Language selection

Search

Canadian Food Inspection Agency On-Site Assessment Report of Guatemala's Food Safety Control System for Fresh Blackberries, Raspberries and Peas - 2016

On this page

Abbreviations and special terms used in the report

AGEXPORT
The Guatemalan Exporter's Association
CA
Competent Authority
CFIA
Canadian Food Inspection Agency
EU
European Union
US FDA
US Food and Drug Administration
FSD
Food Safety Directorate (Guatemala's MAGA)
GAPs
Good Agricultural Practices
Global GAPs
Global Good Agricultural Practices
GMPs
Good Manufacturing Practices
ISO
International Organization for Standardization
MAGA
Ministry of Agriculture, Livestock and Feeding
MSPAS
Ministry of Public Health and Social Assistance
OGA
Officina Guatemalteca de Acreditacion (Guatemala)
OSL
Operating Sanitary License
PIPAA
The Comprehensive Program for Agricultural and Environmental Protection
Primus GFS
Primus Global Food Safety (Initiative) – a Global Food Safety Initiative Variant
US
United States of America

Executive summary

This report summarizes observations made during the Canadian Food Inspection Agency (CFIA)'s September 2016 on-site assessment of Guatemala's government oversight of food safety controls.

The main objective of the visit was to increase CFIA's understanding of Guatemala's food safety control system for fresh blackberries, raspberries and peas, and to observe how Canada's import requirements and public health expectations are achieved.

The results of this assessment will help Canada direct oversight resources to areas of highest risk, increase food safety, and promote consumer confidence in imported products, while contributing to market access benefits. It was also intended to foster our relationship with the Guatemalan competent authorities (CAs) and to increase awareness of Canadian import requirements.

The scope of the visit was Guatemala's fresh berry and green pea industries, with a particular interest in the control of Cyclospora during pre-harvest and post-harvest activities associated with the export of fresh raspberries, blackberries and peas to Canada.

The mission included visits to facilities involved in primary production, packing, storage and export, as well as to laboratories engaged in the testing of food for export. The key elements of the assessment included:

The assessment determined that the Ministry of Agriculture, Livestock and Feeding (MAGA) – the CA in Guatemala – has developed an oversight system as required by their legislation for the safe production (growing, harvesting, storing, and transportation) and trade (import and export) of unprocessed agricultural products. In addition, the industry in Guatemala has a strong commitment to meet the food safety requirements of both the CA and their trading partners. Since the government of Guatemala has limited resources, they rely on private-public partnerships for the implementation of their food safety programs.

This report makes a number of recommendations which identify opportunities for improvement and enhancement of the implementation of their food safety control system measures.

The observations and recommendations contained in this report are based on information provided to the assessment team through the Canadian Assessment Standards tool, personal interviews, and on-site observation. They represent the collective understanding of the members of the assessment team.

1. Introduction

An assessment was conducted in Guatemala from September 26 to 30, 2016, by the CFIA Food Import/Export Division, under the auspices of the food safety oversight initiative.

The 5 day mission included:

An opening meeting was held with the Guatemalan CA on September 26, 2016, during which the objectives of the visit were reviewed, the itinerary confirmed, and an overview of the roles and responsibilities of the CA were presented. In addition, industry representatives presented information on their respective food safety programs and objectives.

September 27 to 29, 2016 was spent in the field visiting the premises of 2 growers and 2 packers of fresh berries and peas and 2 food testing laboratories. Representatives of the CA and the Embassy of Canada to Guatemala accompanied the assessment team throughout the visit.

A closing meeting was held on September 30, 2016, to summarize the preliminary findings of the team (including identification of areas which would benefit from additional explanation and clarification and potential areas for improvement).

2. Assessment objective, scope, and methodology

The objectives of the assessment were to:

2.1 Methodology

The assessment was comprised of 3 phases:

This report is intended to be a risk management tool which may be used by CFIA to inform existing import requirements and to identify opportunities for further collaboration with Guatemalan food safety authorities in the area of food safety.

