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Final report of virtual audit of Austria's meat inspection system governing the production of bovine and swine meat and meat products – March 14 to 23, 2022

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Abbreviations and special terms used in the report

BAVG
Federal Office for Consumer Health
BIP
Border Inspection Post
BMSGPK
Federal Ministry of Social Affairs, Health, Care and Consumer Protection
CA
Competent Authority
CCA
Central Competent Authority
CCP
Critical Control Point
CFIA
Canadian Food Inspection Agency
EC
European Commission
EU
European Union
FBO
Food Business Operator
FSMS
Food Safety Management System
HACCP
Hazard analysis critical control points
LH
Provincial Governor
LMSVG
Food Safety and Consumer Protection Act
PRPs
Good Hygiene and Good Manufacturing Practices
PVS
Provincial Veterinary Services
MIR
Meat Inspection Regulation
NRCP
National Residue Control Monitoring Plan
OA
Official Auxiliaries
OV
Official Veterinarian
RTE
Ready-to-Eat
VIS
Consumer Health Information System

Executive summary

This report describes the outcome of virtual audit of the meat inspection system governing the production of bovine and swine meat and meat products in Austria intended for export to Canada. The Canadian Food Inspection Agency (CFIA) conducted the audit virtually from March 14 to 23, 2022 due to COVID-19 travel restrictions. Therefore, findings of this audit were based on document review and interviews of representatives from the Federal Ministry of Social Affairs, Health, Care and Consumer Protection (BMSGPK) and Food Business Operator (FBO). Lack of on-site visit to the establishments selected for this audit resulted in limited review of the competent authority (CA) and FBO controls at each establishment.

The main objective of the audit was to verify if Austria continues to implement a meat inspection system equivalent to that of Canada, producing safe, unadulterated, and properly labelled meat products for export to Canada.

The audit scope included virtual visits to the central competent authority (CCA) headquarters and slaughter and processing establishments located in different regions of Austria. These included 2 slaughter houses (1 each for bovine and swine) and 1 meat processing establishment.

The audit covered activities within the following subject areas:

Following the review of action plans provided by competent authority, the CFIA determined that Austria continues to implement the bovine and swine meat inspection and meat processing systems determined equivalent to those of Canada. The audit report includes the conclusions and recommendations for Austria to address the deficiencies identified during the virtual audit.

1. Introduction

1.1 Audit objective, scope, and methodology

The audit covered verification of activities within the following subject areas:

The CFIA auditors virtually reviewed the administrative functions of CCA. The auditors evaluated regulatory framework, oversight framework, enforcement framework, training framework, export controls and import controls. Lack of on-site visit to the establishments selected for this audit resulted in limited review of the competent authority and FBO controls at each establishment.

Table 1: Summary of audit scope
Competent authority/establishment audited Number of sites visited Locations
Opening meeting and closing meeting 1 Virtual (skype)
Meat processing establishment 1 Virtual (skype)
Bovine slaughter establishment 1 Virtual (skype)
Swine slaughter establishment 1 Virtual (skype)

The CFIA currently recognizes Austria's meat inspection system for bovine, swine and poultry, and other minor species such as ovine, caprine, farmed cervids and rabbit. However, this audit focussed on the assessment of meat inspection system for bovine and swine only.

1.2 Legal basis for the audit and audit standards

The CFIA conducted audit under the specific provisions of Canadian laws and regulations, in particular:

The audit standards also included all applicable European Union (EU) regulations determined as equivalent as part of the agreement between the European Community and the Government of Canada on sanitary measures. These measures protect public and animal health in respect of trade in live animals and animal products as amended from time to time as part of bilateral negotiations.

2. Competent authority and oversight

2.1 Regulatory framework

Austria is an EU Member State and it is essential for Austria to implement European Parliament and the Council adopted regulations. Regulation (EC) No. 178/2002 lays down the general principles and requirements of food law (General Food Law Regulation). Other key relevant EU regulations are:

In addition to EU regulations, Austria also enforces its own inspection laws and policies in registered establishments to ensure that meat products destined for exports are safe, wholesome and produced under equivalent inspection system. The key relevant Austrian national regulations are:

The Federal Ministry of Social Affairs, Health, Care and Consumer Protection issues both the Implementing Decrees and guidelines.

Conclusion

The competent authority has regulatory framework to ensure the development, maintenance and implementation of the meat inspection system and official controls of the food chain.

2.2 Oversight framework

The Federal Ministry of Social Affairs, Health, Care and Consumer Protection (BMSGPK), headed by the Chief Veterinary Officer of Austria, is the Austria's central competent authority and located in Vienna. The BMSGPK is responsible for most of the legislations governing feed and food safety, animal health, and animal welfare.

Additionally, there are 9 provinces in Austria, and each province has its own Provincial Veterinary Services (PVS), which are part of the provincial administration and the indirect federal administration system, and act on behalf of the Provincial Governor (LH) as federal authorities. The LH is responsible for the implementation of controls and employs staff of veterinary administration in the provinces and districts. The PVS employ Official Veterinarians (OV) permanently for official meat inspections and hygiene controls in meat establishments. The LH may also appoint private veterinary practitioners who act as official veterinarians (authorised/assigned veterinarians) and perform these tasks. In addition, there are 94 District Veterinary Services in Austria that manage and coordinate District Veterinary Officers, executive official subordinate to provincial veterinarian in chef.

