at each farm are not required to be identified. All records are stored electronically.

National legislation act number 46 2008 II chapter requires to develop and maintain a traceability system at every level of the food chain. Food business operators are required to develop a recall plan which equips them to recall and withdraw a product that does not meet regulatory requirements. As an EU member, Hungary participates in the rapid alert system for food and feed (RASFF) system. At the establishment visited, a recall plan was implemented as per requirements and a yearly mock recall was completed.

Conclusion

An animal identification system for rabbit raised for commercial purposes was implemented as per council directive 854/2004 and national legislation act number 46 2008 II chapter, to ensure the traceability of live animals and animal products.

3.2 Ante-mortem inspection

Ante-mortem inspection is completed as per regulation (EC) number 854/2004 of the European parliament and of the Council of 29 April 2004 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption. Ante-mortem inspection of all animals is completed by the registered veterinarian at the farm. After the completion of the ante-mortem inspection, the registered veterinarian issues the health certificate which is valid for 48 hours. Additionally, the producer responsible for raising the animals fills the declaration, and includes usage of all drugs with withdrawal periods. The declaration is valid for 72 hours.

At the receiving of animals, the operator checks the documentation which includes veterinary health certificate, farmer's declaration, and bill of lading. After confirmation of identification, the operator provides all documents to the official veterinarian responsible to complete the ante-mortem inspection at the establishment. The official veterinarian completes the ante-mortem inspection of each lot. A lot is defined as 1 farm, as identified on the ENAR-TIR. Ante-mortem inspection includes animal identification, animal welfare issues and clinical health of animals. After completion of ante-mortem inspection, official veterinarians can either approve or reject the lot for slaughter. All dead on arrivals are inspected by the official veterinarian. The ante-mortem inspection may be completed by the official auxiliaries under the supervision of official veterinarian.

Conclusion

Ante-mortem inspection was completed as per council directive 854/2004.

3.3 Humane handling and animal welfare

Animal welfare at slaughter is verified by the competent authority via ante-mortem inspection and stunning and bleeding checks. At the time of ante-mortem inspection, animals are inspected for any signs of compromised welfare. All animals dead on arrival are counted and inspected by the official veterinarians. All rabbits are stunned using electrocution prior to hanging. Bleeding is completed manually by simultaneous severance of the juglar veins and carotid arteries. Stunning and bleeding effectiveness is verified by the competent authority twice per shift.

Conclusion

Stunning and bleeding was performed and as per Council directives 1099/2009 and 853/2004.

4 Slaughter and post-mortem

Post-mortem inspection is performed as per regulation (EC) number 854/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption. Post-mortem inspection is completed by the official auxiliaries under the supervision of the official veterinarians. The official veterinarian is required to be present onsite at the time of slaughter. Post-mortem inspection is completed in a traditional way where each carcass, cavity and associated viscera is checked by the official auxiliaries at 2 online stations (number of stations may vary). Kidneys are not decapsulated prior to the presentation for the post-mortem inspection. Carcass and associated viscera requiring further veterinary inspection are segregated. Carcasses were processed and packaged with head attached which may result in cross contamination. As per Council directive 853/2004, the carcasses must not contain visible faecal contamination and any visible contamination must be removed without delay by trimming or alternative means having an equivalent effect. Zero tolerance for fecal contamination is implemented at the establishment using a CCP.

Conclusion

Post-mortem inspection was completed as per Council directive 853/2004 and 854/2004. However, carcasses were processed and packaged with head attached which may result in cross contamination.

5 Processing controls

5.1 Chilling/freezing controls

After inspection and evisceration, slaughtered animals must be cleaned and chilled to not more than 4 °C as soon as possible, unless the meat is cut while warm. The food business operator shall ensure that during cutting, boning, trimming, slicing, dicing, wrapping and packaging, the temperature of the meat from lagomorphs is maintained at not more than 4 °C by means of an ambient temperature of 12 °C or an alternative system having an equivalent effect. However, meat may be boned and cut prior to reaching the temperature mentioned above when the cutting room is on the same site as the slaughter premises, provided that it is transferred to the cutting room either directly from the slaughter premises or after a waiting period in a chilling or refrigerating room.

As soon as the meat is cut and, where appropriate, packaged, it must be chilled to a temperature of not more than 4 °C. Meat must attain a temperature of not more than 4 °C before transport, and be maintained at that temperature during transport. Meat derived from lagomorphs intended for freezing must be frozen without undue delay, usually to a temperature of not more than -18 °C. There is no time requirement for chilling or freezing of carcasses and offals. Air chilling was used to chill the rabbit carcasses at the establishment visited. Chilling and freezing controls at establishment visited are maintained using a CCP.

Conclusion

Chilling and freezing controls were implemented as per council directive 853/2004.

5.2 Water retention

There are no regulatory requirements related to retained water control program concerning rabbit meat. At the establishment visited, rabbit carcasses are chilled using air.