2.2 Assessment scope summary

The visit focused specifically on fresh berries and peas destined for the export market. Sites visited included 2 farms, 1 of which had previously been implicated by CFIA in a Canadian outbreak of cyclosporiasis.

Summary of assessment scope
Site visited No. of sites visited Location
CA 1 Guatemala City
Farms 2 Various locations
Packing houses/exporters 2 Various locations
Laboratories 2 Guatemala City
Other 1 Industry association (host)

3. Legal basis for the assessment

This assessment was carried out in agreement with the Guatemalan authorities and under the CFIA's import requirements for fresh fruits and vegetables outlined in Section 3.1 (1) (b) of the Fresh Fruit and Vegetable Regulations and Section 4 of the Food and Drugs Act. In particular:

4. Background

The Guatemalan fresh fruit and vegetable industry consists of operations that range in size, complexity, and capacity. While some operations are large, modern, multi-national companies, others are small farm cooperatives with plots as small as 1/10 of a hectare and which lack basic services including access to a dependable supply of electricity.

Approximately 11 berry exporters and 42 snow and sugar snap pea operations are authorized to export product from Guatemala, representing more than 450 farms, storage and packing facilities. Of these, less than 10% of the pea exporters ship to Canada.

The sector has experienced significant growth in recent years with key markets including the United States of America (US), European Union (EU), Canada and Japan. The industry continues to actively seek opportunities to expand their current market access and the range of export-eligible commodities.

In light of 2 Canadian outbreaks of cyclosporiasis in 1998 and 1999 which were epidemiologically linked to Guatemalan fresh raspberries and blackberries respectively, the CFIA developed commodity-specific import requirements for Guatemala. Following the recommendations of Health Canada fresh blackberries and raspberries were restricted from entering Canada from March 15 to August 14 of each year. Wild blackberries and wild raspberries were restricted from entering Canada at any time.

In November 2012, after consultation with Health Canada, the CFIA's Fresh Fruit and Vegetable Program modified its import requirements to permit the entry of cultivated Guatemalan fresh blackberries on a year-round basis. The import restriction for Guatemalan cultivated fresh raspberries from March 15 to August 14 of each year, and the year round import restrictions for wild raspberries and wild blackberries remain in effect.

Considering there was an outbreak of cyclosporiasis that occurred in the province of Ontario over the period of August 8 to October 15, 2015, that was epidemiologically linked to the consumption of prepackaged fresh Guatemalan sugar/snap peas imported via the US, the scope of the assessment was expanded to include fresh peas.

5. CA and official controls

5.1 Overview of roles and responsibilities

The responsibility for the oversight of food safety is shared between 3 government departments (see Appendix A):

The specific jurisdiction, authorities and requirements are defined by a series of decrees (official orders issued by legal authority) and intergovernmental agreements (also legally binding) such as the National Snow Pea Committee, comprised of representatives from the MAGA, the Ministry of the Economy, and the Exporters Committee from the Guatemalan Exporter's Association (AGEXPORT).

The Ministry of the Economy is responsible for tariffs. They are also the Guatemalan representative to international trade organizations such as the World Trade Organization.

In addition to being responsible for public health in general, the MSPAS is responsible for the oversight of the safety and quality of processed products of plant origin. Decree 90-97 "Health Code of the Republic of Guatemala" confers upon the MAGA the authority and responsibility for the oversight of food safety controls including for fresh (unprocessed) products of plant origin for export. In 2004 the MAGA's Food Safety Directorate (FSD) was established specifically to address this responsibility. Appendix B provides an overview of the MAGA's current organizational structure.

Furthermore, Guatemala's Government Agreement No. 455-2013, Article 1 confers upon the MAGA the regulatory authority to delegate food safety inspection for the purpose of export. Through this agreement, the MAGA has delegated some of the export-related responsibilities to the Comprehensive Program for Agricultural and Environmental Protection (PIPAA), a public-private alliance which is responsible for issuing phytosanitary certificates, delivering of training programs and supporting industry's implementation of GAPs and GMPs. The PIPAA is the primary consultative interface between industry and the MAGA.

