Final report of an Audit of Mexico's Meat Inspection Systems Governing the Production of Meat and Meat Products for Export to Canada – March 19 to April 02, 2019

On this page

• Abbreviations and special terms used in the report
• Executive summary
• 1. Introduction
  • 1.1 Background
  • 1.2 Audit objective, scope, and methodology
  • 1.3 Legal basis for the audit and audit standards
• 2. Competent authority and oversight
  • 2.1 Regulatory framework
  • 2.2 Oversight framework
  • 2.3 Training framework
  • 2.4 Export controls
  • 2.5 Import controls
  • 2.6 Enforcement framework
• 3. Ante-mortem, humane handling and animal welfare controls
  • 3.1 Animal identification
  • 3.2 Ante-mortem inspection and Humane handling controls
• 4. Post-mortem and slaughter controls
• 5. Processing controls
  • 5.1 Antimicrobial controls
  • 5.2 Chilling/freezing controls
  • 5.3 Retained water control program
  • 5.4 Allergens control program
  • 5.5 Lethality treatment
• 6. Preventive control plans
• 7. Microbiological controls
• 8. Chemical residue controls
• 9. Closing meeting
• 10. Conclusions
• 11. Recommendations

Abbreviations and special terms used in the report

CFIA

Canadian Food Inspection Agency

CCA

Central Competent Authority

DETIF

Directorate of Federal Inspection Type

DGSA

General Head Office of Animal Health

HACCP

Hazard Analysis and Critical Control Points.

MVRATIF

Authorized Veterinary Medical Officials

MRL

Maximum Residue Limit

MVO

Veterinary Medical Official

NOM

Mexican Official Standard

OTM

Over Thirty Months

SADER

Secretariat of Agriculture and Rural Development

SRM

Specified Risk Material

SENASICA

National Service for Sanitary, Food Safety and Food Quality

TIF

Federal Inspection Type establishment

UTM

Under Thirty Months

Executive summary

This report describes the outcome of an initial audit of the caprine and ovine and maintenance audit of the bovine and swine meat inspection systems of Mexico. The Canadian Food Inspection Agency (CFIA) conducted an onsite audit during the period of March 19 to April 2, 2019.

The objective of the audit was to verify if Mexico is implementing a meat inspection system equivalent to that of Canada, and if that system is capable of producing safe, unadulterated, and properly labelled meat products for export to Canada. The audit scope included visits to the central competent authority (CCA) headquarter in Mexico City, regional office and slaughter and processing establishments located in different regions of Mexico.

The audit covered activities within the following subject areas:

• Competent authority and oversight
• Ante-mortem, humane handling and animal welfare controls
• Slaughter and post-mortem controls
• Processing controls
• Preventive control plans
• Microbiological controls
• Chemical residue controls

Overall, the audit results showed that meat inspection systems governing the production of bovine and swine meat and meat products and processed meat products in Mexico are performing as intended in an adequate manner and demonstrated an acceptable implementation of controls for all areas described above.

In January 2020, the CCA confirmed that the audited caprine and ovine slaughter establishment is no longer interested to export goat meat to Canada. Therefore, the CCA didn't provide an action plan to rectify the CFIA findings observed at this establishment. Following the review of the findings related to the government oversight, sanitation, post-mortem, HACCP, building maintenance and animal welfare at the audited caprine and ovine slaughter establishment, the CFIA is unable to conclude that Mexico's caprine and ovine meat inspection system is equivalent to that of Canada at this time. A follow-up onsite audit will be required to complete the review of caprine and ovine meat inspection system.

1. Introduction

1.1 Background

Mexico is currently allowed to export bovine (including farmed bison), and swine (including farmed wild boar) meat and meat products to Canada. Earlier, the CFIA conducted audit of Mexico's meat inspection systems in 2006 and 2010.

1.2 Audit objective, scope, and methodology

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

• competent authority and oversight
  • regulatory framework
  • oversight framework
  • training framework
  • export controls and knowledge of Canadian export requirements
  • import controls
  • enforcement framework
• ante-mortem, humane handling and animal welfare controls
  • premises registration, animal movement, identification and traceability
  • animal movement controls
  • ante-mortem inspection
  • humane handling and animal welfare
• slaughter and post-mortem controls
• processing controls
  • chilling/freezing controls
  • water retention
  • allergen control program
  • lethality treatment of the non-ready to eat (NRTE) product
• preventive control plans
• microbiological controls
• chemical residues controls

The CFIA auditors reviewed administrative functions at the CCA headquarters and a state supervisory office. The auditors evaluated regulatory framework, oversight framework, enforcement framework, training framework, export controls and import controls. The representatives from the CCA accompanied the auditors throughout the audit.