As per article 18 of Regulation (EC) No. 2017/625, an OV is present on-site and performs ante- and post-mortem inspection and other inspection activities such as assessing food safety compliance and issuing certificates at animal slaughter establishments. The OV assigns the performance of an action to an Official Auxiliary (OA) who can perform post-mortem inspection and other inspection activities (daily/weekly inspections, sampling) under OV supervision. The competent authority must ensure that sufficient numbers of OA/OV are present at slaughterhouse/establishment. According to section 24 (3) of Food Safety and Consumer Protection Act (LMSVG), the appointed OVs through general hygiene inspections supervise the activities of the assigned veterinarians at the animal slaughter and meat processing establishments. Implementing Decree No 8 deals with controls of authorized official veterinarians. As per Austrian control plan (section 31 of LMSVG and Implementing Decree No. 8), the PVS implement a minimum control frequency of 20% of OVs every year.

During virtual audit, the CFIA noted that Austria has the CCA with indirect federal administration system with PVS overall responsibilities in relation to food safety and animal health and welfare controls. The CFIA noted that there are regulatory requirements of supervisory oversight controls in Austria but the provincial CA did not ensure the consistent delivery of supervisory oversight controls at a minimum control frequency of 20% every year as specified in their regulations. The PVS did not complete supervisory oversight controls consistently as it was completed once in 2019 and 2022 at the bovine slaughter establishment and once in every 5 years at the swine slaughter establishment. Officials did not complete supervisory oversight controls at the meat processing establishment at all.

Conclusion

The government oversight was adequate to ensure compliance with regulatory requirements for official controls of food chain. However, as audited, all slaughter and meat processing establishments exporting to Canada are not consistently under the supervisory oversight controls as per Austria's LMSVG and Implementing Decree No. 8.

2.3 Training framework

As stipulated in article 5 of the Regulation (EU) No. 2017/625, the competent authorities must have access to a sufficient number of qualified staff to perform official controls and activities efficiently and effectively. The European Commission organises workshops within the program "Better Training for Safer Food". It is a training program covering legislation in the area of food, feeds, animal health, animal welfare and plant health. It serves for education of professionals from the EU Member States involved in the performance of official control activities. The aim of the program is to provide updated information on EU legislation and to ease the harmonisation and better efficiency of official control checks across EU Member States. Additionally, the Regulation (EU) No. 2019/624 lays down specific minimum training requirements for OVs, OAs and other inspection staffs.

Austria implements Initial and Continuing Vocational Training Regulation. Under this regulation, inspection officials receive 9 months inspection activity related theoretical and regular practical trainings. These trainings follow the training framework plans set out in annexes of this regulation. It is obligatory for the inspection staffs to participate in continuing education.

The CCA through PVS defines the training requirements and organisation of continuous training for staff performing official control at slaughter and meat processing establishments. The OVs maintain up-to-date knowledge through regular continuing education activities. The PVS discuss and communicate regularly with OVs and OAs to decide training and development requirements.

The CFIA noted that PVS organised various training courses for OVs and OAs responsible for performing official veterinary control at slaughter and meat processing establishments in Austria.

Conclusion

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

2.4 Export controls

The Regulations (EC) No. 178/2002 and No. 2017/625 articles 86 to 89 governs the controls for export of meat and meat products. The BMSGPK via PVS has the legal authority and responsibility to register and de-register establishments eligible to export to third countries. The establishments apply to the PVS and demonstrate the capacity to implement the third countries export requirements to obtain the registration approval and number. The LH approves the establishments following satisfactory inspection by the provincial or district veterinary services. The PVS maintains an updated list of eligible establishments into the Central Establishment Register. The PVS perform an annual verification of the implementation of the third countries export requirements. The information for export of animals and animal products are publicly available at the Kommunikationsplattform VerbraucherInnengesundheit (KVG) website (in German only).

In Austria, the national legislation and decree and EU regulations regulate the export and certification of meat and meat products. The FBOs in Austria interested to export meat to Canada must meet the Canadian requirements. The trained OV verifies the compliance with Canadian requirements and completes the export verification and certification. For each shipment, an official veterinarian is responsible for checking the condition of trailer, the condition of product to be exported and associated documents. An OV signs, stamps and issues the certificate after verifying and confirming that the products meet the importing country requirements. The original templates of the certificates are available in Trade Control and Export System or KVG website.

The CFIA noted that the inspection services performed on-site verification of export certification for each shipment at swine and bovine slaughter and meat processing establishments. However, the Austrian annual export verification didn't include verification of the Canadian requirements; water retention control programs or priority allergen including pine nuts or E. coli O:157:H7.

Conclusion

Adequate export controls and certification procedures are in place in Austria to ensure the export of meat and meat products to Canada that meet Canadian requirements. However, Austria's annual audit did not include the verification of the Canadian export requirements.

2.5 Import controls

As required in the Regulation (EC) No. 2017/625, the competent authority performs official controls at the point of entry regularly on animals and goods entering the EU. All EU Member States have Border Inspection Posts (BIPs) for the entry of live animals, animal products and other veterinary goods imported from third countries. All live animals and animal products as defined in the Commission decision 2007/275/EC must undergo specific veterinary import controls at an approved and designated BIP prior to entry or transit through the territory of EU Member States. The Regulation (EC) No. 2019/2129 establishes rules for the uniform application of frequency rates for identity checks and physical checks on certain consignments of animals and goods entering the EU Member States. The competent authority at the BIPs may decide the frequency of physical checks for certain goods from certain countries.

Austria also implements national legislations such as Community Law, Animal Diseases Act, LMSVG and the ordinances based thereon, in particular the Veterinary Import Ordinance. These Austrian regulatory provisions govern the restrictions and controls applicable to the transport and import of live animals, foodstuffs and goods of both animal and non-animal origins.

The CFIA noted that Austria has regulatory import controls and certificate verification procedures in place that ensure import of only eligible meat and meat products from approved establishments and third countries into Austria.

Conclusion

Austria has a well-established regulatory import controls in place for live animals and animal products imported or transitioned from any third country as stipulated in the Regulations (EC) No. 2017/625 and No. 2019/2129.