The PIPAA is governed by an Advisory Board and an Executive Directorate. The Advisory Board is comprised of a Chair (Deputy Minister of the MAGA), 4 representatives from the MAGA, 3 representatives from AGEXPORT, 1 member from each of the Association of the Chemical and Agricultural Guild, the Association of Users of the PIPAA, and the PIPAA. The functions of the Executive Directorate are proposed by the Advisory Board.

5.2 Overview of food safety controls

In order to export fresh unprocessed foods of plant origin, a company requires a valid Operating Sanitary License (OSL) which is issued by the FSD of the MAGA (the CA). The MAGA has the regulatory authority to grant or renew the OSL based on the legal provisions of Guatemala's Government Agreement No. 72-2003.

The CA has regulatory authority to inspect, investigate and verify compliance with good agricultural, good handling practices and other food safety requirements under Guatemala's Government Agreement No. 969-99.

Exporters must apply to the CA for an OSL for the activities which they are conducting (for example, growing, packing, storage, and transportation of fresh unprocessed foods of plant origin) in order for the product(s) to be eligible for export. The OSL is issued by the CA once it has been determined that the exporter complies with the relevant regulatory requirements and after an on-site verification. The OSL is valid for 1 year and is issued only after compliance with the food safety requirements is confirmed by an on-site inspection by the MAGA.

The MAGA conducts their on-site annual inspection using the check list that was developed by the PIPAA in collaboration with the US Food and Drug Administration (US FDA). The checklist, which is based on GAPs and GMPs, defines the MAGAs baseline food safety requirements. Although the original checklist has been revised several times to reflect updates to various regulations, the current version of the check list dates back to 2006.

Deviations from the check list requirements are classified into 2 categories: low or high risk each of which has a specified or agreed upon time frame for implementation of corrective action(s) (up to 2 months for low risk deviations). Effective implementation is subsequently verified by the CA through document review when it involves low risk deviations and an on-site verification when a high deviation is involved.

The PIPAA plays a key role in assisting small, medium and large farms and cooperatives in meeting the food safety requirements and in preparing for, and responding to, the MAGA's annual inspections. The PIPAA visits the approximately 970 registered producers every 3 months to help operators meet GAP requirements including records maintenance. If a producer does not meet the GAP food safety requirements, the producer is removed from the PIPAA's registry of export eligible producers and is no longer eligible to export until corrective actions have been effectively implemented.

In addition, in order to export a company must have a valid Phytosanitary Certificate for every shipment exported. This is issued by the PIPAA only when the exporter holds a valid OSL.

5.3 Program resources and training

Currently, the MAGA's FSD has 4 inspectors assigned to conduct annual inspections to verify compliance with baseline food safety requirements; however staff from other directorates can be cross-utilized if necessary. All of the MAGA's personnel are trained as agronomists, veterinarians or zootechnicians. Most have a food safety background and complete a university-accredited course(s) in food safety when they join the MAGA. Training is delivered by a third party provider (for example, the US Department of Agriculture, the US FDA, and Hazard Analysis Critical Control Point Alliance) and may be sponsored by, for example, the US Department of Agriculture, US FDA, EU, and others. In addition, before being authorized to conduct inspections, new inspectors must be supervised by a senior inspector for 3 to 5 months. The FSD has an internal procedure to verify that their inspectors are following the appropriate procedures.

With more than 450 companies currently registered with the FSD over 80% of the FSD inspector's time is spent in the field conducting annual inspections to facilitate the issuance of OSL's. The inspector's schedule is designed to ensure impartiality by rotating inspectors. The MAGA maintains inspection-related records for 10 years.

