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Final report of an audit of the European Union Member States Meat Inspection Systems governing the production of bovine, swine and poultry meat and meat products - February 13 to 22, 2019 and June 24 to July 11, 2019

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Abbreviations and special terms used in the report

Aw
Water activity
CA
Competent Authority
CCA
Central Competent Authority
CCP
Critical Control Point
CFIA
Canadian Food Inspection Agency
DG SANTE
European Commission Directorate General for Health and Food Safety
EC
European Commission
EFSA
European Food Safety Authority
EU
European Union
FBO
Food Business Operator
HACCP
Hazard Analysis Critical Control Points
MRL
Maximum Residue Limit
NRMP
National Residue Control Plan
RTC
Ready-to-Cook
RTE
Ready-to-Eat
NRTE
Non-Ready-to-Eat
SFCR
Safe Food for Canadians Regulation
SRM
Specified Risk Materials
STEC
Shiga toxin-producing Escherichia coli

Executive summary

This report describes the outcome of an on-site audit of the meat inspection systems governing the production of bovine, swine and poultry meat and meat products in 9 European Union (EU) Member States conducted in 2 phases. The Canadian Food Inspection Agency (CFIA) audited meat inspection systems of Spain, Italy, Czech Republic and Lithuania from February 13 to 22, 2019 and those of Cyprus, Bulgaria, Greece, France and Germany from June 24 to July 11, 2019.

The main goal of the audit was to verify if EU Member States are implementing meat inspection systems equivalent to that of Canada, and if these systems are capable of producing safe, unadulterated, and properly labelled meat products for export to Canada. The results of this audit informed CFIA's decision whether to recognize the EU Member States meat inspection systems as 1 entity based on compliance with the Canadian and EU regulatory requirements.

The audit scope included visits to the central competent authority (CCA) headquarter of the 9 EU Member States and slaughter and processing establishments located in different regions of EU Member States.

The audit covered activities within the following subject areas:

Following the analysis of audit findings, the CFIA determined that the meat inspection systems of Germany, France, Spain, Italy, Lithuania and Czech Republic are performing in an adequate manner and meet Canadian requirements. However, Cyprus, Bulgaria and Greece are not implementing bovine, swine and poultry meat inspection systems in a manner determined to be equivalent to that of Canada. In these countries, the CFIA noted deficiencies related to the government oversight, humane handling and ante-mortem controls, slaughter and post-mortem controls, preventive control plans, microbiological and chemical residue controls. These findings demonstrated that meat inspection systems were not consistently implemented in all audited Member States as per the EU and Canadian regulatory requirements. Resultantly, the CFIA is unable to approve the EU Member States meat inspection systems as 1 entity.

The CFIA will continue to work with Directorate-General for Health and Food Safety (DG SANTE) under the auspices of the CETA Sanitary and Phytosanitary Joint Management Committee and consider requests for recognition of individual EU Member States meat inspection systems for export of meat and meat products to Canada.

1. Introduction

1.1 Background

The DG SANTE has been requesting to the CFIA to recognize the EU Member States meat inspection systems as 1 entity and allow market access to bovine, swine and poultry meat and meat products from all EU Member States. In the fall of 2018, the CFIA and DG SANTE had a positive discussion on ways to move forward on Canada's recognition of the EU Member States' Meat Inspection Systems. The CFIA agreed to conduct an additional audit in 2 phases to inform its decision to recognize EU Member States meat inspection systems as 1 entity. Resultantly, the CFIA audited 9 member states; Spain, Italy, Lithuania and Czech Republic (first phase February 2019) and Germany, France, Cyprus, Bulgaria and Greece (second phase June – July 2019). The aim of these audits was to verify the implementation of bovine, swine and poultry meat inspection systems and determine the equivalency of EU meat inspection systems to that of Canada.

Prior to conducting on-site audit, both the CFIA and DG SANTE agreed that positive outcome in all audited EU Member States would result in an overall recognition of the EU Member States meat inspection systems. However, in case of any negative outcome in any of the audited Member States, the CFIA won't recognize the EU Member States meat inspection system as a single entity. The CFIA would recognize the individual Member States with a positive audit outcome to export meat and meat products to Canada.

1.2 Audit objective, scope, and methodology

The audit verified activities within the following subject areas in the 9 EU Member States:

The CFIA auditors reviewed administrative functions at the Central Competent Authority (CCA) headquarters of the 9 EU Member States and conducted on-site audit of the 49 animal slaughter, meat processing and cold storage establishments as presented in the Table 1. The auditors evaluated regulatory framework, oversight framework, enforcement framework, training framework, export controls and import controls. The representatives from the EU Member States' CCA accompanied the auditors throughout the audit.

Table 1: Summary of audit scope
Competent authority/establishment Number of sites visited - Spain Number of sites visited - Italy Number of sites visited - France Number of sites visited - Germany Number of sites visited - Czech Republic Number of sites visited - Lithuania Number of sites visited - Cyprus Number of sites visited - Bulgaria Number of sites visited - Greece
Opening meeting and closing meetings 1 1 1 1 1 1 1 1 1
Meat processing 2 2 5 3 2 2 1 0 1
Meat storage 0 0 0 1 1 0 0 0 0
Bovine slaughter 1 1 1 1 1 1 1 1 1
Swine slaughter 2 1 1 1 1 1 1 1 1
Poultry slaughter 1 1 1 1 1 2 1 1 1

1.3 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 EU regulations determined as equivalent as part of the Comprehensive and Economic Trade Agreement (CETA) between the European Community and the Government of Canada on sanitary measures to protect public and animal health in respect of trade in live animals and animal products as amended from time to time and as part of bilateral negotiations.

2. Competent authority and oversight

2.1 Regulatory framework

All EU Member States should implement European Parliament and the Council adopted regulations. The key relevant EU regulations include the following:

In addition to the EU regulations, there is legal binding for EU Member States to implement national laws and decrees in the territory of EU countries. The regulations and decisions of the EU institutions, European Parliament, EU Council and European Commission (EC) are legally binding for all EU Member States.

Conclusion

The competent authorities of audited EU Member States have regulatory framework to ensure the development, planning and implementation of the meat inspection systems and official controls of the food chain.

2.2 Oversight framework

Each of the audited EU Member State has the CCA with overall responsibilities in relation to food and feed safety, and animal health and welfare. The CCA and its subordinates show an adequate capability to implement, coordinates resources and activities with a clear chain of command, from the central to regional/territorial/local level for implementing all regulatory activities. Under Regulation (EC) No. 854/2004, each EU Member State ensures that there are sufficient officials to carry out official controls. In EU Member States, there is no specific number of official veterinarians which are to be present at establishments (slaughter/processing and storage). The risk assessment, volume of meat production, type of product, non-compliance history, and operator's willingness to take corrective actions determine the number of official staff present at slaughter lines in a given slaughter, processing or storage establishments. The applicable authority decides on the number of official staff to meet all requirements resulting from legislation and the frequency of checks laid down in the Multi-annual Control Plan. As stipulated in Annex I Section III Chapter II of this Regulation (EC) No. 854/2004, the competent authority must ensure that at least 1 official veterinarian is present at slaughterhouse throughout both ante-mortem and post mortem inspections.

In Cyprus and France, the official veterinarian was not physically present during ante-mortem or post-mortem inspections at the poultry slaughter establishment as stipulated in Regulation (EC) No. 854/2004.

In 5 Member States, the CFIA noted findings related to government oversight, HACCP, building and equipment maintenance, sanitation, ante- and post-mortem inspection at bovine, swine and poultry slaughter and meat processing establishments. The number and volume of findings reflected that government oversight wasn't adequate to prevent occurrence and/or reoccurrence of non-compliances related to regulatory requirements.

In Greece, the CCA provided supervisory oversight every year for 2 of 13 regions, thereby not covering all animal slaughter establishments on a yearly basis. Government supervisory oversight was not in place for animal slaughter and meat processing establishments in Cyprus. In Lithuania and Czech Republic, the official veterinarian assessed the work completed by technician but didn't record it.

Conclusion

The government oversight was not fully adequate in 5 audited EU Member States (Bulgaria, Cyprus, Greece, Lithuania and Czech Republic) to ensure compliance with Regulations (EC) No. 852/2004 and (EC) No. 854/2004 and (EC) No. 882/2004 requirements for official controls of the food chain. Furthermore, the official veterinarian was not physically present at the poultry slaughter establishment in France and Cyprus during ante-mortem or post-mortem inspections.

2.3 Training framework

The European Commission organises workshops within the program "Better Training for Safer Food" (BTSF). 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. The CCA of EU Member States is responsible for the organisation of continuous training for staff performing the official control at slaughter and meat processing establishments.

The CFIA noted that various training courses were organised for veterinarians and official auxiliaries responsible to perform the official veterinary control at slaughter and processing establishments in the audited EU Member States. Some examples of training included the veterinary supervision within the meat production chain, ante-mortem and post-mortem examination of animals, sanitary assessment of slaughter products and veterinary requirements for the export of animal origin products.

Conclusion

As stipulated in Regulation (EC) No. 882/2004, the CCA of EU Member States possesses 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 Regulation (EC) No. 178/2002 controls the export of meat product. The export or re-export of food and feed from the EU to third country shall meet the food law requirements, unless otherwise requested by the importing country or established by the laws, regulations, standards, codes of practice and other legal and procedures as may be in force in the importing country.

The registered establishments must meet the specific sanitary requirements and health agreements of importing countries or blocks of countries. In audited EU Member States, the OV completes the export verification and certification. In 8 EU Member States, for each shipment, an OV checks the condition of trailer and export product and associated documents, and signs the certificate after confirming that the products meet the importing country requirements. In France, the certification procedures for the export of meat and meat products didn't include visual on-site verification of each load of meat product by the certifying officer or his agent.

At present, food business operators (FBO) in some of the audited EU Member States aren't eligible to export meat and meat products to Canada. Should this situation change, mechanisms will be put in place to verify the compliance with Canadian import requirements, which are over and above the EU.

Conclusion

Adequate export controls and certification procedures are implemented, as required by Regulation (EC) No. 178/2002, to ensure that only eligible meat and meat products from approved establishments are exported to third countries. However, in France, the certification procedures for the export of meat and meat products didn't include visual on-site verification of each load of meat product by the certifying officer or his agent.

2.5 Import controls

As stipulated in the Regulation (EC) No. 882/2004, the Commission shall be responsible for requesting third countries intending to export goods to provide the accurate and up-to-date information on the general organization and management of sanitary control systems. All EU Member States have border inspection posts for the entry of live animals, animal products and other veterinary goods imported from third countries. All live animals and products of animal origin as defined in the Commission decision 2007/275/EC must undergo specific veterinary import controls at an approved and correctly designated border inspection post prior to entry or transit through the territory of EU Member States.

The Commission decision 2009/821/EC describes the latest list of border inspection posts for each EU Member States and is available on the European Commission's website. The EU Member States' responsible authority should receive prior notification of the arrival of the products at the border inspection post. The officials enter the data in the Trade Control and Expert System (TRACES), which contains all the information regarding the movement of the consignment, therefore making it traceable to or from destination.