2.6 Enforcement framework

As per article 138 of the Regulation (EU) No. 2017/625, Austria is responsible for imposing immediate interventions in case of non-compliance. The competent authorities shall give priority to action to be taken to eliminate or contain risks to human and animal health, and animal welfare. The enforcements actions include the performance of intensified official controls on animals, goods and operators for an appropriate period and the official detention of animals and goods. The Regulation (EU) No. 178/2002 requires Austria to enforce the food law, and monitor and verify that the relevant requirements of food law, maintain a system of official controls covering all stages of food production, processing, and distribution, and lay down the rules on measures and penalties applicable to infringements of the food law.

Additionally, under section 39 of the LMSVG, Austria enforces corrective actions in response to violations detected in any legal regulations laid down in the food law. The state governor enforces the required measures according to type of violation and taking into account principle of proportionality to correct non-conformities or mitigate risks, including in particular regarding approval, suspension and withdrawal of establishments.

In response to non-compliance, the PVS and CCA initiate enforcement actions such as warning, suspension of certification and further administrative enforcement measures as needed. The CFIA observed that the competent authority implemented enforcement measures at each establishment as per the EU and Austrian national regulations. As a result of the CFIA's audit findings in contravention of the Canadian regulatory requirements at bovine slaughter establishment, the BMSGPK suspended temporarily the permission of the establishment to export meat to Canada immediately. This establishment has subsequently been removed from the list of Austrian establishments exporting meat and meat products to Canada.

The CFIA noted that the competent authority has regulatory enforcement framework in place to carry out the necessary officials controls of the meat inspection system in Austria. The BMSGPK via PVS implements the enforcement framework and has a procedure in place to escalate the repetitive non-compliances to the higher management level from district to provincial and to central level to mitigate risk.

Conclusion

Legal authority, policies and procedures are in place in Austria to ensure enforcement actions in response to non-compliances related to food safety as per Regulations (EU) No. 2017/625 and No. 178/2002, and Austrian national regulations.

3. Ante-mortem, humane handling and animal welfare controls

3.1 Traceability and animal identification

As per Regulations (EC) No. 625/2017, No. 2075/2005 and No. 853/2004 annex II section III, the FBO must, as appropriate, request, receive, check and act upon food chain information in respect of all animals sent or intended to be sent to the slaughterhouse. The EU Member State is responsible for the day to day enforcement through their national legislation and control activities. Additionally, article 18 of the Regulation (EC) No. 178/2002 of the European Parliament and of the Council of 28 January 2002 governs the traceability principles and requirements of food law.

Nationally, Austria implements Consumer Health Information System (VIS). The VIS contains information on populations identification, holdings registration and movements of cattle, sheep, goats, pigs, horses, poultry, wild ruminants, farmed game (camelids, ostriches, ruminants, and wild boars), aquaculture, lagomorphs and bees. The VIS contains all relevant data along the food chain. Austria also implements registration system for bovine animals called "Austrian Cattle Database" (AMA) The AMA and VIS are linked. Ear tags are the means of cattle identification.

It is mandatory for FBO to accompany movement document for the inter and intra region/community movement of live farm animals. As audited, the operators implemented traceability and identification of live animals and their movement requirements at the establishments as per regulatory requirements.

Conclusion

Austria has a well-established and harmonised identification system in place for bovine and swine movements as per Regulations (EC) No. 853/2004 and No. 625/2017.

3.2 Ante-mortem inspection

Austria fulfils ante-mortem inspection requirements as described in the national Meat Inspection Regulation (MIR) and Implementing Decrees 1/Version 9, 3/Version 3 and 4/Version 2 on ante-mortem inspection of ungulates and additional inspection. Additionally, Regulations (EC) No. 2017/625, No. 2019/624 and No. 2019/627 also govern the ante-mortem inspection of animals intended for slaughter. The FBO is responsible for monitoring of animals at arrival, and checking the veterinary health certificate, farmer's declaration (animal information document), and way bill.

After confirmation of identification, the operator provides all documents to the OV responsible for completing the ante-mortem inspection at the establishment. The OV completes the ante-mortem inspection of each animal (bovine and swine) within 24 hours of arrival at the slaughterhouse and less than 24 hours before slaughter. Ante-mortem inspection includes inspection of animal identification, animal welfare and health of animals. After completion of ante-mortem inspection, OV either approves or rejects the individual animal or lot for slaughter. The OV inspects all dead animals arriving during day and over night. The OAs under the supervision of OV may complete the ante-mortem inspection of animals.

The PVS provide supervisory services in the slaughterhouses and meat processing establishments and control ante- and post-mortem and regular/general hygiene inspections, and animal welfare at slaughter. The authorised veterinarians perform the ante- and post-mortem inspections and regular hygiene checks. The OAs are responsible for the examination for Trichinella in establishments. Through general hygiene inspections, the District Veterinary Officers supervise activities of the OVs present in establishments. PVS checks the approved establishments at least once a year according to a control plan, and verify whether the establishments comply with veterinary legislations (animal welfare and animal health), food legislation (hygiene and food safety) and export requirements.

Austria uses the Animal Slaughter and Meat Inspection Database and VIS to record and store ante- and post-mortem results/findings. During virtual audit, the CFIA verified records for the completion of ante-mortem inspection by the OVs at the bovine and swine slaughter establishments.

Conclusion

The OV completed the ante-mortem inspection of animals as per Regulation (EC) No. 2017/625, No. 2019/624 and No. 2019/627, and MIR.