The PIPAA has 50 employees who are dedicated to various phytosanitary and food safety activities such as facilitating training of growers, providing technical support, developing guidelines, and collecting samples for testing. There were 14 inspectors/auditors trained by the US FDA in GAPs and GMPs.

5.4 Traceability and recall

Every company is required to have an effective traceability system before they are issued an OSL which certifies them for export.

When the MAGA is notified by another CA of a food safety incident/outbreak involving Guatemalan produce, they conduct a comprehensive investigation into the implicated farm(s) and packer(s). This includes a document review of the farm/packer's production history and food safety programs, and an on-site inspection. Evaluation of any test results generated related to the event (food, water, and environmental samples, etc.) also falls within the scope of the investigation.

5.5 Microbiological testing and laboratory controls

The MAGA does not prescribe any microbiological sampling or testing except for an annual water analysis for generic E. coli. Samples for this purpose are collected by the PIPAA. In addition, PIPAA collects 1 sample per grower per season for analysis of chemical residues to meet the MAGA's requirements. There is no requirement for physical analysis. In the case of a non-compliance and /or food safety investigation, the MAGA requests the implicated company to collect samples for testing at their expense. However, although the MAGA has a laboratory, it does not currently have the capacity to perform this testing. Therefore, sampling is typically conducted either by trained company personnel or, by a contracted sampler who is employed by a private third party testing laboratory.

Each company is responsible for any additional analysis of water, food and environment in accordance with requirements for third party certification, that is, Global Good Agricultural Practices (Global GAPs), Primus, Costco, Tesco, etc. Water used for cleaning, personal hygiene, processes etc. must comply with the standards of Guatemala's water normative: COGUANOR NGO 29001. The MAGA reviews reports of analysis as part of their annual on-site inspections. In addition, the PIPAA takes a food sample to be analyzed for chemical contamination from each producer at the beginning and end of the production season.

All sampling and testing is performed by International Organization for Standardization (ISO) 17025 accredited laboratories. At the time of the assessment there were 38 member laboratories in AGEXPORT's Laboratory Commission. The number and scope of accredited laboratories is increasing each year. While most routine testing is conducted in Guatemala, external laboratories may be contracted for specialized analyses.

5.6 Implementation of food safety controls at the farm, packing and exporter levels

The CFIA team visited 2 farms and 2 packers/exporters in order to observe and assess how the CA verifies the implementation of Guatemala's food safety requirements. These visits focused on:

During the visit the assessment team interviewed the Field Managers of both farms as well as key field staff, Production Managers of both packing/export facilities and their Food Safety Managers/Coordinators. The team reviewed a range of documents including their:

Overview of farm number 1 and packing facility number 1

This family business has been in operation for over 30 years and is currently responsible for over 50% of the blackberries exported from Guatemala. It also has operations in Mexico and Chile, and a head retail office in Florida, US. They grow and market a variety of produce under various trade names, with blackberries and French beans the most important fruit and vegetable crop, respectively. Their markets include the US, EU, Mexico, Canada and Japan.

The company employs approximately 25 staff across the 4 farms that they manage in Guatemala. During 2 peak harvest seasons, the number increases from 80 to 120 employees. Produce from the farms is packaged in a packing facility which is located in close proximity to the farms.

French (green) beans are trimmed by hand instead of being cut with a knife. To minimize handling damage and spoilage due to excessive moisture, the product is not washed.

The company owns its own transport vehicles to convey the product for export. Most of the product is shipped by air, but alternative shipping options by sea are being pursued.

The company has had a food safety system in place since 1997. They have a valid OSL for the harvesting, processing, storage and transportation of fresh fruits and vegetables. They also hold certification from Global GAPs and Primus Global Food Safety (Initiative) – a Global Food Safety Initiative Variant (Primus GFS). The company is subject to annual audits to maintain these certifications. Copies of their current certificates were observed by the assessment team.