All consignments must undergo documentary, identity and physical checks before being considered cleared for animal and public health purposes. All consignments must carry a correctly completed common veterinary entry document (CVED). The competent authority completes sampling as part of the physical checks and according to the national monitoring plan or randomly. The aim of sampling is to check compliance with the health requirements laid down in the accompanying veterinary certificate. The accredited laboratories do the testing of samples. If there is a suspicion for samples to be positive, the competent authority withholds the consignment and isolates at the border inspection post until receiving of results. In accordance with animal and public health legislations, consignments that don't follow the above procedures will not enter EU Member States.

Conclusion

The audited EU Member States have well established regulatory import controls in place for live animals or animal products imported or transitioned from any third country as stipulated in the Regulation (EC) No. 882/2004 and the Commission decision 2007/275/EC. The CFIA didn't assessed any border inspection post during this audit.

2.6 Enforcement framework

The EU Member States are responsible for the enforcement of agri-food chain legislation as stipulated in the Regulation (EC) No. 882/2004. The government authorities set sectorial guidelines and document procedures on the use of legal powers and common operating procedures describing enforcement measures in most sectors of food safety. In audited EU Member States, the officials identify the non-compliances and infringements at slaughter, processing and storage establishments during the continuous or planned periodic official veterinary controls.

The range of actions varies according to severity of the deficiency or infringement, which includes the request for corrective actions, setting deadlines, fines, suspension of export certification and activities, and suspension of approval or withdrawal of approval. Additional actions in the event of regulatory non-compliance included destroying of unsafe animal products and safe disposal, restrict processing or placing of animal products on market, and declare emergency veterinary measures.

The enforcement procedures in all audited Member States generally followed as per the programs and policies. At swine slaughter establishment in Greece, the CCA wasn't able to provide the criteria used to grant extension for corrective actions in regard to non-compliance identified during official controls.

Conclusion

Legal authority, policies and procedures are in place in the audited EU Member States to ensure enforcement actions in response to non-compliances related to food safety as per Regulation (EC) No. 882/2004 and national regulations.

At a swine slaughter establishment in Greece, the CCA was not able to provide the criteria used to grant extension for corrective actions about non-compliance identified during official controls.

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

3.1 Traceability and animal identification

As per the Regulation (EC) No. 853/2004, the food business operators must, as appropriate, request, receive, check and act upon food chain information with respect to all animals sent or intended to be sent to the slaughter establishment. The EU Member States are responsible for the day to day enforcement through their national legislation and control activities. Additionally, the Article 18 of 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.

As audited, traceability and identification of the live animals requirements at the establishments were implemented in accordance with the regulatory requirements.

Conclusion

The EU Member States have a well-established and harmonised identification of live animals, traceability and systems in place for bovine, swine and poultry movements as per Regulation (EC) No. 853/2004.

3.2 Ante-mortem inspection

The Regulation (EC) No. 854/2004 governs the ante-mortem inspection of animals slaughtered for meat production. This regulation lays down specific rules for the organisation of official controls on products of animal origin intended for human consumption. The official veterinarian can completes ante-mortem inspection of all animals at the farm and issues the health certificate. Additionally, the producer responsible for raising the animals fills the flock information, and includes usage of all drugs with withdrawal periods.

The CFIA verified the implementation of ante-mortem procedures at slaughter establishments and noted deficiencies as mentioned below:

Conclusion

Ante-mortem inspection was not consistently completed as per Regulation (EC) No. 854/2004 in 1 or more audited EU Member States.

3.3 Humane handling and animal welfare

Each EU Member State has the competent authority to regulate the transportation and handling of animals for slaughter. As per Regulation (EC) No. 854/2004 Annex I Section II chapter IV, the official veterinarian is to verify that the operator immediately takes necessary corrective measures and prevents recurrence of any animal welfare concerns during slaughter. Furthermore, the Regulation (EC) No. 1099/2009 on the protection of animals at the time of killing (arrival, moving, and handling of animals) partly regulates the transport of animals for slaughter.

The CFIA auditors noted deficiencies related to humane handling and animal welfare in Bulgaria and Greece. At a bovine slaughter establishment in Bulgaria, there was no written program for ritual slaughter. The OV verified the ritual slaughter without any performance criteria to ensure humane treatment of animals during ritual slaughter. Additionally, the training record of employees performing ritual slaughter was not available. At swine slaughter establishment, the CFIA auditors noted that the operator without any previous experience with usage of specific new stunner provided training to the person responsible for stunning. This led to ineffective stunning of swine. At poultry slaughter establishment, the crates used to transport ducks were broken in 1 of the trailers, thereby potentially compromising animal welfare.

At bovine slaughter establishment in Greece, the OV verified the effectiveness of stunning and bleeding, but did not record it. At swine slaughter establishment, the CFIA auditors noted ineffective stunning of pigs with signs of corneal reflex, neck and head movements, attempt to stand, and squeaking. Additionally, the alley leading to stunner had broken iron panel with sharp protruding edges. These protruding edges may potentially cause injury to animals during walking. In poultry, some crates/cages used to transport birds were broken and open at the top, thereby resulting birds coming out of crates while on trailer.

Conclusion

Humane handling and animal welfare controls were implemented as per Regulations (EC) No. 1099/2009 and No. 854/2004 in most of the audited EU Member States. However, the CFIA noted deficiencies related to stunning and bleeding controls in Bulgaria and Greece.

4. Slaughter and post-mortem controls

The Regulation (EC) No. 854/2004 of the European Parliament and of the Council of 29 April 2004 lays down specific rules for the organisation of official controls on post-mortem inspection and products of animal origin intended for human consumption. Additionally, as per Regulation (EC) No. 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. The CFIA noted deficiencies related to the implementation of post-mortem controls as outlined below:

4.1 Bovine

In Cyprus, the official veterinarian completed the post-mortem inspection of carcass and red offal (heart, lungs, liver, tongue and trachea) but not of green offal (stomach and intestine). The official veterinarian checked carcass for fecal, ingesta and milk contamination during post-mortem but did not record it. In Bulgaria, the OV did not perform adequate PM inspection as the carcasses were approved without removing the complete spinal cord and faecal contamination. The FBO neither removed Specified Risk Materials (SRM) completely nor had a written program for the removal of SRM from the bovine.

In Greece, the OV didn't perform complete post-mortem inspection of carcasses. The OV completed inspection of the carcass while standing at the viscera station, therefore OV was not in a position to complete the full inspection of carcass. Furthermore, OV didn't inspect kidneys during post-mortem inspection. The OV approved the carcass with remnant of spinal cord. The handling of carcasses during dressing was not adequate to prevent the cross contamination. The forelegs of carcasses were touching the boots of employee during dressing. The SRM written procedures didn't include process of equipment usage for removal of SRM. The operator didn't define if knives being used were dedicated for SRM or must be disinfected after removal of SRM. Furthermore, the operator's SRM procedure didn't reflect the current EU requirements.

In Germany, the competent authority implemented the SRM segregation and control procedures as per the Regulation (EC) No. 2015/1162. However, it didn't meet the Canadian conditions for importation of meat products from the European Union.

4.2 Swine

In Cyprus, the official veterinarian completed post-mortem inspection of carcass only, but checked viscera if noticed any problems with carcass. Neither operator nor officials recorded the monitoring of zero tolerance for fecal/ingesta/milk contamination. The OV didn't complete post-mortem inspection fully as OV inspected only front, not the back of carcasses. In Bulgaria, the OV completed post-mortem inspection after trimming of the carcasses. This activity potentially removed the pathology and defects prior to post-mortem inspection.

In Czech Republic and Lithuania, the CFIA noticed that post-mortem inspection was completed using visual and palpation techniques, while incision was completed as per veterinary technician's discretion. No written guidance was available for official veterinarian or technician regarding usage of incision for post-mortem inspection.

In Lithuania, the CFIA noticed that the operator completed post-mortem inspection of carcass at the end of line after trimming and cleaning. This resulted in removal of pathology before completion of post-mortem inspection.

4.3 Poultry

In Cyprus, the official veterinarian didn't complete post-mortem inspection on all birds slaughtered during each shift. The official veterinarian or veterinary inspector was present at poultry slaughter establishment only for limited time period (45 minutes to 1 hour during slaughter). Out of 1 hour, the official veterinarian or veterinary inspector remained present for 10 minutes at slaughter floor. Additionally, the official veterinarian or veterinary inspector didn't complete post-mortem inspection records fully as the number of birds checked for post-mortem inspection was missing from post-mortem record. Both official veterinarian and inspector were not aware about the number of birds checked for post-mortem inspection. The Pre-requisite Program Control (PRPC) was used to manage zero tolerance for fecal/ingesta contamination, however, there was no documentation for monitoring and verification.

In Bulgaria, the OV didn't complete post-mortem inspection of 100% of carcasses and associated viscera in the absence of a written and validated post-mortem examination program including detection of defects in the carcass and its parts, identification of carcass and its parts as approved or rejected, and monitoring and verification of post-mortem inspection effectiveness.

In Greece, the company's employee completed the post-mortem inspection without a written and validated post-mortem examination program including detection of defects in the carcass and its parts, identification of carcass and its parts as approved or rejected, and monitoring and verification of post-mortem inspection effectiveness. The OV did not conduct correlation and verification tests ensuring completion of post-mortem inspection by the operator as per requirements. Furthermore, there was no written training program for the employees responsible for conducting post-mortem inspection and rejecting the carcasses and viscera. There was only 1 OV who inspected the carcasses and viscera on the line. However, the OV was not present at the post-mortem inspection station at all times as he or she had to conduct ante-mortem inspection at the same time.

In Germany, partially dressed whole carcasses containing oil gland and kidneys were not labelled as stipulated in Canadian guideline dressing procedures and preparation of edible parts and the SFCR 145 (1)(b) and SFCR 286 (d).

In France, the trained slaughterhouse staff under the supervision of official auxiliaries completed the post-mortem inspection of ducks. However, the CFIA auditors noted that OV was not present continuously at the establishment as required by the Regulation (EC) No. 854/2004 Annex I, Section III, Chapter III.

In Czech Republic, it was observed that technicians conducting the post-mortem inspection were trimming and throwing the carcasses at the same time. Due to these simultaneous activities by the same person, there was a potential that some carcasses and viscera might have missed the post-mortem inspection. Additionally, the veterinary technicians didn't inspect the cavity of each poultry carcass. The inspection of poultry cavity was based on the discretion of veterinary technicians performing post-mortem inspection. No written guidance was available for official veterinarian or technician to decide when to inspect poultry cavity during post-mortem inspection.

In Lithuania, it was observed that OV conducting the post-mortem inspection were trimming and throwing the carcasses at the same time. Due to these simultaneous activities by the same person, there was a potential that some carcasses and viscera might have missed the post-mortem inspection. Additionally, the inspection of poultry cavity was based on the discretion of OV performing post-mortem inspection. No written guidance was available for official veterinarian to decide when to inspect poultry cavity during post-mortem inspection.

Conclusion

The animal slaughter and post-mortem inspection were not consistently implemented in 1 or more audited Member States as per the Regulations (EC) No. 853/2004 and No. 854/2004 and Canadian requirements.

5. Processing controls

5.1 Antimicrobial controls

As stipulated in the Regulations (EC) No. 2015/1474 and No. 101/2013, the establishments can use steam or antimicrobial aids such as lactic acid and various chemicals to reduce microbiological surface contamination on bovine and pork carcasses. As audited, the EU Member States used antimicrobials as per the regulations. The auditors didn't identify any issues.