3.3 Humane handling and animal welfare

Austria's Animal Protection Act and Animal Welfare at Slaughter Regulation supplement the Regulation (EC) No. 1099/2009 on the protection of animals at the time of killing. The Regulation (EC) No. 1099/2009 on the protection of animals at the time of slaughter (arrival, moving and handling of animals) partly regulates transport of animals related to slaughterhouse operations. The OV inspects animals for signs of compromised welfare and verifies animal welfare at slaughter via ante-mortem and stunning inspection and monitors bleeding at pre-determined frequencies as per regulations.

For religious/ritual slaughter in Austria, ritual slaughters without prior anesthesia are regulated in section 32 of the Animal Protection Act and Animal Welfare at Slaughter Regulation. Austria allows ritual slaughter only in a slaughterhouse that has been approved for this purpose. The authority only grants the authorization to carry out ritual slaughter if it comply with the applicable EU and national animal welfare regulations.

The CFIA verified the records of animal welfare program implementation, animal handling, stunning and bleeding procedures, and monitoring of these procedures at the slaughter establishments. Operator stunned and bled the non-ambulatory animals on site without being moved. The CA followed on incidents of animal welfare non-compliance detected during transportation, handling and slaughter of animals and verified FBO's corrective actions.

Conclusion

Austria implemented humane handling and animal welfare control program as per Regulations (EC) No. 1099/2009, No. 2017/625 and No. 853/2004, and national regulations.

4. Slaughter and post-mortem

In Austria, national legislations LMSVG, MIR and Implementing Decrees 1/Version 9, 3/Version 3 and 4/Version 2 on ante- and post-mortem inspection and additional inspection and EU regulations govern slaughtering of animals. As per Regulation (EC) No. 2019/624 article 9 and No. 2017/625 article 17, post-mortem inspections and auditing activities are essential to protect human health, and animal health and welfare. As per articles 7 of the Regulation (EC) No. 2019/624 and 18(2)(c) of the Regulation (EU) No. 2017/625, OAs under the supervision of OVs complete post-mortem inspection. The post-mortem inspection consists of an examination of carcasses, carcass parts, organs, tissues and lymph nodes, by means of observation, palpation, smell and incisions. At medium/small slaughter establishments, OA without the physical presence of OV completes the post-mortem at the establishment.

At bovine and swine slaughter establishments, the CFIA noted that operator did not implement zero tolerance for fecal contamination using a CCP. At bovine slaughter establishment, the operator did not include fecal and ingesta contamination in Critical Control Point (CCP) or Control Point (CP). At swine slaughter establishment, operator controlled faecal and ingesta contamination as post-mortem inspection control point but did not consistently document non-compliance and corrective actions completed in response to non-compliance.

Conclusion

Austria completed post-mortem inspection as per the Regulations (EC) No. 2017/625. However, the CFIA noticed that the operator did not include fecal and ingesta contamination in CCP or CP at bovine slaughter establishment.

Furthermore, the operator did not consistently document the non-compliance and corrective actions completed in response to the non-compliance detected during monitoring of faecal and ingesta contamination at swine slaughter establishment.

5. Processing controls

5.1 Antimicrobial controls

As required in the Regulations (EC) No. 2015/1474 and No. 101/2013, the establishments can use steam and antimicrobial aids such as steam vacuum or lactic acid to reduce microbiological surface contamination on bovine and swine carcasses. As audited, the operator used steam vacuum at the end of evisceration line at the bovine and swine slaughter establishments.

Conclusion

Austria implemented antimicrobial controls as per the EU regulatory requirements.

5.2 Chilling/freezing controls

The Regulation (EC) No. 853/2004 lays down chilling requirements for domestic ungulates and poultry. During cutting, boning, trimming, slicing, dicing, wrapping and packaging, the FBO ensures the maintenance of meat at not more than 3°C for offal, 7°C for ungulates meat by means of an ambient temperature of 12°C. The FBO can have an alternative system having an equivalent effect. However, meat may be boned and cut prior to reaching temperature mentioned above when the cutting room is on the same site as slaughter premises. The operator must transfer meat to cutting room either directly from the slaughter premises or after waiting period in a chilling room.

The audited establishment maintained chilling and freezing controls using a CCP. The competent authority verified the implementation of chilling controls at each audited slaughter establishment.

Conclusion

Austria implemented chilling and freezing controls as per Regulation (EC) No. 853/2004.

5.3 Water retention controls

Currently, there are no regulatory requirements related to retained water control program for bovine and swine meat and meat products in EU Member States. As audited, the FBO did not implement the retained water control program as per Canadian requirements at the bovine slaughter establishment. At swine slaughter establishment, the FBO implemented the retained water control program as per Canadian requirements, but the officials did not verify this requirement during annual verification. The FBOs are responsible for developing and implementing retained water control program for carcass, parts and offal as per the Canadian requirements as prescribed in the Canadian control programs: water retention in edible raw red meat products.

Conclusion

Currently there are no EU regulatory requirements for the implementation of retained water control program for bovine and swine meat and meat products. Therefore, the audited bovine slaughter establishments did not implement a water retention control program as per Canadian requirements. Additionally,the officials did not verify this requirement during annual verification at the swine slaughter establishment.

5.4 Allergen controls

Slaughter establishments and producers and processors of meat products in Austria must comply with the requirements of Regulation (EU) No. 1169/2011. There are 14 major allergens listed in annex II of this regulation. If the FBOs use allergens on-site, they must implement allergen control program. The list of allergens is similar to that of Canada, with the exception of pine nuts. annex II of this regulation does not include pine nuts.

The CFIA verified that the audited establishments in Austria developed and implemented the allergen control program in accordance with EU regulation. However, the operators of bovine and swine slaughter establishments did not develop and implement written allergen control program as they did not use allergens their establishments. Additionally, the meat processing establishment developed and implemented written allergen control program, but did not include all Canadian priority allergens in its program. The FBOs are responsible for developing and implementing written allergen control program at the bovine and swine slaughter and meat processing establishments as per the Canadian requirements as prescribed in the priority allergen including pine nuts.