Overview of farm number 2 and packing facility number 2

Established in 1998, this company consists of 4 farms: 2 certified organic, and 2 conventional. They share a common processing facility. They grow and market a variety of produce under various trade names, with French beans the most important vegetable crop at the time of the visit. Their markets include the US, Canada, Japan and the United Kingdom. This company was implicated in the 2015 Ontario outbreak of cyclosporiasis which was linked to snow peas.

The company employs approximately 16 to 26 field workers and 35 to 45 packing plant employees depending on seasonal needs.

French beans are trimmed using a knife, washed in a flume and dried in a centrifuge.

The company owns its own transport vehicles to convey the product from the farms to the packing facility.

The company has implemented a documented food safety (Hazard Analysis Critical Control Points) system based on Global GAPs, Primus GFS, and the Equitable Food Initiative.

The company has an OSL for growing and packing, and third party certifications from Global GAPs, Primus GFS, Costco and the US National Organic Program. The requirements of these schemes generally exceed the MAGA's baseline requirements.

5.7 Summary of observations at farm and packing facilities

The facilities visited have implemented and maintain food safety systems in accordance with the MAGA's requirements. They maintain valid OSLs for the activities they conduct.

Both operators have a Field Manager who is responsible for the implementation of the food safety system at the field level including training, worker health and hygiene, and overall production. The quality of the water, soil, fertilizers and the plants themselves are managed by a qualified agronomist. While 1 farm does not use manure on the fields (they use chemical fertilizers which are delivered via a drip irrigation system), the other uses compost and chicken manure which are applied 65 days before harvest. Neither farm uses human sewage to fertilize their farms.

The farms meet the MAGA's requirement to have deep water wells for irrigation. Entrance to the facilities is physically controlled with access limited to authorized personnel. Employees are trained to monitor chlorination equipment and levels and to maintain the filtration system (where one is in place). Microbiological analysis of water for E. coli and coliforms is routinely conducted twice per year (once each in the dry and rainy seasons), more frequently if necessary, for example, when filters are changed. Drip irrigation lines are flushed routinely to prevent clogging with soil and minerals.

The food safety management systems for packing and export are implemented and managed at both packing/exporting facilities by a Quality Manager who is a food safety specialist by profession. The Manager is supported by a quality team.

The food safety management systems are subject to annual internal audit and management review. In addition, they are subject to annual inspection by the MAGA and food safety audits by third party certification bodies. Corrective actions resulting from these activities are addressed within 30 days or, by an agreed upon schedule up to 2 months (in the case of low-risk issues identified by the MAGA).

As part of their food safety systems, both packing/export facilities have documented procedures to monitor raw materials, cleaning and sanitation, equipment, personnel hygiene, training, storage, waste disposal, transportation, traceability and complaints.

Employees must be trained before they can work at these packing facilities. Regular training sessions on food safety, personal hygiene, internal procedures and processes, etc. are also held throughout the year. Training is provided internally by the quality team and externally by third parties, for example, the PIPAA and various contracted services.

Company hygiene and health policies require staff to have a valid government health card which attests to the absence of a variety of illnesses/infections. It is renewed annually. Employee health and hygiene is monitored and documented routinely. Procedures are in place to remove an employee from handling produce if they don't meet health/hygiene requirements. In addition, employees have to attest in writing to their fitness to work each day prior to entering the packing facility.

Both operations have adequate hand washing stations and toilet facilities on the farm and in the packing facilities. Employees are required to wear personal protective equipment (for example, masks, aprons, gloves, hairnets, etc.) which is provided by their employers.

Written procedures are implemented for daily, weekly and other scheduled cleaning of the premises and equipment, including personal protective equipment.

Pests are managed by an integrated pest management system which includes various types of traps and deterrents. Monitoring of controls is conducted by a third party pest control company and by internal staff.

The companies have developed detailed traceability systems that allow them to trace back to the level of the farm, and lot. Even the picker can be identified by 1 farm. Mock recalls are conducted at least twice a year to test their system. While there are still challenges in maintaining records, companies are working to address this by developing standard forms and procedures, and applying to private certification schemes.