Conclusion

No regulatory requirement related to retained water in the rabbit carcasses and offals is currently in effect. Therefore, the establishment audited was not required to implement a water retention control program.

5.3 Allergen control program

As per article 9 (1)(c) of regulation (EC) 1169/2011, any ingredient or processing aid listed in annex II or derived from a substance or product listed in annex II causing allergies or intolerances used in the manufacture or preparation of a food and still present in the finished product, even if in an altered form, shall be declared by the food business operator. 14 major allergens are listed in annex II to the regulation 1169/2011 and the presence of any of these allergens shall be declared by the food business operator. The allergens listed in annex II of regulation (EC) 1169/2011 are recognized across Europe as the most common ingredients or processing aids causing food allergies and intolerances. The list of allergens is similar to that of Canada, with the exception of pine nuts. If the food business operator uses allergens onsite, allergen control program must be implemented. The establishment visited doesn't use allergens; therefore no allergen control program is in place.

Conclusion

The establishment visited didn't use allergens on-site, and no allergen control program was implemented.

The list of allergens provided in Council directive 1169/2011 does not include pine nuts, which is contrary to Canadian requirements.

6 HACCP and pre-requisite programs

As per the regulation (EC) number 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs, food business operators shall put in place, implement and maintain a permanent procedure or procedures based on the HACCP principles. The implementation of HACCP and prerequisite program is verified by the competent authority using checklists. The tasks to verify the implementation HACCP and prerequisite programs included yearly comprehensive review by the county/district government office. Furthermore, local inspection personnel verify the implementation of HACCP and prerequisite programs multiple times in a year to ensure that all elements are covered over the period of 1 year. At the establishment visited, all elements of HACCP and prerequisite programs were implemented, as per regulatory requirements.

Conclusion

HACCP and prerequisite programs were implemented as per regulatory requirements.

7 Microbiological controls

Microbiological controls include official sampling and self-monitoring by the food business operator. For official sampling, microbiological plan is developed annually by the NFCSO food safety experts. The annual microbiological sampling plan is distributed to each CGO for implementation. Thereafter, each CGO allocates samples to each establishment. For this year (April 2017 to March 2018), 8 microbiological samples are allocated to 2 rabbits establishments in Hungary. Testing of samples is completed by the government or accredited laboratories. In case of non-compliances, NFCSO gets notified from the laboratories. In response, NFCSO sends a letter to the responsible CGO which completes the follow-up at the affected establishment to determine the root cause. Based on the follow-up inspection, CGO may ask the establishment to submit an action plan to prevent the recurrence of the issue with a specified deadline. The CGO compiles the report and submits to the NFCSO. All data is stored electronically.

Commission regulation (EC) no 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs specifies the requirements for food safety and process hygiene microbiological sampling. Process hygiene microbiological sampling from rabbit carcasses is not required. However, finished rabbit meat products shall be tested for salmonella. At the establishment visited, rabbit meat products are tested on a monthly basis for Salmonella, Listeria, Staphylococcus aureus, E. coli, Enterobacteriaceae, Campylobacter, and total microbial count. Furthermore, environmental swab sampling is completed on a monthly basis for Salmonella and total microbial count and semi-annually for mold and E. coli.

Conclusion

Official sampling and self-monitoring sampling was completed as per the EU regulatory requirements.

8 Chemical residue controls

Hungary must implement residue monitoring plans for the illegal use of substances, misuse of authorized veterinary medicines, and minimize residue recurrence in accordance with directive 96/23/EC on measures to monitor certain substances and residues thereof in live animals and animal products. The maximum residue limit (MRL) for each substance are established at the EU level by the relevant species and products or tissues by commission regulation (EU) No 37/2010 of 22 December 2009 on pharmacologically active substances and their classification regarding maximum residue limits in foodstuffs of animal origin.

Council directive 96/23/EC requires member states to adopt and implement a national residue monitoring plan for specific groups of residues. Based on the production volume of each commodity, the European Commission (Directorate General for Health and Food Safety) sends the number of samples to be collected and analyzed for each group. The NFCSO-FFSD is responsible for the preparation of the national residue control plan (NRCP).