Conclusion

The audited EU Member States implemented antimicrobial controls as per EU regulatory requirements.

5.2 Chilling/freezing controls

The Regulation (EC) No. 853/2004 lays down chilling requirements applicable to domestic ungulates and poultry in EU Member States. The CFIA auditors reviewed and verified the implementation of chilling and freezing controls at the animal slaughter and meat processing establishments. In Bulgaria, the monitoring of chilling of carcasses at bovine slaughter establishment was not effective as the recorded temperature of carcass was higher (5.5°C) than the CCP limit of 0 to 2°C when CFIA asked to check the temperature during the audit. Additionally, the operator at the swine slaughter establishment didn't sign off the monitoring record for CCP-2b (chiller temperature for meat storage) for the month of June.

At a swine slaughter establishment in Cyprus, the operator controlled temperature of cold storage room as CCP 2 and monitored twice per day, but didn't take corrective action when temperature rose above the critical limit for instance 7°C. At poultry slaughter establishment, the operator maintained the record of chilling PRP1, but didn't sign off the record for May 31, 2019. Additionally, the operator took corrective actions related to chilling PRP1, but didn't record it.

In Czech Republic, monitoring of chilling of carcasses at poultry and swine slaughter establishments was not adequate as the CCP for chilling didn't meet critical limits as the temperatures were more than 8°C and 7.5°C respectively. At bovine slaughter establishment, the operator didn't complete monitoring of CCP for chilling temperature as per the written procedures. At bovine and swine slaughter establishment in Lithuania, the operators didn't complete monitoring of chilling controls as per the HACCP plan.

In Spain, it was observed in the audited pork slaughter establishment that the operator monitored temperature of the rooms during operation and storage, but didn't measure the temperature of the product either during production or before shipment.

Conclusion

1 or more audited EU Member States didn't implement chilling and freezing controls consistently as per the HACCP plan.

5.3 Water retention controls

In EU Member States, the Regulation (EC) No. 543/2008 lays down detailed rules concerning the marketing standards for poultry meat. The article 16 of this regulation stipulates an obligation for operators to carry out regular checks on water absorption by chicken carcasses during chilling/freezing. Currently, there are no regulatory requirements related to retained water control program for duck, bovine and swine meat and meat products in EU Member States. However, development and implementation of retained water control program is a Canadian requirement as prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

As audited, the operators implemented the retained water control program in all audited EU Member States as per EU requirements. The Canadian requirements which are over and above the European requirements must be implemented as a condition for export at establishments eligible to export to Canada.

Conclusion

All audited EU Member States implemented the retained water control program as per the Regulation (EC) No. 543/2008. The Canadian requirements, which are over and above the European requirements, will need to be implemented consistently at establishments eligible to export to Canada.

5.4 Allergen control

In regard to allergens, operators of slaughter and processing establishments in EU Member States must comply with the requirements of Regulation (EU) No. 1169/2011. There are 14 major allergens listed in annex II of this regulation. The food business operator need to declare the presence of any of these allergens through labelling. These allergens are recognized across EU Member States 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.

The CFIA auditors verified and observed that the audited establishments of the EU Member States developed and implemented the allergen control program in accordance with the EU regulation. The operator included pine nuts in the written allergen control program at the establishments eligible to export to Canada.

Conclusion

The EU Member States developed and implemented allergen control programs in compliance with the requirements of Regulation (EC) No. 1169/2011.

5.5 Ready-to-eat and ready-to-cook meat products controls

Lethality treatments refer to the treatment delivered to a meat product to achieve a reduction in the viable pathogenic organisms. In Regulation (EC) No. 2073/2004, the ready-to-eat (RTE) foods means food intended by the producer or the manufacturer for direct human consumption without the need for cooking or other processing to eliminate or reduce microorganisms to an acceptable level. Additionally, the Regulation (EC) No. 852/2004 outlines the operator's responsibility to develop and implement process control programs and performance requirements for RTE and canned products.

The CFIA audited the establishments that processed both RTE and non RTE meat products. The auditors noted that the operators didn't monitor adequately the process controls (pH, water activity (Aw) and degree hour) for the production of fermented (without starter culture) and dry cured meat products in Spain, France and Italy.

Conclusion

The audited EU Member States implemented lethality controls for the production of meat products as per the EU regulatory requirements. However, the process controls (pH, Aw and degree hour) were not adequately monitored for the production of fermented (without starter culture) and dry cured meat products in Spain, France and Italy.

6. Preventive control plans (PCP)

The application of HACCP program and principles is a mandatory requirement for all establishments according to the Regulation (EC) No. 178/2002, No. 852/2004, No. 853/2004 and No. 854/2004. As stipulated in the article 5 of Regulation (EC) No. 852/2004, it is essential for the operators (except primary producer) in each EU Member State to develop, implement and maintain effective HACCP system in their establishments for the production and processing of safe and wholesome meat and meat products for human consumption.

The CFIA noted deficiencies related to the implementation of various components of HACCP and prerequisite controls in the audited animal slaughter and meat processing establishments in 1 or more audited EU Member States:

Conclusion

The CFIA noted deficiencies in the implementation of HACCP and pre-requisite programs as per the EU regulatory requirements in 1 or more audited Member States.

7. Microbiological controls

The commission 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. As stipulated in 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 European Food Safety Authority (EFSA) monitors and analyses information and data on biological hazards, chemical contaminants, food consumption and emerging risks. The EU Member States has to follow the recommended number of microbiological sampling and send results to the EFSA for publication. The operators are responsible for sampling and must meet the food safety criteria for the food category produced in the establishment. The annex I of the Regulation (EC) No. 2073/2004 include sampling frequency and micro-organisms targeted for meat and products thereof as carcasses, RTE food, minced meat, meat preparation and baby food products.

The CFIA visited animal slaughter and RTE and non RTE meat products processing establishments, and reviewed the officials and operators' microbiological sampling plan. The CFIA noted the following deficiencies:

The RTE meat products intended for export to Canada must meet the Canadian requirements for the control of Listeria monocytogenes in RTE food as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods and the Canadian operational guideline: product inspection and sampling of meat and poultry products.

The precursor materials used in the preparation of finished raw ground beef product (FRGBP) intended for export to Canada must meet the Canadian requirements for the preventive controls for E. coli O157/NM in raw beef products.

Conclusion

EU Member States developed microbiological control program as per the Regulation (EC) No. 2073/2005. However, deficiencies were noted in the implementation of the sampling plans in Cyprus, Greece, Spain, Italy and France.

8. Chemical residue controls

The EU Member States must implement an official National Residue Monitoring Plan (NRMP) 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 on 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 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 regulation (EC) No. 37/2010 establishes the maximum residue limit (MRL) for each substance at the EU level by the relevant species and products or tissues on pharmacologically active substances and their classification regarding maximum residue limits in foodstuffs of animal origin.

Each EU Member State prepares and implements an annual plan for the NRMP. The NRMP 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 the meat products. The officials collect and ship residue samples to the laboratories for analysis. In the case of non-compliant testing result, the competent authority performs investigation and takes necessary measures.

The CFIA reviewed and analyzed the EU Member States' NRMP for 2017 and 2018 including sampling and methods of analysis. The review indicated that the NRCP sampling in Cyprus was not statistically relevant to capture non-compliance should it happened. In Greece, the officials collected only 30% of samples for chemical residue testing in 2018 at the bovine slaughter establishment, while officials did not perform chemical residue sampling in 2017, 2018 or 2019 at swine slaughter establishment. Furthermore, the officials collected less than 25% samples for chemical residue testing in 2018 in the region of poultry establishment, while officials didn't perform any chemical residue sampling in 2018 at meat products processing establishment.

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 (MRLs) for veterinary drugs in foods.

Conclusion

EU Member States developed NRMP for chemical residue controls as per the directive 96/23/EC and 96/22/EC on measures to monitor certain substances and residues thereof in live animals and animal products. However, deficiencies were noted in the implementation of the sampling plan in Greece.

9. Closing meeting

The closing meeting was held in each audited EU Member State with the representatives from central and territorial government inspection personnel. At these meetings, the CFIA lead auditors presented a summary of the preliminary audit findings.

10. Overall conclusions

Following the analysis of audit findings, the CFIA determined that the meat inspection systems of Germany, France, Spain, Italy, Lithuania and Czech Republic are performing in an adequate manner and meet the Canadian requirements. However, Cyprus, Bulgaria and Greece are not implementing bovine, swine and poultry meat inspection systems in a manner determined to be equivalent to that of Canada. Deficiencies related to the government oversight, humane handling and ante-mortem controls, slaughter and post-mortem controls, preventive control plans, microbiological and chemical residue controls were noted in these countries. These findings demonstrated that meat inspection systems were not consistently implemented in all audited Member States as per the EU and Canadian regulatory requirements. Resultantly, the CFIA is unable to approve the EU Member States meat inspection systems as 1 entity.

The CFIA will continue to work with DG SANTE under the auspices of the CETA Sanitary and Phytosanitary Joint Management Committee and consider requests for recognition of individual EU Member States meat inspection systems for export of meat and meat products to Canada.

11. Audit recommendations

11.1 Audit recommendations (Italy)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during the audit be corrected and verified in a timely fashion.

Ministry of Health actions plan/comment 1

The establishment specific findings have been corrected and verified by the local competent authority according to the regular inspection procedure.

The Italian Ministry of Health provided the documents related to the establishments corrective actions and the letters official verification.

CFIA recommendation 2

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated retained water retention control program as per the Canadian requirements prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

Ministry of Health actions plan/comment 2

The Italian Ministry of Health have created a specific working group in cooperation with the regional competent authorities most involved on Canada issue, in order to set and promulgate a Ministerial Circular with specific measures able to cover the gap identified for the Italian establishment's water retention control program for Canada export. The ministerial circular is based on the Canadian requirements.

July 3th, 2020:

the Italian Ministry of Health provide to CFIA:

CFIA recommendation 3

The CFIA recommends that adequate controls are implemented for the production of fermented (without an acid starter culture) and dry cured meat products.

Ministry of Health actions plan/comment 3

The Italian Ministry of Health provides a table with the follow-up operators correctives actions and official verification performed by the local competent authority regarding the controls implemented in the production of fermented and dry cured meat.

July 3th, 2020

the Italian Ministry of Health provide to CFIA:

CFIA recommendation 4

The CFIA recommends that the hazard analysis and critical control point (HACCP) and pre-requisite programs are implemented and monitored effectively to correct and prevent all deficiencies noted in section 6 of this report.

Ministry of Health actions plan/comment 4

The Italian Ministry of Health provides a table with the follow-up operators correctives actions and official verification performed by the local competent authority regarding the HACCP and pre-requisites deficiencies' observed during the CFIA audit.

CFIA recommendation 5

The CFIA recommends that: RTE meat products must meet the Canadian requirements for the control of Listeria monocytogenes as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods and the Canadian operational guideline: product inspection and sampling of meat and poultry products.