These companies manage complaints following their respective documented complaint procedure. They are not required to inform the MAGA of complaints unless there is an outbreak. However, companies are required to notify the MAGA when results relative to food safety are obtained, for example, the presence of E. coli. In the event of a complaint/recall/outbreak which implicates a fresh product from Guatemala, the exporter's client notifies the exporter directly. The exporter then initiates a follow up.

Each operation is visited once a year by the MAGA in order to renew their OSL; and every 3 months by the PIPAA. Third party certification bodies also audit annually. The assessment team confirmed that the implementation of the operations' written procedures is verified by the MAGA and the PIPAA during their on-site activities.

6. Laboratory capacity

Industry typically engages private certified laboratories for their routine testing of water, food and environmental samples which are required to meet the requirements of the MAGA and/or their clients.

Historically, support for laboratory research and development in Central America was provided by the Central American Institute for Industrial Research and Technology. The dissolution of this organization in 1998 led Guatemala to establish a Laboratory Commission (part of AGEXPORT's Services sector) to build capacity amongst the existing network of private laboratories. Since then, there has been an increase in the number and scope of accredited laboratories. The Commission currently facilitates collaboration among 38 private participating food laboratories and organizes provision of proficiency panels. Private laboratories in Guatemala often partner with international laboratories in the US, EU, etc. to send samples for a broader range of analyses. For example only 3 laboratories in Guatemala can conduct basic pesticide analysis. Samples are therefore sent to overseas laboratories.

Shortly after the Commission was created, a national accreditation body (Officina Guatemalteca de Acreditacion (OGA)) was established to provide consistent oversight of the private laboratories and verify compliance with ISO 17025. The accreditation body maintains a current list accredited laboratories on their website.

To avoid conflict of interest, public regulatory laboratories (the MAGA and the MSPAS) are not part of the commission but they maintain close communication with it. This communication includes exchange of information, advice and services.

Officials advised that some of the tests performed by the MSPAS laboratories are accredited, although they comprise only a small percentage of the overall testing done. Most of the tests they perform are conducted using internal (unaccredited) methods. They have staff dedicated to quality assurance and maintenance of a Quality System. However, the main priority of the MSPAS laboratories is human (clinic) health, including hospitals, medicines, and foods. Although the Guatemalan government does not engage private laboratories in outbreak investigations, the OGA has authority to allow private laboratories to participate in some testing, if needed.

The team visited 2 private laboratories to observe their involvement in the testing of foods. Both laboratories are members of the laboratory commission. They are accredited by the OGA to the ISO 17025 standard. As part of their accreditation they are subject to annual audits conducted by the OGA.

The scope of analysis for the first lab visited includes these analyses:

The second lab visited conducts the following analyses:

The staff in both laboratories are suitably trained and qualified for their respective roles (have diplomas or degrees as relevant, including professional degrees for some staff). Training and re-training (theoretical and practical) is documented. The laboratories participate in inter-laboratory comparisons nationally and internationally (for example, the Food Analysis Performance Assessment Scheme, United Kingdom).

Both laboratories have written procedures on sampling to provide guidance to clients on how to collect samples. They receive samples from:

For the latter case, the lab informs the client that if a sample has not been collected and submitted in accordance with required fitness criteria the results may not be reliable. In such cases, the sample will only be tested should the client wish to proceed.

There is no regulatory obligation for the laboratories to report any positive results to authorities.

7. Role of the industry associations and interests of the industry

The industry is supported by a strong export community which is coordinated by AGEXPORT. AGEXPORT is a private non-profit association whose mission is to promote and develop exports of Guatemalan products and services. Their focus is on 3 main export sectors: Agriculture and Fishing, Manufacturing and Services. Each sector area is comprised of several committees, for example, the Fruits Committee and the Vegetables Committee. The work of each committee is delivered by product-specific commissions, for example, Peas and Vegetables Commission, Berries Commission, Laboratories Commission, etc. AGEXPORT provides services and negotiates public policies that facilitate and sustain access to global markets.