Conclusion

Austria developed and implemented allergen control programs as required and in compliance with the requirements of the Regulation (EC) No. 1169/2011.

However, the meat processing establishments did not include all Canadian priority allergens in its written allergen control program.

5.5 Processing controls

Lethality treatments refer to the treatment of meat products to achieve a reduction in the viable pathogenic organisms. The Regulation (EC) No. 852/2004 annex II,chapter 11 on heat treatment describes the requirements that apply only to continuous use of traditional methods at any stages of production, processing or distribution of food. These requirements relate to any heat treatment process used to process an unprocessed product, and prevent the product from becoming contaminated during the process. Additional requirements are control of temperature, sealing and microbes as per international standards.

The Regulation (EC) No. 852/2004 also outlines FBO responsibility to develop and implement process control programs and performance requirements for fermented, cooked or smoked meat products. The operator must complete the quality control check internally via validation of the horizontal autoclave and externally by third party. As audited, for ready-to-eat (RTE) cooked (cured) products, the operator controlled the cooking temperature requirements by CCP6 at 74°C with no holding time against the requirement of 71.1°C for 10 seconds (no holding time). Additionally, the operator used E250 (sodium nitrite) at 100 to 150 parts per million (ppm) in accordance with the specified prerequisites from customers in cured meat products at the audited meat processing establishment. The operator validated the cooling process of the cooked products. For fermented meat products, the operator controlled the pH via CCP3 and achieved a pH value of <4.9 in 48 hours, and validated pH in accordance with category B products (pH<5.0).

The Regulation (EC) No. 1333/2008 describes the maximum level of added nitrites in the cured products. The operator used up to the maximum permitted level of 150 ppm of sodium nitrite in cured meat products at the audited meat processing establishment.

The CFIA virtually audited an establishment producing and exporting salami, pizza salami and pepperoni to Canada. The CFIA reviewed the controlling factors used for cured and fermented meat products being exported to Canada. The CFIA noticed that the operator did not control and monitor the cooling of heat treated products at meat processing establishment. The meat processing establishment intending to export heat treated meat products to Canada must meet the Canadian cooling control requirements as described in the Canadian preventive control recommendations for cooling heat processed meat products.

Additionally, the operator also did not monitor the degree/hours for each batch of fermentation at meat processing establishment. The establishment intending to export fermented meat products to Canada must meet the Canadian fermentation control requirements as described in the Canadian preventive control for manufacturing fermented meat products.

Conclusion

Austria implemented the lethality controls for the production of cured meat products as per the EU regulatory requirements.

However, the operator did not monitor the cooling of cooked meat products and degree/hours for each batch of fermented meat products for export to Canada.

6. Preventive control plans

The application of HACCP program and principles is a mandatory requirement for all establishments according to the Regulations (EC) No. 178/2002, No. 852/2004, No. 853/2004 and No. 854/2004. As required in the article 5 of Regulation (EC) No. 852/2004, it is essential for the operators (except primary producers) in each EU Member State to develop, implement and maintain effective HACCP system in their establishments.

Austria implemented HACCP and pre-requisite programs in the bovine and swine slaughter and meat processing establishments. At the audited slaughter and processing establishments, the Austrian competent authority audited the implementation of HACCP system at a defined frequency, and monitored the functionality of the HACCP system and prerequisite programs. However, the CFIA noted various deficiencies related to elements of HACCP system at bovine and swine slaughter establishments. These deficiencies included.

At bovine slaughter establishment, the CFIA noticed that FBO's pre-operational written program did not specify monitoring frequency, corrective actions and follow up. Additionally, the FBO's general food hygiene written program also did not specify the corrective actions and follow up to be completed in response to non-compliance. At swine slaughter establishment, the CFIA observed that the operator completed the monitoring of metal detection (CCP-2) at the beginning of shift and then every 2 to 3 hours, but did not specify this frequency in their written program. Furthermore, the operator neither define the verification frequency for metal detector nor included root cause analysis for the identified deficiencies in correction action procedures for metal detection.

Conclusion

The Austrian competent authority implemented the HACCP and prerequisite programs as per the EU regulatory requirements.

However, the CFIA noted deficiencies in the implementation of HACCP and prerequisite programs at the bovine and swine slaughter establishments.

7. Microbiological controls

The Regulation (EC) No. 2073/2005 on microbiological criteria for foodstuffs specifies the requirements for food safety and process hygiene microbiological sampling from meat and meat products. Additionally, under the regulation (EC) No. 882/2004, the competent authorities have to verify that feed and food should be safe and wholesome and that the criteria are met. The Regulation (EC) No 2019/627 lays down uniform practical arrangements for the performance of official controls on products of animal origin intended for human consumption.

The BMSGPK issues official sampling plan as part of national microbiological monitoring control program and verifies that the FBOs comply with the microbiological criteria and food safety levels defined in the EU and national legislations. The program is risk-based and includes data from previous years controls.

The FBOs shall ensure that foodstuffs comply with the relevant microbiological criteria set out in Regulation (EC) No. 2073/2005, annex I, and develop risk based sampling plans and establish appropriate sampling frequencies. The sampling frequencies shall be at least comparable to the ones as provided in annex I of this regulation. The FBOs establish the microbiological criteria in the context of their procedures based on HACCP principles and good hygiene practice. Additionally, operators manufacturing RTE foods conduct sampling and testing of the products, processing areas and equipment for Listeria monocytogenes (L. monocytogenes) as part of their sampling scheme. The competent authority shall verify FBOs' compliance with the applicable rules and criteria as prescribed in the EU regulations. The competent authority also conducts microbiological sampling and testing of products and environment.