Ministry of Health actions plan/comment 5

The Italian Ministry of Health in cooperation with the Italian National Reference Lab for Listeria monocytogenes (Instituto Zooprofilattico Abruzzo e Molise) developed a specific guideline for the Operators and the competent authorities useful to cover the gap existing in the control of Listeria monocytogenes for ready to eat meat products destined to Canada market. The guidelines have been shared also within the European Commission. The implementation of the additional measures described in the above-mentioned guideline will be assured in Italy promulgating a specific Ministerial Circular according to which Italian establishment authorized to export to Canada will control their process production in relation to the Listeria monocytogenes hazard.

July 3th, 2020

The Italian Ministry of Health provide to CFIA:

11.2 Audit recommendations (Spain)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during the audit be corrected and verified in a timely fashion.

Ministry of Agriculture, Fisheries and Food and Environment (MAPA)/ Ministry of Health, Consumption and Social Welfare (MSCBS) action plans/comments 1

The MAPA and MSCBS provided a document detailing the actions taken by the establishments for any of the specific findings. All the corrective actions have been successfully implemented and have been verified by the official services.

The MAPA and MSCBS provide the authorization procedure for export to Canada that was fully reviewed after the CFIA audit. This procedure includes official instructions to assure the implementation of correctives actions about the audit findings in all the establishments exporting meat and meat products to Canada.

CFIA recommendation 2

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated retained water control program prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

Ministry of Agriculture, Fisheries and Food and Environment (MAPA)/ Ministry of Health, Consumption and Social Welfare (MSCBS) action plans/comments 2

The MAPA provides the authorization procedure for export to Canada that was fully reviewed after the CFIA audit. This procedure includes the obligation for the operators that export to Canada of controlling the retained water in carcasses and carcass parts according to the provided Canadian regulations.

CFIA recommendation 3

The CFIA recommends that adequate controls are implemented for the production of fermented (without a starter culture) and dry cured meat products.

Ministry of Agriculture, Fisheries and Food and Environment (MAPA)/ Ministry of Health, Consumption and Social Welfare (MSCBS) action plans/comments 3

The MAPA provides the authorization procedure for export to Canada that was fully reviewed after the CFIA audit. This procedure includes the obligation to implement a validated HACCP plan and to be audited by the official control authorities. Risk categorisation of RTE products must be present in the operator's HACCP system including the measurement of physical-chemical parameters (water activity (Aw) and pH) for the control of Listeria monocytogenes.

Only RTE products can only be exported to Canada when they contain preservatives in accordance with Canadian regulations.

CFIA recommendation 4

The CFIA recommends that HACCP and pre-requisite programs are implemented and monitored effectively to correct and prevent condensation on the walls, ceilings and equipment in establishments.

Ministry of Agriculture, Fisheries and Food and Environment (MAPA)/ Ministry of Health, Consumption and Social Welfare (MSCBS) action plans/comments 4

The MAPA provides the authorization procedure for export to Canada that was fully reviewed after the CFIA audit. This procedure included the obligation for the operator to implement a Standard Hygiene Control Program (PNCH) in accordance with the July 22th, 2019 MSCBS official guidelines document available on MSCBS website that included the pre-operational and operational controls to prevent the contamination of the meat products and monitoring activities, corrective actions and recording of the presence of condensation on the higher structures and equipment as required in the Regulation (EC) No. 852/2004.

CFIA recommendation 5

The CFIA recommends that the RTE meat products must meet the Canadian requirements as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods and the Canadian operational guideline: product inspection and sampling of meat and poultry products.

Ministry of Agriculture, Fisheries and Food and Environment (MAPA)/ Ministry of Health, Consumption and Social Welfare (MSCBS) action plans/comments 5

The MAPA and provide the authorization procedure for export to Canada that was fully reviewed after the CFIA audit. This procedure includes the operator's obligation to comply with the Canadian policy on Listeria monocytogenes in RTE meat products. Risk categorisation, sampling frequencies of the meat products and surfaces are included in the Annex II of the procedure.

A new official sampling procedure has been implemented and it will be applicable to all the authorized establishments exporting to Canada. This new procedure implies the official sampling of RTE product, FCS and NFCS once a year. The results of the sampling will be sent by the regional authorities to the Ministry of Health for each establishment exporting to Canada RTE products. Additionally, this sampling procedure includes a check list that should be fulfilled by the regional official services to ensure the control procedure of Listeria monocytogenes developed by the establishment is in accordance with Canadian regulation.

CFIA recommendation 6

Ministry of Agriculture, Fisheries and Food and Environment (MAPA)/ Ministry of Health, Consumption and Social Welfare (MSCBS) action plans/comments 6

The MAPA provides to CFIA the additional information requested by email regarding the residues sampling plan.

February 13th, 2020: the MAPA and the MSCBS provide the authorization procedure for export to Canada that was fully reviewed after the CFIA audit. The procedure includes the 2019 informative note that give the obligation for the operators to comply with the Canadian regulations on residues of veterinary drugs in meat and meat products and the instructions to implement in case of non-compliances.

11.3 Audit recommendations (Lithuania)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during audit be corrected and verified in a timely fashion.

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 1

According to the Order of the SFVS Director, No. B1 -59 of 28 January 2015, which approves the rules for the conduct of the operators inspections, the SFVS, following the CFIA audit and any breaches of legislation found during the audit, has instructed all audited companies to prepare corrective action plans of non-compliances and, within 14 days, to coordinate them with the territorial SFVS unit.

In the corrective action plans of non-compliances, FBOs indicated the breaches of legislation that were identified during the CFIA audit as well as measures required to eliminate those breaches and the timeframe for their implementation which would not exceed 56 days. By the end of the deadlines for rectifying non-compliances that have been coordinated with territorial units of the SFVS, all operators informed the territorial SFVS units by email about the rectification of non-compliances and a proof submitted the documents (modified procedures) and the photos.

From 1 until 20 of August 2019, the SFVS performed a physical control (verification of non-compliances in all audited operators by the CFIA audit. Repeated inspections revealed that FBOs have taken appropriate measures to eliminate the identified non-compliances and have complied with the deadlines set out in the corrective action plan of non-compliances.

The SFVS confirms that all non- compliances identified during the CFIA audit have been eliminated.

CFIA recommendation 2

The CFIA recommends to further enhance the government oversight to ensure compliance with regulatory requirements for official controls of food chain.

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 2

In order to strengthen the official controls of FBOs exporting to Canada and implementation of this recommendation, the SFVS:

Has updated the following Quality System work Program: KT-6-9-D1 "procedure for the conformity assessment and certification of production of animal food operators exporting animal food to third countries" and KT-2-1-D3 "division of food business operators into risk groups" with reviewed risk assessment of operators and enhanced the SFVS oversight".

Provided the training on "official control of animal food operators approved for export of manufactured products to Canada, specific requirements for import and control of animal products in the legislation of Canada" for the territorial SFVS inspectors.

August 20, update: Additional information was provided for this recommendation.

CFIA recommendation 3

The CFIA recommends implementing procedures in place to prevent the mixing of birds from different flocks received or unloaded at the same time at poultry slaughterhouse.

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 3

The SFVS has initiated a review of Quality System Work Programs: KT-2-3-D1 "Guidelines for the assessment of the suitability for human consumption of meat and other slaughter products in the animal slaughterhouses" and KT-2-1-4 "control of food or feed traceability", where is the enhanced control of the bird separation due to the possible risk to ensure that such animals are not mixed. The birds are separated by individual flocks making a blank space in the slaughter lines. The slaughterhouses, accordingly described in HACCP procedures, separate the slaughter flocks by assigning a separate number to each slaughter flock, comprising the establishment name and the number of poultry house.

The SFVS has initiated an obligation for the companies intended to export food products to Canada to replace/supplement their HACCP procedures. Poultry slaughter establishments have developed the procedures (rules) for the separation of different flocks. In accordance with the rules described in the procedures, the employees of the establishments responsible for receiving and uploading the birds have been trained. The SFVS confirms that the operators have taken appropriate measures to eliminate the identified non-compliances.

CFIA recommendation 4

The CFIA recommends implementing ante-mortem inspection program at poultry establishments to ensure that:

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 4

In the implementation of this recommendation, the SFVs has initiated a review of the Quality System Work Programs: KT-2-3-1-D1 "guidelines for the assessment of the suitability for human consumption of meat and other slaughter products in the animal slaughterhouses" and also obliged the operators, intending to export food products to Canada, to replace/supplement their HACCP procedures.

The appointed official veterinarian, carrying out the permanent supervision of poultry slaughterhouses (responsible for ante-mortem inspection) in the veterinary certificate (referring to its form in Regulation (EC) No. 854/2004, Chapter X, Part A), the identity of the animals and checks whether there is the compliance with animal health and welfare rules. In the case of non-compliance with the legislation, the official veterinarian indicates the date of inspection on the veterinary certificates and the signature as well as the stamps, certifying the verification and relevance of the data. The signature, the stamp and the date of the official veterinarian on the veterinary certificate shall constitute the authorisation to slaughter a specific batch of poultry, as specified in the certificate. The official veterinarian records the slaughter inspection data in the following logbooks "Permanent surveillance of the official veterinarian at the slaughterhouse" and "Report on the results of ante- and post-mortem inspection of animals".

The certificate signed by the official veterinarian is passed on to another official veterinarian, performing the permanent supervision (responsible for post-mortem inspection). Poultry slaughter establishments have added the provision to their poultry acceptance procedures that the slaughter of a particular poultry batch may only begin after the veterinary certificate (confirming the results of ante-mortem inspection) is signed and received by the official veterinarian, performing the permanent supervision in the poultry slaughterhouse.

CFIA recommendation 5

The CFIA recommends that stunning effectiveness check performed by official veterinarian at poultry establishments is documented.

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 5

The SFVs has initiated a review of the quality system work programs: KT-2-3-1-D1 "guidelines for the assessment of the suitability for human consumption of meat and other slaughter products in the animal slaughterhouses" which instructs the official veterinarian to properly assess the stunning of birds and describes the signs of consciousness. The corrective actions are taken immediately if any problems occur and the birds are not receiving the effective stunning. The stunning efficiency control data is recorded in the daily maintenance logbook.

CFIA recommendation 6

The CFIA recommends that:

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 6

The SFVs has supplemented the quality system work programs: KT-2-3-1-D1 "guidelines for the assessment of the suitability for human consumption of meat and other slaughter products in the animal slaughterhouses" including the registration (in the ante-mortem inspection logbook) of accepted cattle with the BSE risk status and has provided to carry out the measures for assigning certain tissues of cattle (controlled or undetermined BSE risk category) to specified risk materials and their removal.

The slaughterhouses have also supplemented their HACCP procedures for establishing the BSE risk management of cattle, either at time of their acceptance, by separating cattle of the controlled or undetermined BSE risk category, slaughtering them individually or from cattle with a negligible BSE risk. The SFVS has conducted the slaughterhouse inspection on the completeness and practical implementation of the procedures during the control of non-compliances to be eliminated.

The SFVS has provided the training on the risk control of BSE for SFVS inspectors and veterinarians carrying out the permanent supervision of establishments.

The SFVS has updated the Quality System Work Programs: KT-2-3-1-D1 "Requirements applied to the slaughterhouses for the removal of SRMs" which states that all bovine animals irrespective of the BSE risk, should have their front shot hole in head covered with the impermeable plug. The control is the responsibility of the official veterinarian who carries out the permanent supervision (post-mortem inspection).