8. Closing meeting

The closing meeting was held on September 30, 2016 with the MAGA, the PIPAA, AGEXPORT, and representatives from the Embassy of Canada to Guatemala. The CFIA team expressed their overall satisfaction with Guatemala's strong system of third party food safety oversight and identified areas where Canada could offer recommendations for improvement.

8.1 Observations

During the closing meeting the following observations were shared with the CA:

  1. Guatemala has in place a food safety control system which is shared across the MAGA and the PIPAA, and supported by the export community.
  2. All exporters of fresh unprocessed foods must have an OSL before they can export. The OSL - which is based on GAPs, GMPs, and Codex norms - is granted by the MAGA following a company's annual on-site inspection which confirms compliance with the MAGA's requirements.
  3. The checklist currently used by the MAGA was developed in the 1990s by the PIPAA in collaboration with the US FDA. It was adopted by the MAGA in 2004. The current version of the checklist was dated 2006. It does not include minimum acceptability criteria for sampling and testing.
  4. It is expected that any corrective actions resulting from these activities will be addressed within 30 days or, by an agreed upon schedule (up to 2 months). However, during 1 of the visits, the team noticed that several corrective actions had not been implemented despite the fact that the MAGA re-issued their OSL.
  5. Companies are not required to notify the MAGA of complaints/recalls/potential food safety issues other than the finding of E. coli in water.
  6. There is no regulatory requirement for a company to initiate a trace-back in the event of a potential food safety risk, for example, an ill employee.
  7. A Phytosanitary Certificate is issued for unprocessed foods of plant origin on the condition that the operator has a valid OSL and proof of export shipment inspection issued by the PIPAA. Results of analysis (microbiological, chemical, and physical) are attached to the documentation package if they are required by the importing country.
  8. Companies often have multiple third party certifications, for example, Global GAPs, Primus GFS, Costco, Tesco, etc. which require annual on-site inspections. They are also audited regularly by other country authorities, for example, the US FDA. Some exporters participate in the US FDA 'green list' program which grants them access to the US market without being subject to detention for physical examination.
  9. The industry appears to rely on chlorination (which is not reliably effective for parasites, viruses) and annual water testing for indicator organisms only, that is, E. coli and other coliforms to mitigate the microbial contamination of the water supply. Even so, reliable implementation of chlorination was acknowledged as an ongoing challenge.
  10. Companies have not developed comprehensive sampling plans for their sites and therefore have limited capacity to conduct trend analysis.
  11. No routine sampling and testing for Cyclospora is conducted by companies or the CA.
  12. There are no oversight controls in place specifically for Cyclospora or, for other protozoan parasites.
  13. Private laboratories also receive multiple third party audits each year (for example, from the US FDA, EU, OGA, etc.) to verify compliance with ISO 17025.
  14. Although the food laboratories visited have limited capacity for Cyclospora testing, they have signalled their interest in expanding their scope of analyses to include Cyclospora.
  15. Although the MAGA has the authority to conduct surveillance activities, collect samples and submit for testing, etc., they do not routinely do so. They appear to accept results which are required by international third party certification schemes.
  16. Although the outcome of the MAGA's investigation into a previous concern regarding fresh Guatemalan produce conducted at the request of CFIA identified the opportunities for improvement. However, during the visit, the team did not observe the implementation of any additional control measures that could mitigate the risk of Cyclospora contamination.
  17. One (1) of the farms visited does not filter their water except for the purpose of removing physical debris. This farm also uses unchlorinated well water for irrigation.
  18. Given the season, it was only possible to observe companies that were handling beans.
  19. In discussion with the CA during the on-site visit the assessment team realized that the information provided in the Canadian Assessment Standards tool did not mention that the MAGA has 2 laboratories involved in the testing of foods, nor that small cooperative farms without basic services are involved in the export of fresh berries and peas. Therefore, activities to observe these sites were not included in the assessment plan. In addition, due to operational requirements, and security policies established by the Embassy of Canada to Guatemala, we were unable to meet with other the MAGA inspectors.