At the bovine slaughter establishment, the operator implemented control measures and testing plan for Escherichia coli (E.coli) O157:H7 in raw beef products precursor materials. The establishment conducted microbiological sampling and testing of beef voluntarily 4 times a year for E.coli O157:H7.

At the meat processing establishment, the CFIA noted that the competent authority completed the annual verification of country specific export requirements, but did not verify the Canadian export requirements of Listeria sampling during annual verification. The operator of meat processing establishment specified frequency for Listeria sampling, but there was no documented analysis to determine quarterly frequency. The establishment needs to develop the Listeria sampling frequency based on risk analysis. The RTE meat products for exporting to Canada must meet Canadian requirements for the control of L. monocytogenes in RTE food as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods.

Conclusion

The Austrian competent authority developed the microbiological control program as per the Regulation (EC) No. 2073/2005 requirements. However, the official annual audit for the Canadian export requirements did not include the verification of sampling and testing of beef for E. coli O:157/H7 at the bovine slaughter establishment and Listeria sampling and testing of meat at meat processing establishment.

Furthermore, the operator of meat processing establishment did not document the analysis to establish the Listeria sampling frequency. The analysis of Salmonella sampling results was not completed as per 2073/2005 regulation at the bovine slaughter establishment.

8. Chemical residue controls

Austria implements National Residue Control Plan (NRCP) and report the results for the illegal use of substances, misuse of authorized veterinary medicines, and minimize residue recurrence in accordance with directive 96/23/EC and 96/22/EC. These directives provide measures to monitor certain substances and residues thereof in live animals and animal products. The Council directive 96/23/EC requires EU Member States to adopt and implement a NRCP for specific groups of residues.

Under EU regulations, the BMSGPK forecasts NRCP every year and submit to EU Commission for approval followed by submission of the results to European Food Safety Authority for publication. The number of samples and frequency depends on previous year national slaughter volume per species, compliance history and slaughterhouse participation in the quality assurance program. The NRCP include the species, categories, points of sampling, substances for testing, and test procedures as prescribed in the European Commission's legal provisions to ensure wholesomeness of meat products. The CA collect and ship samples to laboratories for analysis. For non-compliant results, the CA investigates non-compliance and takes necessary actions.

The indirect federal administration is responsible for the official chemical residue controls. The provincial and district CA carry out the official controls for NRCP. The provincial authorities draft and execute the details of sampling plans in cooperation with Division Data Collection and Risk Assessment.

As audited, the BMSGPK established and implemented a chemical residue sampling plan for bovine and swine as per council directive 96/23/EC annex IV. In regard to off-label policy, Austria implemented cascade rule as described in EU directive 2001/82/EC on the Community Code related to use of veterinary medicinal products. Additionally, Additionally, Austria also implemented Regulation (EU) No. 1881/2006 setting maximum levels for contaminants in foods, Regulation (EU) No. 2019/1871 for action for prohibited substances in food of animal origin, and Regulation (EU) No. 37/2010 for substances, classification and maximum residue limits in foods of animal origin.

Canada routinely monitors the imported meat products for chemical residues, and assess the testing results. The results must comply with Canadian maximum residue limits. The maximum residue limits for veterinary drug residues are established by Health Canada and described in the list of maximum residue limits for veterinary drugs in foods.

Conclusion

Austria developed and implemented NRCP for chemical residue controls as described in the Regulations (EC) No. 37/2010 and No. 1881/2006, and directives 96/23/EC, 96/22/EC, 2001/82/EC and 2019/2090/EC.

9. Closing meeting

The virtual closing meeting was held with representatives from BMSGPK and provincial and district authorities on March 23, 2022. The CFIA presented a summary of the preliminary findings in the closing meeting.

10. Conclusions

Following the review of action plans provided by competent authority, the CFIA determined that Austria continues to implement the bovine and swine meat inspection and meat processing systems determined equivalent to those of Canada. The audit report includes recommendations for Austria to address the deficiencies identified during the virtual audit.

11. Recommendations

The recommendations are linked to the specific conclusions made during this report.

CFIA recommendation 1

The CFIA recommends that all systemic findings noted in establishments be corrected and verified in a timely fashion

BMSGPK action plans/comments 1

BMSGPK provides a response to CFIA recommendations for the operator's correctives actions and BMSGPK verification of the findings in the establishments audited.

CFIA recommendation 2

The CFIA recommends that Austria must implement supervisory oversight control consistently in all establishments that produce and process meat and meat products intended for export to Canada as per the Austrian plan with a minimum control frequency of 20% every year.

BMSGPK action plans/comments 2

Supervisory oversight is yet fully and consistently implemented as to section 31(3) LMSVG together with Implementing Decree No.8. The proper conduct of Official Control activities by the official meat inspection bodies in terms of OVs is being verified as "Supervisory oversight" carried out by the Provincial Official Veterinarians according to the requirements of Implementing Decree 8, whereby 20% of the investigative OVs are subject to a supervisory control per Year. This means that in a period of 5 years, each meat inspection body according to section 31 (3) LMSVG is controlled at least once.

It thus appears that the above conclusion is due to a problem in communication or misinterpretation leading the auditors to the opinion that Supervisory Oversight of all meat inspection bodies is only carried out every 5 years.

CFIA recommendation 3

The CFIA recommends that the annual export verification of all establishments eligible to export meat and meat products to Canada must include verification of all Canadian requirements.

BMSGPK action plans/comments 3

All relevant Canadian Export requirements have been re-addressed and summarised on the KVG website accordingly. The Austrian Federal Office for Consumer Health (BAVG) being in charge for ongoing annual Export Controls in approved establishments according to section 51 (3) LMSVG will be verifying compliance with requirements as to export to Canada.

CFIA recommendation 4

The CFIA recommends that all bovine and swine slaughter establishments eligible to export meat and meat products to Canada implement control program to prevent the fecal and ingesta contamination of carcasses.

BMSGPK action plans/comments 4

All procedures established to meet compliance as to legal requirements, ensure Good Hygiene and Good Manufacturing Practices (PRPs) relevant at slaughter and post mortem processes are being subject to a review (in all establishments) in operation and on the level of the verification of the Food Safety Management System (FSMS) based on the HACCP principles. Preventive control programmes (including introduction and enhancement of written procedures and documentation) have been yet introduced in the audited establishments and will be disseminated amongst all establishments approved for export to Canada.

At bovine slaughterhouse, a procedure has been implemented based on a new control point (CP/operational prerequisite program (OPRP)) where 20 carcasses per day are being subject to a detailed visual observation procedure carried out by a member of the quality assurance (QA) department before the trimming focussing on small (pin size) and large dirt possibly present, including the presence of hair, hook grease and blood residues. The results are documented accordingly and further appropriate corrective actions taken upon detection as trimming of affected carcasses and/or parts thereof as well as training of the responsible operators and staff member/s in charge.

At swine slaughterhouse, the document "5.3 QMFB06_operative inspection production" has been adapted to include the area "Documentation faecal Contamination – CP3" based on 5 carcasses per shift the production manager has to check for faecal contamination. Faecal contamination is considered as non-compliance and affords a mandatory recording of the state and detail its cause/source as well as corrective actions subsequently taken. Only deviations are being recorded.

CFIA recommendation 5

The CFIA recommends that all Austrian establishments that are eligible to export meat and meat products to Canada have a written and validated retained water control program as per the Canadian requirements.

BMSGPK action plans/comments 5

Though post-evisceration procedures and mainly more specifically the chilling procedures applied in Austrian meat establishments rather differ from Canadian procedures. The CCA together with the provincial veterinary administrations and the BAVG are investigating the overall and specific individual situation in concerned Meat establishments as to the necessity for further provisions (to be published on the KVG) regarding "Control Programs in relation to water retention in edible raw red meat products". As a follow up to the past audit, the Canadian requirements as to water retention Control programs will be considered by each FBO approved for export to Canada and specific control procedures may be adopted depending on the individual situation in relation to established practices and procedures. In any case, each FBO, based on this individual assessment, will have to validate and implement a compliant procedure addressing the control of water retention or demonstrate to the satisfaction of the Competent Authority that no water retention occurs in its process.

At bovine slaughter establishment, the company does not have any carcass spray chilling systems or similar in the slaughtering and cooling (storage) area such as washing the carcasses after evisceration, spray chilling the carcasses, water or ice cooling of the carcasses or spraying the carcasses after cooling with or without an antimicrobial solution such as chlorine, lactic acid etc. Only at the position of spinal cord removal bone dust is removed from the surfaces cut off the spinal cord with a water spray. In addition at the vapor aspirator position, the skin opening incisions are treated with a commercially available and approved vapor aspirator.

Corrective measure with regard to the control of water retention (to be implemented and verified): A work instruction has been set up in which the new validated procedure for detecting undesired water intake is described: after evisceration on the slaughter/preparation line, the first measurement of the carcass weight is recorded in order to determine the "raw weight" of the carcasses. This is done on an extra lane with scales. 12 random carcasses are identified, marked and weighed over several groups of carcasses. The groups are distributed evenly over the daily production period (beginning, middle and end). The second weighing is done (following rinsing off the remains of bone on the back and after the steam extractor) after cooling. Post-organ removal weights are compared to post-refrigeration weights to determine retained water using a mathematical difference calculation (exit weight before refrigeration minus "green" weight) by a percentage Limit: 0.5%. A weight loss being expected during the chilling process, the described procedure will be applied once a year to re-validate the process together with "water application" and chilling procedures in place.

At the end of the slaughtering process, the carcasses are showered once with drinking water to remove blood and bone residues, after which they are chilled exclusively by air cooling without any further application of water or spray chilling. Based on a daily evaluation of the processes efficiency, inputs and outputs of carcasses to be chilled and those which passed the chilling process are weighed and the difference is being calculated. The general conclusion is that no increase in weight of the carcasses has been observed but on the contrary a loss of up to 3% of the input carcass weight.

CFIA recommendation 6

The CFIA recommends that the pine nuts be included in the allergen control program as per Canadian requirements at all establishments eligible to export meat and meat products to Canada.

BMSGPK action plans/comments 6

In Austria, the EU not listed allergens will have to be re-addressed in the hazard analysis of FBOs FSMS and included in the written allergen control program to fully satisfy Canadian requirements. Based on the code of practice adopted by the International Codex Alimentarius Commission, annex I and II of the Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs have been amended in 2021 to improve food allergen management for food business operators, including recommendations on the mitigation of food allergens by a harmonised approach in the food chain based on general hygiene requirements.

Considering the adoption of the mentioned global standard (CXC 80-2020), expectations of consumers and trade partners specific requirements were legally introduced as good hygiene practices to prevent or limit the presence of substances causing allergies or intolerances, referred to in annex II to Regulation (EU) No 1169/2011, in equipment, conveyances and/or containers used for the harvesting, transport or storage of foodstuffs along the entire food chain incl. slaughter, meat processing and storage establishments. Since contamination of foodstuffs might take place both at the level of primary production and at stages beyond that production, both annexes I and II to Regulation (EC) No 852/2004 were amended.