The SFVs has revised KT-2-3-1-D1 and indicated that ovine and caprine and swine carcasses and their related parts, in particular the thorax and abdominal cavity must be inspected immediately after the slaughter and the organs of thoracic and abdominal cavities removed before any tissue damage has occurred.

The SFVs has described the procedure for testing pig carcasses in the Quality System Work Instructions Programs: KT-2-3-1-D1, which clearly states in which cases and what additional incisions are to be made. In accordance with the training plan, practical pre-slaughter and post-mortem inspection training is provided each year to state inspectors and veterinarian carrying out the permanent supervision of establishments.

The SFVs has updated the KT-2-3-1-D1 to ensure the implementation of the recommendations by clarifying the procedures for certain cases of post-mortem inspection of birds:

Pigs and cattle slaughterhouses have supplemented their HACCP program by providing the documentation of root cause analysis, when the zero faecal tolerance is exceeded (CCP).

The SFVs has updated KT-2-3-1-D1 by specifying the post-mortem requirements: bovine, ovine, caprine, and swine carcasses and their related parts, in particular the thorax and abdominal cavity must be inspected immediately after the slaughter and the organs of thoracic and abdominal cavities removed before any tissue damage has occurred.

The SFVS confirms that the appropriate measures are taken to eliminate the identified non-compliances.

The SFVS has supplemented KT-2-3-1-D1 by specifying the post-mortem requirements: the official veterinarian is responsible for the control of traceability as well as correlation between the individual parts of the carcass and the internal organs of the same animals; also for the check of the company compliance with HACCP requirements by verifying whether the control of the establishment is included into the HACCP system and ensures traceability and correlation between the individual parts of the carcass and the internal organs of the same animal. Veterinarian monitors the line synchronisation at least once per shift. The control data is recorded in the daily maintenance logbook.

The SFVS confirms that the appropriate measures are taken to eliminate the identified non-compliances.

CFIA recommendation 7

The CFIA recommends that:

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 7

The SFVS has obliged the operators intending to export food products to Canada to replace/supplement their HACCP procedures.

A written verification procedure for poultry slaughter establishments has been developed with CCP for chilling being included in their HACCP plans.

The SFVS at operators during physical control (verification) of the correction of non-compliances estimated that operators supplemented their HACCP plans and provided that routine control process and the control records of the carcasses are additionally checked, the procedure for the control of carcass chilling have been changed, the results are recorded, the training for the employee carrying out the carcass freezing control has been provided.

Actions taken by the cattle slaughter establishment:

Actions plan by the pig slaughter establishment:

August 13, 2020 update: Additional information was provided for this recommendation.

CFIA recommendation 8

The CFIA recommends that all establishments interested in exporting meat and meat products to Canada have a written and validated retained water control program as per Canadian requirements as prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 8

The poultry slaughterhouses perform the absorbed water control in accordance with Regulation (EC) No. 854/2004, Annex IX. The HACCP changes additionally have been made according to the Canadian requirements.

During the control of rectifying non-compliances, SFVS has verified and confirmed that the establishments meet these requirements.

August 13, 2020 update: Additional information was provided for this recommendation.

CFIA recommendation 9

The CFIA recommends that:

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 9

Taking into account the recommendations of the CFIA, all companies intending to export to Canada have been instructed by the SFVS to supplement their allergen management procedures and to include the pine nuts into the arranged list of allergens, according to the provisions in Annex II, Regulation (EC) No. 1169/2011of the European Parliament and the Council and to provide for preventive and control measures concerning their access to meat and meat products.

During the control of rectifying deficiencies, the SFVS has verified and confirmed that the companies have supplemented allergens management procedures, identifying the risk of allergens in food, cross-contamination, and the risk management measures. The companies have prepared the list of used allergens (including pine nuts), staff hygiene requirements, different production times with different allergens, the labelling of intermediates at all stages of production, a separate allergens weighing inventory, at least once a year, the training of staff on allergen, laboratory control of allergens, their labelling as well as control of allergens storage. On March 06 2019, the SFVS The SFVS changed the Quality System Work Instruction KT-2-3-1-D1 "assessment and audit of the HACCP System for economic operators" by including the provision to review, in the context of allergens management procedure assessment, the list of allergens in companies according to the requirements and individual companies and to check out the control and risk management measures and effectiveness.

The official veterinarian, who carries out the continuous supervision of the company, during the process of production, checks how the company actually manages the risk of allergens.

CFIA recommendation 10

The CFIA recommends that the exporting country must meet the Canadian requirements for the control of Listeria monocytogenes in RTE food products as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods and the Canadian operational guideline: product inspection and sampling of meat and poultry products.

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 10

FBOs have conducted the challenge test study for the RTE food to determine the potential growth of Listeria monocytogenes and assessed the process of the lethality treatment for Listeria monocytogenes in RTE foods. The self-control laboratory testing plan for FBOs has been also reviewed and Listeria monocytogenes testing for RTE and environmental samples corrected.

August 13, 2020 update: Additional information was provided for this recommendation.

CFIA recommendation 11

The CFIA recommends that HACCP and pre-requisite programs are implemented and monitored effectively to correct and prevent following deficiencies:

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 11

According to the CFIA recommendations, during the rectification control of non-compliances, carried out by the SFVS, the inspections of mandatory surveillance programmes in all companies were repeatedly revised; the implementation of planned corrective and preventive measures and the effectiveness of their implementation evaluated; HACCP plans, CCP summary tables, monitoring procedures reviewed. The changes have been made to the management of CCPs, record forms in the establishments: the logbook on the evaluation of the stunning efficiency of birds with a column of "Birds status evaluation after stunning" supplemented; the carcass chilling control logbook modified, additionally including the reasons for non-compliance with the specified frequency of carcass control; the cause analysis of carcass contamination added to CCPs and the corrective measures provided; the adjustment to the CCP summary plan made, indicating how and with what frequency the chilling process will be controlled. The persons responsible for the records have been appointed and trained.

Good Hygiene Practices (GHPs) were reviewed and evaluated in all companies: the cause of oil contamination of carcasses has been identified and eliminated; the procedure for washing the carcass refrigerator has been changed; the staff has been provided with training on packaging of raw materials, on placing caresses, meat an meat products in containers refrigerators in such a way as to prevent the contamination; the drying times of refrigerators were changed; the additional training of employees has been conducted.

The equipment maintenance procedures have been supplemented with the requirement to check the rust formation in risk areas and the condition of the surfaces in contact with food at least once a month. The repair work of equipment and premises has been performed only after identifying potential food risks, not according to the planned repair schedule.

All companies have re-evaluated potential food risks and anticipated management tool. In all companies, the procedures for controlling the implementation of GHPs have been adjusted to include corrective measures, cases of production stoppage and immediate corrective actions.

CFIA recommendation 12

The CFIA recommends that:

State Food and Veterinary Services of Lithuania (SFVS) actions plans/comments 12

The National Food and Veterinary Risk Assessment Institute has implemented and have been accredited for the Standard Working Procedure (SWP) 5.4.4M.17:2017 "Detection of E. coli 0157:H7 in foodstuffs applying in a real time polymerase chain reaction (PCR) method and using the BAX system Q7" which is an equivalent to Only Health Canada approved method MFLP-76.

The FBOs intending to export finished raw ground beef products (FRGBP) to Canada have amended their self-control laboratory testing plans with E. coli 0157:H7 testing for the precursor materials used for the preparation of FRGBP.

According to the official control sampling plan of the SFVS, exporting establishments are already controlled for the STEC testing parameter in raw beef.

The evaluation form for microbiological results was made by operators for the purpose to evaluate the compliance with the requirements specified in Regulation No. 2073/2073.

11.4 Audit recommendations (Czech Republic)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during audit be corrected and verified in a timely fashion.

State Veterinary Administration (SVA) actions plans/comments 1

The relevant Regional Veterinary Administrations (RVAs) carried out targeted inspections focusing on correction of the identified deficiencies, with records made and deadlines set for the correction of the deficiencies. Where appropriate, staff training was provided. (RVA for South Bohemia – 12 March 2019 and 13 March 2019; RVA for Vysočina – 29 March 2019; RVA for Central Bohemia – 12 February 2019, 25 February 2019, 4 March 2019).

The RVA for Central Bohemia carried out an audit after the plant's reconstruction on 30 July 2019. A representative of the Central Veterinary Administration (CVA) took part in the audit and performed the so-called "witness audit".

June, 2020: during the "witness audit", the audit procedure conducted by the RVA for Central Bohemia was checked by the CVA, including deadlines set for the correction of the deficiencies. Most of the deficiencies were corrected by the time of the audit.

The RVA for Central Bohemia subsequently carried out targeted inspections and found that all the remaining deficiencies had been remedied.

The RVAs supervising the other establishments where deficiencies were identified, also verified in subsequent inspections that the deficiencies were corrected within set deadlines.

CFIA recommendation 2

The CFIA recommends to further enhance the government oversight to ensure compliance with regulatory requirements for official controls of food chain.

State Veterinary Administration (SVA) actions plans/comments 2

The information was presented at meetings of the CVA with RVA Directors for veterinary hygiene held on 19 March and 23 May 2019.

The CVA has drawn up "operating and organizational rules" for the veterinary hygiene units at slaughterhouse. These rules comprise 2 documents (a separate document for the slaughter of ungulates and another 1 for the slaughter of poultry). The documents lay down the obligation to assess the work of an official veterinary assistant / technician and to record such assessments (see Annexes 1 and 2).

The SVA revised its procedures and all identified deficiencies must be recorded in the inspection reports or inspection sheets, always including an indication of the corrective action to be taken and deadline for the correction. The veterinary inspector must subsequently check that the deficiencies have been corrected (See Annex 3 – a document that has been presented at the aforementioned meetings).

CFIA recommendation 3

The CFIA recommends implementing ante-mortem inspection program to ensure that all ante-mortem inspection records are signed by the veterinarian at the swine slaughter establishments.

State Veterinary Administration (SVA) actions plans/comments 3

The information was presented at meetings of the CVA with RVA Directors for Veterinary Hygiene held on 19 March and 23 May 2019. It was emphasised that all relevant documents must be duly signed.

CFIA recommendation 4

The CFIA recommends implementing a program to ensure that all animals are humanely stunned at poultry slaughter establishments interested to export poultry meat products to Canada.

State Veterinary Administration (SVA) actions plans/comments 4

The information was presented at meetings of the CVA with RVA Directors for veterinary hygiene held on 19 March and 23 May 2019.

The relevant RVA carried out an inspection on 13 March 2019 which confirmed that the deficiency was corrected.

CFIA recommendation 5

The CFIA recommends that:

State Veterinary Administration (SVA) actions plans/comments 5

The information was presented at a meeting of the CVA with RVA Directors for Veterinary Hygiene held on 19 March 2019. It was emphasised that the HACCP based systems must contain clearly specified conditions for the SRM removal, even when in practise SRM is removed in accordance with legislation. It was also emphasised that the HACCP based systems must include a procedure ensuring that animals, which are to be examined for BSE, are slaughtered as the last ones.

On 29 March 2019, the RVA for the Vysočina region carried out an inspection in the plant concerned in order to check that the operator in his HACCP system indicated that also in animals younger than 12 months SRM is removed as in bovine animals older than 12 months. And further that the age of animals is calculated on the basis of the date of birth as indicated in the cattle passport.