The legislations governing the design and implementation of residue monitoring plans are as follows:

The directive lays down specific sampling levels and frequencies, as well as the groups of substances to be monitored for each food commodity. Samples to be taken under the NRCP are allocated to the CGO, mainly on the basis of the number of animals slaughtered and the volume of animal products produced in the previous year. All NRCP samples are taken by official staff of the district government offices. The NRCP indicates species/product to be sampled, the number of samples to be taken on farm/slaughterhouse, the substance group to be analysed and the laboratory responsible for the analysis. The NRCP is distributed to the CGO every March. Sampling begins in April and the plan specifies the samples to be taken each month. The NFCSO-FFSD monitors the implementation of the plan on a monthly basis and with a mid-year review to make any necessary adjustments. Copies of results are sent to the inspector, normally within a month. In addition to the sampling prescribed in the NRCP, the CGOs have discretion to take extra samples in the case of suspicion. In case of a positive confirmed sample, the NFCSO-FFSD and the animal health and food control services are immediately informed. The outcome could be an immediate ban on sales of these animals or products, and/or restriction of movements off the farm. In case of non-compliances, NFCSO get notified from the laboratories. In response, NFCSO sends a letter to the responsible CGO which completes the follow-up at the affected establishment to determine the root cause. Based on the follow-up inspection, CGO can ask the establishment to submit an action plan to prevent the recurrence of the issue within a specified deadline. The CGO compiles the report and submits it to the NFCSO. All data is stored electronically. For this year (April 2017 to March 2018), 140 samples are assigned to 2 rabbit establishments. The samples include substances having anabolic effect and unauthorized substances, and veterinary drugs and contaminants. At the establishment visited, all samples were collected and processed as per regulatory requirements.

Conclusion

Chemical residue controls were implemented as per the EU regulatory requirements.

9 Closing meeting

The closing meeting was held in Budapest with representatives from Ministry of Agriculture and NFCSO on October 12, 2017. At the meeting, a summary of the preliminary findings from the audit were presented by the CFIA lead auditor.

Conclusions

Overall, the audit results showed that rabbit meat inspection system in Hungary is performing as intended in an adequate manner and generally demonstrated an acceptable implementation of controls for all areas described above.

The rabbit establishment visited was under normal production status on the auditing day. The establishment and competent authority provided sufficient written documents and records upon request to substantiate the implementation of rabbit meat inspection system. This establishment may be approved by CFIA for the export of rabbit meat and meat products to Canada upon finalization of this report and agreement on the text of the official meat inspection certificate for both animal and public health attestations.

Following the review of the action plan provided by NFCSO, the CFIA has determined that Hungary's rabbit meat inspection system for slaughter, cutting and deboning meets Canadian import requirements. Therefore, the audited establishment may be able to export rabbit meat and 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.

11 Annex

Annex 1: Summary of the NFCSO action plan in response to the CFIA recommendations of the audit completed to evaluate the rabbit meat inspection system in Hungary
CFIA recommendations NFCSO actions plans/comments

1. CFIA recommends that all non-compliances and associated corrective and follow-up actions be recorded, as per Council directives No 882/2004, article 9.

  • Central circular (annex 2 and 3 to our letter) was sent to all CGOs highlighting the differences between Canadian and EU/Hungarian national law and also to put special emphasis on the other findings of the audit, per example the compliance with the requirements of article 9, regulation 882/2004/EC.
  • Deficiencies identified during on-site inspections that can't be corrected immediately and thus requiring an action plan from the establishment are documented immediately while minor deficiencies that are immediately corrected are documented in the periodic reviews by the official veterinarians.
  • Compliance with the documentation requirements will be further checked during the periodic central level inspections by NFCSO.

2. CFIA recommends that a system be implemented to ensure that official veterinarians responsible for signing export certificates have access to Canadian import requirements.

  • Central circular was sent to all CGOs (annex 2 and 3 to our letter) requesting the CGOs to ensure appropriate access for the official veterinarians to the Canadian requirements; official veterinarians are aware of and are familiar with the relevant website of CFIA.
  • We use the email notification system of CFIA to receive up to date information on Canadian requirements.
  • Furthermore we use the information provided by the European commission on the SPS related notifications as a source of information.
  • The Ministry of Agriculture will inform NFCSO and the CGOs on future changes in Canadian requirements on a periodic basis as a general approach, or on an ad-hoc basis when important changes take for immediate actions.

3. CFIA recommends that a procedure be implemented to prevent the potential contamination of packaged carcasses from attached heads.

  • As it is recorded in the follow-up inspection report by the local competent authority (annex 4 and 5 to our letter) the establishment appropriately modified its process so to eliminate the risk of possible cross-contamination of packaged carcasses from attached heads.

4. CFIA recommends an allergen control program to be developed, maintained and implemented in all establishments eligible to export meat products to Canada and inspection oversight shall be provided as an export requirement to Canada. The list of allergens for the meat products destined to Canada shall include pine nuts.

  • Central circular was sent to all CGOs (annex 2 and 3 to our letter) requiring all establishments exporting meat products to Canada to maintain an allergen control program capable of controlling the risk arising from allergens.
  • Attention was drawn to the differences in the list of allergens as well so that establishments shall include pine nuts in their allergen control program.
  • According to the on-site inspection report of the local competent authority, the establishment paid special attention to this additional criteria and determined that the establishment doesn't receive any products containing pine nuts and the geographical location and the surrounding vegetation also ensure an absolutely pine free environment.
  • Implementation of an appropriate control program will be further checked during the next central level inspection by NFCSO
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