Other than Canadian requirements annex II of Regulation (EU) N. 1169/2011 on the provision of food information to consumers does not consider a category being "tree nuts" though most of those listed under point 8 are "tree nuts", however this does not include "pine nuts". Due to this lack of harmonisation between EU and Canadian requirements not all are allergens were listed in the control program of audited establishments (see also comments in annex I) and will thus be re-addressed in the hazard analysis of FBOs FSMS and included in the written allergen control program to fully satisfy Canadian requirements.

Corrective measure implemented and verified. The FBO allergen control program has been reviewed and adapted to the Canadian standards regarding "Preventive controls for food allergens, gluten and added sulphites" accordingly.

In the HACCP concept of the FBO (document QMSP04 – HACCP concept) the hazard analysis has been reviewed subsequently including "tree nuts" such as "pine nuts" as a hazard "allergens", considering the source of a possible presence being the introduction of pine nuts by staff members. Further to that locker checks and staff training are carried out as a preventive measures.

CFIA recommendation 7

The CFIA recommends that meat processing establishment eligible to export meat products to Canada must control and monitor the cooling of heat treated products and record the degree/hours for each batch of fermentation.

BMSGPK action plans/comments 7

The entire cooling chain and mainly the cooling procedure with impact on heat treated meat products will be fully reviewed and adapted to meet the Canadian requirements as to "preventive control recommendations for cooling heat processed meat products" including recommendations as laid down in the Food Safety and Inspection Service (FSIS) Stabilization Guideline for Meat and Poultry Products (revised appendix B) – and necessary written procedures will be implemented accordingly.

Likewise, based on FBOs re-evaluation as to established procedures and preventive control measures with regard to lethality treatments of processed meat products and RTE foods, establishments intending to export fermented meat products to Canada are urged to adapt their written control programmes where applicable in order to meet the Canadian fermentation control requirements as described in the Canadian preventive control for manufacturing fermented meat products.

For monitoring of degree/hour for each batch of fermentation, the maximum room temperature in the fermentation chamber is +26°C, what results in a degree-hours limit of 665. According to table 1 of the CFIA "Preventive control recommendations for manufacturing fermented and dried meat products", at a room temperature of 26°C, a maximum of 63.8 hours would be allowed to achieve the critical pH value of 5.3.

According to company HACCP specifications, reaching a pH value of < 4.9 within a maximum of 48 hours has been defined as critical limit/s for fermentation. Thus, at worst, this would result in a product of 26-15.6 = 10.4 obtaining a degree-hours limit of (10.4 x 48h = 499.2) what is considerably lower than the limits specified by CFIA (< 665).

The degree/hours having been considered as difficult to measure on an ongoing basis (what is thus not an ideal criterion for monitoring) the FBO limits for the CCP (fermentation) having been set to critical limits for the pH reached after the end of the process (time/pH combination). The fermentation process being concluded within 48h with a limit set to ≤ 4.9 at max 26°C temperature that is ongoingly monitored as a PRP at this specific step. This validated procedure hence aims to reach a combination of degree/hours at lower than 665, as to Scientific Reference used by the FBO. An ongoing monitoring of degree/hours has thus not be considered as necessary in the FBO's HACCP plan. The process is being re-validated once a year.

For preventive measure, the currently implemented approach as described above will entirely be reviewed and re-validated during the next verification of the entire HACCP system.

For control cooling of heat treated products, the entire cooling chain and mainly the cooling procedure with impact on heat treated meat products will be fully reviewed and adapted to meet the Canadian requirements as to "Preventive control recommendations for cooling heat processed meat products" including recommendations as laid down in the FSIS Stabilization Guideline for Meat and Poultry Products (revised appendix B) – and necessary procedures will be implemented accordingly.

CFIA recommendation 8

The CFIA recommends that the competent authority implements and monitors the HACCP and pre-requisite programs effectively to correct and prevent deficiencies identified in this report.

BMSGPK action plans/comments 8

Austrian establishments approved for export to Canada are urged to fully review their entire FSMS and its proper implementation including PRPs, HACCP based procedures as well as additional control or preventive programmes and establish written procedures and documentation as well as ongoing record keeping where necessary to ensure food safety by providing full satisfaction to both EU and Canadian requirements.

Article 4 of Regulation (EC) No. 852/2004 requires FBOs to "comply with the general hygiene requirements laid down in its annex II and any specific requirements provided for in Regulation (EC) No 853/2004" and does not explicitly urge FBOs to implement according written documentation and records to be kept on an ongoing basis. However, article 5 urges "Food business operators to put in place, implement and maintain a permanent procedure or procedures based on the HACCP". This requires FBOs to establish according (written) documentation and records as to implemented HACCP (based) procedures, including non-compliances identified by the system's proper functioning as well as corrective actions and a root cause analysis regarding an adequate compliance management.

"HACCP based", according to the above described approach, hence doesn't force the FBO to have a full HACCP or a fully documented Food Safety Management System (being equivalent to all components necessary as to the Canadian provisions for "Processing Controls and Preventive Control plans") but allows a certain flexibility also for large establishments at least within the EU market. Certainly, they may not fully satisfy Canadian requirements that are mandatorily to be met by any establishment approved for export to Canada.

Austrian establishments approved for export to Canada are urged to fully review their entire FSMS (according to HACCP principle 6) and its proper implementation including PRPs, HACCP based procedures as well as additional control or preventive programmes and establish written procedures and documentation as well as ongoing record keeping where necessary to the full satisfaction of Canadian requirements.

Corrective measure at processing establishment to be implemented and verified. Upon a re-evaluation and carrying out another risk analysis as recommended, the current sampling plan is being reviewed and implemented.

Although the applied procedure is stricter than provided for by law in Regulation (EC) 2073/2005, it is indeed not described and laid down in written in the establishment's documentation. Subsequently a work instruction has now been developed in which this procedure (which deviates from the regulation but is stricter in itself) is properly described.

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