The CVA has drawn up "operating and organizational rules" for the veterinary hygiene units at slaughterhouse. These rules comprise 2 documents (a separate document for the slaughter of ungulates and another 1 for the slaughter of poultry). The documents specify in which cases to incise lymph nodes and organs and when a more thorough examination and decision on meat is to take place. The document also specifies when and with what frequency the cavity of poultry carcasses must be examined. The document also lays down the obligation to record the correlation test for carcasses and viscera (Annexes 1 and 2).

The relevant RVA developed a system of work organisation in the poultry slaughterhouse so as to ensure that veterinary technicians examine all poultry carcasses. Where pathological changes are detected, the carcass is removed from the line, assessed as unfit for human consumption and incisions are made across the breast muscle in order to destroy it. The carcass is then put in a container for animal by-products. The container for animal by-products is placed immediately next to the inspection site.

Note: at the time of the audit, the technicians were not trimming the poultry carcasses. They were only making incisions in breast muscles in order to destroy the carcasses deemed unfit for human consumption.

June 2020: the RVA for the Vysočina region carried out an inspection in order to check the HACCP system, especially the part concerning the segregation between cattle from countries having controlled and negligible risk of BSE. The operator has introduced this segregation into its HACCP system.

CFIA recommendation 6

The CFIA recommends that:

State Veterinary Administration (SVA) actions plans/comments 6

The information was presented at meetings of the CVA with RVA Directors for Veterinary Hygiene held on 19 March and 23 May 2019.

It was emphasised that the cold chain and temperature limits set in the CCPs must be adhered to, the CCP monitoring frequency and recording must be carried out thoroughly, and the CCP must be validated according to prescribed HACCP procedures.

The relevant RVAs carried out inspections focusing on the correction of the identified deficiencies. The deficiencies concerned have been corrected.

CFIA recommendation 7

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated retained water control program as per the Canadian requirements prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

State Veterinary Administration (SVA) actions plans/comments 7

This goes beyond the requirements of the EU legislation. In the Czech Republic, requirements of EU legislation were audited. In case of an interest to export to Canada, the retained water control program will be validated also for beef and pig slaughter.

CFIA recommendation 8

The CFIA recommends that the pine nuts must be included in the allergen control program at establishments interested to export red and poultry meat and meat products to Canada.

State Veterinary Administration (SVA) actions plans/comments 8

This goes beyond the requirements of the EU legislation. In the Czech Republic, requirements of EU legislation were audited. In case of an interest to export to Canada, pine nuts will be included in the allergen control program.

CFIA recommendation 9

The CFIA recommends that HACCP and pre-requisite programs are implemented and monitored effectively to correct and prevent following deficiencies:

State Veterinary Administration (SVA) actions plans/comments 9

The information was presented at meetings of the CVA with RVA Directors for Veterinary Hygiene held on 19 March and 23 May 2019.

It was stressed that all RVAs need to focus inspections on the HACCP based systems.

In the visited establishments, targeted inspections took place focusing on correction of the identified deficiencies, with records made and deadlines set for the correction of the deficiencies. Where appropriate, staff training was provided. (RVA for South Bohemia – 12 March 2019 and 13 March 2019; RVA for Vysočina – 29 March 2019; RVA for Central Bohemia – 12 February 2019, 25 February 2019, 4 March 2019).

The RVA for Central Bohemia carried out an audit after the plant's reconstruction on 30 July 2019. A representative of the Central Veterinary Administration (CVA) took part in the audit and performed the so-called "witness audit".

June 2020: during the "witness audit", the audit procedure conducted by the RVA for Central Bohemia was checked by the CVA, including deadlines set for the correction of the deficiencies. Most of the deficiencies were corrected by the time of the witness audit.

The RVA for Central Bohemia subsequently carried out targeted inspections and found that all the remaining deficiencies had been remedied.

The RVAs supervising the other establishments where deficiencies were identified, also verified in subsequent inspections that the deficiencies were corrected within set deadlines.

CFIA recommendation 10

The CFIA recommends that:

State Veterinary Administration (SVA) actions plans/comments 10

This goes beyond the requirements of the EU legislation. In the Czech Republic, requirements of EU legislation were audited. In case of an interest to export to Canada, microbial aspects will be monitored in accordance with the requirements of Canadian legislation.

11.5 Audit recommendations (Greece)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during audit be corrected and verified in a timely fashion.

Ministry of Rural Development and Food (MRDF) actions plans/comments 1

All findings listed in appendix 1 have been addressed. The verification will be done by the central competent authority by the end of the first semester of the year 2020. The final reports will be sent to the CFIA.

CFIA recommendation 2

The CFIA recommends to further enhance the government oversight to ensure compliance with regulatory requirements for official controls of food chain.

Ministry of Rural Development and Food (MRDF) actions plans/comments 2

  1. The MRDF in cooperation with the Supreme Council for civil personnel selection (ASEP) has launched the procedure for recruitment of personnel. Thirty of the veterinarians for the General Directorate of Veterinary Services (7 out of 30 for the Directorate of veterinary Public Health).
  2. All establishments intended to export to Canada will be included in the annual supervision program (by the CCA)

CFIA recommendation 3

The CFIA recommends that the enforcement framework is implemented to ensure that extension for completing corrective actions in response to non-compliance is granted based on the specific criteria.

Ministry of Rural Development and Food (MRDF) actions plans/comments 3

The possible extension for completing corrective actions in response to non-compliances is treated on a case by case approach. The swine slaughterhouse was not fully operational during the audit due to financial problems (bankruptcy) and now operates under a new ownership.

CFIA recommendation 4

The CFIA recommends that the official veterinarian must document the ante-mortem inspection records to ensure completion of ante-mortem inspection before slaughtering of animals at swine and poultry slaughter establishments.

Ministry of Rural Development and Food (MRDF) actions plans/comments 4

According to our practice post mortem inspection data are full electronically documented in a computer program formed after our request by the Department of Information Systems and Digital Services of our Ministry.

After the CFIA audit the official veterinarians were informed that they should keep hard copies of the ante mortem inspection before entering them in the relevant data base.

CFIA recommendation 5

The CFIA recommends that humane handling and animal welfare program is implemented to ensure:

Ministry of Rural Development and Food (MRDF) actions plans/comments 5

By the December 2019 there is a new legislation of animal welfare in place about recording effectiveness of stunning.

The OV's of the related regional authorities have already been informed about the non-compliances in the live animal handling area and the use of improper crates. All the above are to be verified by the CCA in a scheduled targeted inspection before the end of June of 2020.

Furthermore, due to the amendment of legislation regarding checklists and risk assessment of the establishments all slaughterhouses will be reevaluated by the end of the year. The relevant Ministerial Decision is to be published.

CFIA recommendation 6

The CFIA recommends implementing post-mortem controls to ensure that:

Ministry of Rural Development and Food (MRDF) actions plans/comments 6

According to our practice post mortem inspection data are full electronically documented in a computer program formed after our request by the Department of Information Systems and Digital Services of our Ministry.

After the CFIA audit the official veterinarians were informed that they should keep hard copies of the post mortem inspection before entering them in the relevant data base.

CFIA recommendation 7

The CFIA recommends implementing a SRM control program to ensure:

Ministry of Rural Development and Food (MRDF) actions plans/comments 7

1 of the official veterinarians of the bovine slaughterhouse has already been trained recently by the CCA and the second one will be trained during the next training seminar.

CFIA recommendation 8

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated retained water control program as per the Canadian requirements prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

Ministry of Rural Development and Food (MRDF) actions plans/comments 8

This is about to be implemented in the case of establishments eligible for exporting to Canada.

CFIA recommendation 9

The CFIA recommends that the pine nuts must be included in the allergen control program at establishments interested to export red and poultry meat and meat products to Canada.

Ministry of Rural Development and Food (MRDF) actions plans/comments 9

This is about to be implemented in the case of establishments eligible for exporting to Canada.

CFIA recommendation 10

At the meat and meat products processing establishment, the CFIA recommends that operator completes documented analysis for chosen frequency for microbiological sampling of finished products as per Article 4 of the commission Regulation (EC) No. 2073/2005.

Ministry of Rural Development and Food (MRDF) actions plans/comments 10

Please see the highlighted part of the new HACCP checklist attached below that includes the obligation of the operator to complete documented analysis for chosen frequency for microbiological sampling of finished products as per Article 4 of the commission Regulation (EC) No. 2073/2005:

CFIA recommendation 11

The CFIA recommends that HACCP and pre-requisite programs are developed, implemented and monitored effectively to correct and prevent deficiencies identified in this report.

Ministry of Rural Development and Food (MRDF) actions plans/comments 11

The new check list includes that HACCP and pre-requisite programs should be implemented and monitored effectively.

CFIA recommendation 12

The CFIA recommends that:

RTE meat products must meet the Canadian requirements for the control of L. monocytogenes as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods and the Canadian operational guideline: product inspection and sampling of meat and poultry products.

Ministry of Rural Development and Food (MRDF) actions plans/comments 12

This is about to be implemented in the case of establishments eligible for exporting to Canada.

CFIA recommendation 13

The CFIA recommends that

Chemical residue monitoring program was implemented as per the EU requirements.

Ministry of Rural Development and Food (MRDF) actions plans/comments 13

The final report of 2019 and the plan for 2020 will be sent to CFIA as soon as they are completed by the relevant Department.

11.6 Audit recommendations (Cyprus)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during audit be corrected and verified in a timely fashion.

Actions plans/comments of Veterinary Services of Cyprus 1

Bovine and swine slaughterhouses:

Inspections of the slaughterhouse aiming the verification of the operators conformity with the legal requirements as well as the requirements foreseen by the Canadian Legislation have been carried out by the Veterinary Services.

In order to remedy the shortcomings the FBOs responded by proceeding with infrastructure upgrades and other corrective measures as to implementing the necessary procedures, for instance modifying their HACCP system.

The relevant administrative fines have been imposed by the Veterinary Services to the red meat slaughterhouses which were not in compliance with the veterinary provisions foreseen by the veterinary legislation.

Poultry slaughterhouse:

The Veterinary Services have, on the first place, demanded from the operator to proceed with the relevant corrective measures for remedying the shortcomings found. The operator has then, proceeded with implementing the relevant corrective actions which, at a second place, had been evaluated by the Veterinary Services and assessed as satisfactory. Confirmation of the corrective actions was done through an on the spot inspection by the Veterinary Officer.

Meat product processing establishment:

A relevant letter was sent to the FBO indicating to him the need to take corrective actions on all shortcomings found. The FBO had then taken the necessary corrective actions which were then notified to the Veterinary Services by letter on 23/07/2019. A series of inspections by Veterinary Officers followed in order to verify the compliance of FBO. The measures taken had been assessed as satisfactory.

CFIA recommendation 2

The CFIA recommends further enhancing the government oversight to ensure compliance with regulatory requirements for official controls of food chain.

Actions plans/comments of Veterinary Services of Cyprus 2

The Veterinary Services carried out in 2019 a second annual inspection of the red meat slaughterhouses. Another 2 inspections are foreseen to be realized in 2020.

Based on written instructions issued by the Veterinary Public Health Sector, Official Veterinarians at ungulate's Slaughterhouses, inspect weekly the slaughterhouses; in particular the hygiene requirements, edible viscera, waste areas, animals.

CFIA recommendation 3

The CFIA recommends having supervisory oversight at establishments interested in exporting meat and meat products in order to meet Canadian requirements.

Actions plans/comments of Veterinary Services of Cyprus 3

There is no interest in exporting meat and meat products to Canada from a Cyprus for the time being. The Veterinary Services though carry out administrative checks on all exports to third countries and on-the-spot checks of the consignment at a frequency determined on risk base analysis.

CFIA recommendation 4

The CFIA recommends that the animal information document be fully completed and signed as per the requirements.

Actions plans/comments of Veterinary Services of Cyprus 4

Instructions had been given to slaughterhouse staff to ensure that the forms are fully and duly completed.

CFIA recommendation 5

The CFIA recommends that:

Actions plans/comments of Veterinary Services of Cyprus 5

Bovine and swine slaughterhouses:

An updated checklist/form for pre-slaughter checks, which incorporates the requirement that inspection in accordance with the Canadian requirements has been done. The Official Veterinarian inspects the animals, fills the first page of the checklist/form and hand it over to the FBO so that only the animals which had been inspected and their inspection was registered on the checklist/form can be slaughtered., A new checklist/form is completed each time ante-mortem inspection is carried out.

CFIA recommendation 6

The CFIA recommends that the official veterinarian documents the stunning verification at slaughter establishments.

Actions plans/comments of Veterinary Services of Cyprus 6

Verification of stunning efficacy is checked and recorded in the relevant form on a weekly basis, including control of stunning and slaughter procedures.

CFIA recommendation 7

The CFIA recommends that the National/regional guidance is available to ensure the segregation between cattle from countries having controlled and negligible risk of BSE.

Actions plans/comments of Veterinary Services of Cyprus 7

The Veterinary Services regularly inform slaughterhouse staff on the status of countries in this regard, with relevant circulars. The relevant guidelines to the FBOs are in the process of been finalized and communicated to the FBOs.

CFIA recommendation 8

The CFIA recommends that adequate post-mortem controls be implemented to ensure:

Actions plans/comments of Veterinary Services of Cyprus 8

Additional supervision of government oversight to ensure compliance with the requirements of legislation on official food chain controls will be ensured by the delegation of official controls tasks to a relevant delegated body. The Council of Ministers has already approved the delegation of this activity to an authorized delegated body.

The post-mortem inspection as well as the slaughter is done under the official veterinarian supervision at the poultry slaughterhouse.

CFIA recommendation 9

The CFIA recommends that adequate chilling controls are implemented to ensure:

Actions plans/comments of Veterinary Services of Cyprus 9

The FBOs take corrective action when the refrigerator temperature rises above the critical freezing point at the pig slaughter establishment.

Inspections are carried out on a weekly basis by Official Veterinarians which include the monitoring of meat temperatures. The corrective actions on the operators part are verified during the annual inspections of the slaughterhouse.

The operator sign PRP1 refrigeration monitoring forms and record any corrective action taken in relation to its non-compliance with the PRP1 freezing point for poultry carcasses.

CFIA recommendation 10

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated retained water control program as per the Canadian requirements prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

Actions plans/comments of Veterinary Services of Cyprus 10

It will be implemented by changing the export capability of products from Cyprus to Canada, to establishments of interest.

CFIA recommendation 11

The CFIA recommends that:

Actions plans/comments of Veterinary Services of Cyprus 11

The food establishment which has been inspected by the CFIA applies an allergen control program through which it is ensured that all additives containing allergens are securely stored and safely packaged in the raw material room. During their validity period, all measures targeting the avoidance of their contamination are duly implemented and all finished products are labelled in accordance with Regulation (EC) No. 1169/2011 and No. 1333/2008. The Veterinary Services have carried out official inspections of the establishment both, after the inspection of the Canadian Competent Authority and in the framework of the annual control program, the Veterinary Services have confirmed the FBO's and compliance with the relevant legal provisions in force.

CFIA recommendation 12

At the meat and meat products processing establishment, the CFIA recommends that operator:

The CFIA recommends that RTE meat products must meet the Canadian requirements for the control of L. monocytogenes as described in the Canadian control measures for Listeria monocytogenes in ready-to-eat foods and the Canadian operational guideline: product inspection and sampling of meat and poultry products.

Actions plans/comments of Veterinary Services of Cyprus 12

A relevant letter was sent to the FBO asking for corrective actions on his part to remedy all the observations found. The FBO had taken the relevant corrective actions which were then notified to the Veterinary Services by letter dated 23/07/2019.

A series of follow up inspections by Veterinary Officers to check full compliance on FBOs part. The measures taken were considered satisfactory.

CFIA recommendation 13

The CFIA recommends that all elements of HACCP and pre-requisite programs are developed, implemented and monitored effectively to correct and prevent deficiencies identified in this report.

Actions plans/comments of Veterinary Services of Cyprus 13

Bovine and swine slaughterhouses:

The Veterinary Services have audited the establishments in 2019. Another 2 inspections are foreseen to be realized in 2020 during which the HACCP manuals will be verified and prerequisite programs.

Poultry slaughterhouses, meat product processing establishment:

All the operators of the establishments which had been inspected by CFIA have taken the necessary corrective actions.

The appropriate implementation of the HACCP provisions on the FBO's part are systematically checked by the CyVS in the framework of the official controls realized by the Veterinary Services. Whenever necessary, the relevant measures for imposing the necessary corrective actions are implemented.

CFIA recommendation 14

The CFIA recommends that:

Actions plans/comments of Veterinary Services of Cyprus 14

Αs foreseen by Regulation (EC) No. 2073/2005 the Veterinary Services implement and monitor the Campylobacter bacterial program. In this framework, one parameter relating to Campylobacter had not been examined for the second sample and as of this instructions had been given for correct implementation of the program.

This requirement will be obligatorily fulfilled whenever the relevant interest for exporting these products from Cyprus to Canada is demonstrated on the FBO's part.

This requirement will be obligatorily fulfilled whenever the relevant interest for exporting these products from Cyprus to Canada is demonstrated on the operators part.

CFIA recommendation 15

The CFIA request that competent authority provide a rationale for the low NRCP sampling number for imported meat and meat products.

Actions plans/comments of Veterinary Services of Cyprus 15

In accordance with the European acquis, all consignments originating from third countries arriving at the BIPs and destined for the EU are checked 100%.

Pursuant to national provisions (Law 98 (I)/2002) the consignments of food of animal origin moved in the framework of the intracommunity trade are checked at a percentage of 10% of the total number of consignments transported. The National Residue Program setting the number of samples of food of animal origin to be checked is designed and monitored in accordance with the relevant applicable EU Legislation.

11.7 Audit recommendations (Bulgaria)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during audit be corrected and verified in a timely fashion.

Bulgarian Food Safety Agency (BFSA) actions plans 1

The BFSA took immediate actions concerning the audited establishments. With official letters of 16 July 2019 of the Executive Director of the BFSA, the Directors of the relevant Regional Food Safety Directorates (RFSD) in Blagoevgrad, Lovech and Pleven were informed about the preliminary findings presented during the closing meeting and the recommendations made by the CFIA audit team. As a result, the relevant establishments have been given prescriptions in order to correct the identified non-compliances within a specific deadline. In December 2019, the Directors of the RFSD Blagoevgrad, Lovech and Pleven informed the Headquarters of the BFSA with official reports to the Executive Director of BFSA (based on the governmental inspections carried out in the relevant establishments), that all non-compliances regarding the food legislation have been removed and the slaughterhouses meet the requirements of the applicable legislation.

CFIA recommendation 2

The CFIA recommends to further enhance the government oversight to ensure compliance with regulatory requirements for official controls of food chain.

Bulgarian Food Safety Agency (BFSA) actions plans 2

As a result of the audit carried out and the non-compliances found, all the audited establishments were reassessed and the frequency of the official controls increased.

CFIA recommendation 3

The CFIA recommends implementing ante-mortem inspection program to ensure that official veterinarian signs off the ante-mortem inspection records at the duck slaughter establishment.

Bulgarian Food Safety Agency (BFSA) actions plans 3

The official veterinarian at the duck slaughter completed and recorded thoroughly the ante-mortem inspection. Following the recommendation made by the CFIA audit team each ante-mortem inspection record is signed by the official veterinarian. During 2020, training for the official veterinarians in charge of official controls in meat-producing establishments is foreseen. The training will focus on the ante-mortem and post-mortem inspections and the compliance with animal welfare requirements during slaughter.

CFIA recommendation 4

The CFIA recommends implementing humane handling and animal welfare controls to:

Bulgarian Food Safety Agency (BFSA) actions plans 4

Following the audit carried out by CFIA the governmental control on the official control regarding the animal welfare has been increased. By an order of the Executive Director of the BFSA, a thorough inspection of all vehicles transporting domestic ungulates and poultry was carried out from the middle of July to the middle of August 2019. In total, 410 vehicles have been checked and 4 non-compliances have been found. The managers of the meat-producing establishments and the owners of the vehicles have been given prescriptions in order to correct the non-compliances. A follow up inspection showed that all prescriptions have been fulfilled.

The control regarding the stunning of swine, including the applicable technical devices has been strengthened.

With regard to the development of criteria and control measures for the ritual slaughter of bovine animals, BFSA is working together with other EU-MSs to develop uniform rules for the control of the ritual slaughter.

During 2020, training for the official veterinarians in charge of official controls in meat-producing establishments is foreseen. The training will focus on the ante-mortem and post-mortem inspections and the compliance with the humane handling requirements and animal welfare during slaughter.

CFIA recommendation 5

The CFIA recommends implementing post-mortem controls to ensure that:

Bulgarian Food Safety Agency (BFSA) actions plans 5

In all three meat-producing establishments, the non-compliances with regard to the official control were corrected and the official veterinarians are fully working in accordance with the rules laid down in Regulation (EC) No. 2019/627.

During 2020, training for the official veterinarians in charge of official controls in meat-producing establishments is foreseen. The training will focus on the ante-mortem and post-mortem inspections and the compliance with the humane handling requirements and animal welfare during slaughter.

CFIA recommendation 6

The CFIA recommends that:

Bulgarian Food Safety Agency (BFSA) actions plans 6

The Bulgarian Food Safety Agency has developed a Standard Operating Procedure for carrying out official controls at food producing establishments and sites for trade with foodstuffs in relation to compliance with the health rules on animal by-products (ABPs) and the control and prevention of TSE during the production and marketing of products of animal origin. The Procedure details the requirements for official controls on the prevention of bovine spongiform encephalopathies and the activities of official veterinarians to ensure compliance with regards to the specific risk materials legislation, including control requirements for the separation of animals originating from regions having different BSE status.

CFIA recommendation 7

The CFIA recommends implementing chilling controls to ensure that:

Bulgarian Food Safety Agency (BFSA) actions plans 7

During the inspection performed by the Regional Food Safety Directorates Blagoevgrad and Pleven, the compliance with the recommendations was checked. The recordings for the temperature regime of the cameras comply with the HACCP principles for monitoring and verification of CCP.

CFIA recommendation 8

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated retained water control program as per the Canadian requirements prescribed in the Canadian poultry water retention control program and Canadian control programs: water retention in edible raw red meat products.