8.2 Recommendations

The CFIA assessment team identified the following areas where Canada could offer recommendations for improvement:

  1. Develop and implement a process for the continuous improvement of the MAGA's oversight systems (for example, ensure routine updates of their checklist based on current knowledge, international standards, etc.), add minimum acceptability criteria, optimize documentation maintenance procedures, avoid overstock of outdated versions.
  2. Develop and implement a system to validate the effectiveness of industry's recall capabilities.
  3. Strengthen documentation of corrective actions and the process of issuing of an OSL.
  4. Develop capacity and expertise at the national level in the detection of, bacteria, parasites including Cyclospora, viruses, and including organisms that are antimicrobial resistant. This will facilitate the surveillance of the human population necessary to better inform risk-based decisions for microbiological control, and enable more effective monitoring of the effectiveness of those measures.
  5. Encourage industry to enhance their routine random sampling and initiate monitoring programs, trend analysis, verification of controls, etc.
  6. Include filtration as an integral part of all food safety plans as the only effective means of control of Cyclospora and other protozoa. Standardized procedures for the use, maintenance (including replacement) and verification of the effectiveness of these filters should be developed, based on available international standards.
  7. Take caution when interpreting negative results of analysis, particularly for chlorinated samples, since most of the testing performed for E. coli and coliforms appears to employ culture-based assays which rely on the presence of live bacteria in order to detect their presence. In such cases negative results can only be used to demonstrate the effectiveness of chlorination for killing susceptible bacteria, but not to demonstrate whether fecal contamination has occurred or not. This would require detection methods that do not rely on viable bacteria in the samples, such as polymerase chain reaction.
  8. Explore other available test methods for the analysis of water and produce for Cyclospora and Cryptosporidium, for example, the US FDA method to provide a more suitable indicator model for both untreated and chlorinated water.

8.3 Conclusions and next steps

As a result of this visit, the CFIA assessment team has established a general understanding of Guatemala's food safety control systems and a foundation for future working relations with our Guatemalan counterparts, including channels for open communication and information-sharing.

The representative from the MAGA acknowledged the observations presented by the CFIA team and expressed their future interests in collaboration.

The team also indicated that they would advise CFIA's Technical Assistance group of Guatemala's interest in working together to identify potential opportunities for targeted technical assistance.

Appendix A: Overview of the roles and responsibilities of the foreign CA

The MSPAS

The MSPAS is responsible for the prevention and control in the stages of processing, distribution, transportation and marketing of all kinds of processed domestic and imported foods.

Grants include:

The MAGA

The MAGA is responsible for the prevention and control in the stages of production, processing, storage, transportation, import and export of unprocessed natural foods.

Grants include:

The FSD (part of the MAGA)

The FSD is responsible for the oversight of food safety controls including for fresh (unprocessed) products of plant origin for export and supervision of the packing houses (GMPs).

Grants include:

The PIPAA (under the Phyto-Sanitary Directorate of the MAGA)

The PIPAA is responsible for the supervision of the GAPs.

Grants include:

Appendix B: Organizational chart of the MAGA

Picture - Organizational chart of the Ministry of Agriculture, Livestock and Feeding. Description follows.
Description for photo - Organizational chart of the MAGA

The hierarchy of Guatemala's CA's organizational chart (descending from the highest level organization):

  • Ministry of Agriculture, Livestock and Feeding
    • Vice Ministry of Agricultural Health and Regulations
      • Directorate of Phyto Zoogenetic and Native Resources
      • Food Safety Directorate (Note: responsible for the oversight of food safety controls including for fresh (unprocessed) products of plant origin for export supervision of packing houses)
      • Phyto Sanitary Directorate
        • The Comprehensive Program for Agricultural and Environmental Protection
      • Fishing and Aquaculture Normative Directorate
Date modified: