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Final report of an audit conducted in the United States of America to evaluate the food safety systems governing the production of meat and poultry products intended for export to Canada – January 23rd to February 10th, 2017
6 Processing controls

6.1 Salmonella control in RTE meat products

As described in the FSIS Salmonella compliance guidelines for meat and poultry, establishments producing dry, fermented, and salt cured products may also implement a process achieving a 5D-log lethality of Salmonella for meat products and a 7D-log lethality of Salmonella for poultry products. Regardless of the lethality process used, all establishments that produce RTE meat and poultry products must provide supporting documentation that the process for their RTE products achieves the required or recommended reduction of Salmonella. This supporting documentation must be provided as part of an establishment's hazard analysis decision-making documents, and validation data must be included in its HACCP records (9 CFR 417.5(a)(1) and (2) and 417.4(a)).

As described in MOP chapter 11.7.3.2.2.2 (U.S. import requirements), it is required that RTE non-heated products, such as dry cured salted and dry cured fermented meat and poultry products that are processed without the application of heat require a 5D log reduction of Salmonella in meat products and a 7D log reduction of Salmonella in poultry products because of the synergistic antimicrobial effect of lower pH and/or lower water activity. The validation may be done through the combination of scientific peer reviewed journal articles which includes critical operational parameters that align with the establishment's process/product composition or challenges study/inoculated pack. The scientific supporting documentation should be sufficiently related to the establishment's product and process.

During CFIA audit conducted in 2013, the auditors learned during on-site activities that USDA-FSIS allows establishments to produce the above types of products without having to conduct a validation of the lethality of the process for the required 5D log Salmonella reduction (non-heat treated RTE beef products)/ 7D log Salmonella reduction (non-heat treated RTE poultry products). The same observation was made regarding the validation of Salmonella control requirements during CFIA audit conducted in 2017. The scientific article was used for validation; however establishment was not able to prove that the variables in the study represent the conditions of their process.

U.S establishment visited during this audit, produces the RTE non-heated products, such as dry cured salted and dry cured fermented meat and poultry products without conducting a proper validation of the lethality of the process for the required 5D log (RTE beef products)/ 7D log (RTE poultry products) as described in FSIS salmonella compliance guidelines.

6.2 Allergens

Multiple inspection tasks are conducted to verify that an establishment's food safety system meets regulatory requirements with regard to allergens and other ingredients of public health concern, including the HAV task, the HACCP verification tasks, the review of establishment data task, preoperational and operational SSOP tasks, the general labelling task, and the big 8 formulation verification task. If non-compliance is detected, a recall can be initiated as described in the FSIS directive 8080.1.

As described in the FSIS directive 7230.1, the allergens include wheat, crustacean shellfish, eggs, fish, peanuts, milk, tree nuts and soybeans. The ingredients of public health concern that may cause food intolerance include sulfites, lactose, tartrazine, gluten, and monosodium glutamate (MSG); yet they are not considered allergens. Canada's priority food allergen includes US's big 8; and sesame and mustard. As per the export library requirements for Canada, descriptive terms applied to meat and poultry product must be consistent with Canadian Food and Drug Regulations and the Canadian MIR which includes allergens declaration.

Allergen control program was implemented as per FSIS directive 7230.1.

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