Bulgarian Food Safety Agency (BFSA) actions plans 8

Of the establishments audited by the audit team, only the waterfowl slaughterhouse had expressed a desire to export meat and products to Canada. During the audit, the business operator provided information on the implementation of laboratory control of retained water. The other 2 establishments do not implement such a program because they are not interested in exporting to Canada.

The Bulgarian Food Safety Agency guarantees that if Canadian competent authorities approve import of meat and meat products from Bulgaria all exporting establishments will be subject to control for the implementation of retained water control program in accordance with Canadian requirements.

CFIA recommendation 9

The CFIA recommends that the pine nuts must be included in the allergen control program at establishments interested to export red and poultry meat and meat products to Canada.

Bulgarian Food Safety Agency (BFSA) actions plans 9

The BFSA guarantees that if Canadian competent authorities approve import of red and poultry meat and meat products from Bulgaria, all exporting establishments will be subject to control for compliance with the requirement pine nuts to be included in the allergen control program.

CFIA recommendation 10

The CFIA recommends that HACCP and pre-requisite programs are developed and implemented effectively to prevent the deficiencies identified in this report.

Bulgarian Food Safety Agency (BFSA) actions plans 10

All audited establishments had their HACCP and GMP inspected by audit teams from the relevant Regional Food Safety Directorates. The non-compliances found regarding the developed and implemented programs are removed and the business operators strictly fulfil the requirements of their self-control systems.

CFIA recommendation 11

The CFIA recommends that:

Bulgarian Food Safety Agency (BFSA) actions plans 11

The Bulgarian Food Safety Agency guarantees that if Canadian competent authorities approve import of red and poultry meat and meat products from Bulgaria, all establishments intending to export meat and products to Canada will comply with Canadian microbiological control requirements.

CFIA recommendation 12

The CFIA requests BFSA to provide a rationale or factor considered for determining number of samples to be tested every year under the NRCP program.

Bulgarian Food Safety Agency (BFSA) actions plans 12

On the basis of Directive 96/23 on measures to monitor certain substances and residues thereof in live animals and animal products and repealing Directives 85/358/EEC and 86/469/EEC and Decisions 89/187/EEC and 91/664/EEC, the number of samples is determined on the basis of the quantities produced for the previous year. An EC platform has been created that calculates the minimum number of samples.

11.8 Audit recommendations (Germany)

CFIA recommendation 1

The CFIA recommends that all establishment findings identified during the audit be corrected and verified in a timely fashion.

Federal Office of Consumer Protection and Food Safety (BVL) actions plans/comments 1

BVL provides the establishments' actions plans to the specific findings and the BVL official verification of their implementation.

CFIA recommendation 2

The CFIA request that bovine slaughter establishments eligible to export meat and meat products to Canada identify and segregate the SRM as specified in the Canadian conditions for importation of meat products from the European Union.

Federal Office of Consumer Protection and Food Safety (BVL) actions plans/comments 2

BVL-180 issues an official letter to the Federal States regarding the Canadian SRM removal requirements as stipulate in the Canadian Traces veterinary certificate. The letter includes the 2019 Guideline for certification for Canada.

This letter was sent by email to the CFIA on July 26, 2019.

BVL provides the bovine slaughterhouse action plan that include the implemented SRM written program and the BVL official verification of their implementation.

CFIA recommendation 3

The CFIA recommends that all establishments exporting meat, meat products and offal to Canada have a written and validated retained water control program for carcasses and offal as prescribed in the Canadian poultry water retention control program and Canadian Control Programs: water retention in edible raw red meat products.

Federal Office of Consumer Protection and Food Safety (BVL) actions plans/comments 3

BVL provides the bovine, pig and poultry slaughterhouses action plans that include a water control written program and the BVL official verification of their implementation.

The establishments through the relevant associations and Federal States must have a validated retained water control program for carcasses and offal as per stipulate in the Canadian requirements.

CFIA recommendation 4

The CFIA recommends that HACCP and pre-requisite programs are implemented and monitored effectively to correct and prevent the deficiencies identified in this report.

Federal Office of Consumer Protection and Food Safety (BVL) actions plans/comments 4

BVL provides the establishments' action plans including the HACCP and pre-requisites programs and the BVL official verification of the implementation.

11.9 Audit recommendations (France)

CFIA recommendation 1

The CFIA recommends that all establishment-specific observations noted during the audit be corrected and verified by the competent authority.

Direction Générale de l'Alimentation (DGAL) Action Plans 1

February 24, 2020: all non-compliance identified by the CFIA will result in corrective action by the establishments and verified by the French official authorities (DDecPP).

The DGAL has provided the corrective-action plans and associated documents for all audited establishments.

CFIA recommendation 2

The CFIA requires that at least 1 official veterinarian be present in poultry slaughter establishments throughout ante mortem and post mortem inspections as stipulated by Regulation (EC) #854/2004 and subsections 41(1), 138(1), 139(1) and 165(1) of the Safe Food for Canadians Regulations (SFCR).

Direction Générale de l'Alimentation (DGAL) Action Plans 2

February 24, 2020: compliance is ongoing, including observations in the duck slaughter establishment, to ensure that an official veterinarian is present in poultry slaughter establishments approved for export to Canada.

CFIA recommendation 3

The CFIA requests that certification procedures for the export of meat and meat products be revised to include on-site verification of each shipment by officials from the competent authority.

Direction Générale de l'Alimentation (DGAL) Action Plans 3

February 24, 2020: export certification is based on documentary and physical verification in case of doubt. The reliability of traceability and the establishment's hygiene levels are evaluated during each inspection, which helps to maintain confidence in the certification documentation provided. A batch inspection may be carried out if there are any doubts or as part of the risk assessment to determine the frequency of inspection.

June 25, 2020: official inspections for export certification are systematic and based on a documentary review and risk analysis, and they include a field inspection where appropriate. These official inspection procedures are consistent with European regulations and international standards. The DGAL would like technical clarifications to be made during a videoconference arranged by the European Commission or at the next Comprehensive Economic and Trade Agreement (CETA) Sanitary and Phytosanitary (SPS) Joint Management Committee (JMC) meeting so this point can be addressed and clarified under the existing equivalency agreement between Canada and the European Union.

CFIA recommendation 4

The CFIA recommends that all establishments exporting meat and meat products to Canada have a written and validated water-retention monitoring program, in accordance with Canadian requirements.

Direction Générale de l'Alimentation (DGAL) Action Plans 4

February 24, 2020: since this recommendation goes beyond European regulations, France will follow the findings of the equivalency process established with the European Commission, including whether to add this requirement to the specifications for Canadian accreditation.

CFIA recommendation 5

The CFIA recommends that adequate controls be put in place for the production of fermented and dried meat products.

The CFIA recommends that samples of sterilized meat products be incubated for a minimum of 10 days at 37°C ± 1°C.

Direction Générale de l'Alimentation (DGAL) Action Plans 5

February 24, 2020: in France, canned food incubation tests are performed based on 2 standards from the French association of normalisation (AFNOR):

A longer incubation period (21 days) is preferred in France when validating the scheduled process deviation procedures to allow germination and growth of sporulated flora and to detect changes in pH in case of instability. This makes it possible to ensure the scales are reliable before they are implemented. Then, for the routine, the test at 37°C for 7 days is considered sufficient.

The process of determining the degree/hour is not currently implemented in establishments producing dry sausages in France but has been suggested to the Institut du Porc français (IFIP), which is responsible for France's dry sausage charter. The Staphylococcus aureus risk assessment is incorporated into the institution's PMS and monitored by officials.

June 25, 2020: in the dry sausage production chain, the addition of starter lactic cultures (or ferments) in the mix, associated with acidification during steaming, is the main safeguard against the risk of Staphylococcus aureus.

Studies corroborate this. In fermented dry sausage–type products, the impact of fermentation and drying was examined on the synthesis of toxin A by Staphylococcus aureus during fermentation and drying.

A Japanese study (reference 1 below) assessed the role of Lactobacilli (present in the ferments) in dry sausage on the growth and production of S. aureus enterotoxins added at 4 log cfu/g in the mix and using 2 different steaming temperatures (20°C and 35°C). The study shows that in the control product with no added Lactobacillus, enterotoxins were produced at both fermentation temperatures, while the presence of Lactobacillus inhibited the growth of S. aureus and its ability to produce enterotoxins.

Similarly, process challenge tests were conducted in France by the ADIV (Institut Technique Agro-Industriel) in 2008 (reference 2 below) on a profile of the most frequently isolated Staphylococcus aureus; the mixture was contaminated with S. aureus at a rate of approximately 3 log cfu/g, and the results of the study showed a decrease in the concentration of S. aureus from the end of fermentation (-1.2 log/g) and the absence of this microorganism from the 20th day of the process.

Reference: Sameshima T., Magome C., Takeshita K., Arihara K., Itoh M., Kondo Y. Effect of intestinal Lactobacillus starter cultures on the behaviour of Staphylococcus aureus in fermented sausage. 1998, International Journal of Food Microbiology, 41,(1) 1–7.

Reference 2: Christieans S., Dorchie G., Chacornac J.P., Talon R. (2009). Écologie microbienne du chorizo français : Incidence des paramètres technologiques sur la sécurité et la salubrité des produits.

CFIA recommendation 6

The CFIA recommends that HACCP and prerequisite programs be adequately implemented and monitored to address and prevent condensation in meat product production and storage rooms.

Direction Générale de l'Alimentation (DGAL) Action Plans 6

February 24, 2020: all identified instances of non-compliance, including condensation control, have resulted in corrective action being taken by the establishments and verified by the French official authorities (DDecPP).

The DGAL has provided the corrective-action plans and associated documents for all audited establishments.

CFIA recommendation 7

The CFIA requires that duck slaughter establishments include testing and sampling of microbiological hazards in their HACCP system as required by the Canadian Poultry Pathogen Reduction Program and subsections 47(1) and (2) of the Safe Food for Canadians Regulations.

Ready-to-eat meat products must meet Canadian requirements for the control of Listeria monocytogenes as outlined in the control measures for Listeria monocytogenes in ready-to-eat foods.

Direction Générale de l'Alimentation (DGAL) Action Plans 7

February 24, 2020: European regulations do not set hygiene criteria for duck slaughter establishment processes. Once the risk assessment has been completed and the standards validated by the CFIA, and in accordance with Canadian requirements that may not be recognized as equivalent to those of the European standard, France will incorporate the Canadian process hygiene criteria into the monitoring plans of French approved duck slaughter establishments.

A review of the Canadian Listeria monocytogenes control program did not reveal any discrepancy with the French requirements (testing frequency, non-compliance management). Guidelines are currently being drafted to clarify the rules applicable to ready-to-eat products.

Under section 50 of Act #2018_938 (Loi EGalim), establishments are required to notify the administration of any non-negative self-control results on the product and in the product's environment.

As part of the national monitoring and surveillance plan for 2020, a Listeria monocytogenes monitoring plan is planned for ready-to-eat products.

June 25, 2020: instructions on RTE foods will be forwarded as soon as they are published in the Official Bulletin.

DGAL/SDSSA/2019-846 guidelines dated 26/12/2019 relating to the monitoring plan for contamination of sandwiches and mixed salads by Listeria monocytogenes during production and distribution.

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