1.3 Audit objective, scope, and methodology

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

• Safe Food for Canadian Act and Regulations
• Health of Animals Act and Regulations

The audit was conducted in a manner consistent with conventional program delivery audit standards to assess the consistency of CCA's inspection activities with the Mexican and Canadian regulatory requirements and specifications.

2. Competent authority and oversight

2.1 Regulatory framework

The Federal Animal Health Act covers the slaughter of animals and processing of products of animal origin for human consumption. This act also covers the animal welfare and good manufacturing practices applicable to the primary production and Federal Inspection Type establishment (TIF). The Ministry of Agriculture, Livestock and Rural Development issues the Official Standards under the Federal Animal Health Act. The key relevant Official Standards are:

• Mexican Official Standard NOM-008-ZOO-1994: zoo sanitary specifications for building and equipping establishments for slaughtering animals and those dedicated to industrializing meat products and 1997 and the Draft Amendment of the Mexican Official Standard NOM-008-ZOO-1994.
• Mexican Official Standard NOM-009-ZOO-1994: sanitary meat processing
• NOM-033-SAG/ZOO-2014: Methods for slaughtering domestic and wild animals
• Mexican Official Standard NOM-130-SSA1-1995: goods and services.
• Mexican Official Standard NOM-120-SSA1-1994: establish goods, services, hygiene and safety practices for processing food, non-alcoholic and alcoholic beverages
• Agreement DOF 09/10/2014: agreement establishing the criteria for determining the maximum limits of toxic and contaminating residues, the operation of analytical methods, the National Program of Control and Monitoring of Toxic Residues in goods of animal origin, aquaculture and fishery resources, and Program of Monitoring of Toxic Waste in animals, as well as the consultation module, which are regulated by the Secretariat of Agriculture, Livestock, Rural Development, Fisheries and Food'
• Mexican Official Standard NOM-O51-ZOO-1995: humane treatment when transporting animals
• Mexican Official Standard NOM-033-ZOO-1995: humane sacrifice of domestic and wild animals

2.2 Oversight framework

Mexico's meat inspection system is organized into 3 levels: central, state and establishment. The National Service for Sanitary, Food Safety and Food Quality (SENASICA) is a decentralized administrative body of the Secretariat of Agriculture and Rural Development (SADER). The SENASICA acts as a Central Competent Authority. The Directorate of Federal Inspection Type Facilities (DETIF) provides direct oversight to the Federal Inspection Type (TIF) establishments that produce meat and meat products for domestic and international market.

Mexico is divided into 32 federal entities. At regional level, the State supervisors are directly under the supervision of DETIF. The State supervisors supervise the establishments and are responsible for verification of export requirements, enforcement implementation, pathogen reduction and residues sampling program. The State supervisory visits are done on a monthly basis as per the Mexican requirements.

In Veracruz State, the monthly supervisory visits weren't conducted for 4 months prior to the onsite audit. The samples for official microbiological sampling program weren't collected in January and February, 2019 at audited establishments in Veracruz and San Luis Potosí states.

The TIF establishment's team is composed of one Official Medical Veterinarian (MVO) employed and paid by SENASICA and Authorized Veterinary Medical Officials (MVRATIF) contracted by a third-party organization and paid by the operator. The MVRATIF works under the direct supervision of the MVO and perform all inspection tasks except signing the export certificates.

Both the MVO and the MVRATIF are responsible for daily ante-mortem inspection, post-mortem inspection, and verification of the implementation and effectiveness of Good Manufacturing Procedures (GMP), HACCP, Sanitation Standard Operating Procedures (SSOP), official sampling and export certification activities. At the audited processing TIF establishments, a MVO was present during operations and was responsible for verification of the compliance of the raw material, GMP, SSOP, HACCP and official sampling.

2.3 Training framework

The MVO and the MVRATIF perform the inspection and verification tasks related to the production and processing of meat and meat products. As stipulated in the Federal Animal Health Act and Professional Career Service Law, the MVO and the State supervisor must receive at least 40 hours per year of continuing education and undergo an evaluation of their professional abilities at least once every 5 years. The MVRATIF must complete at least 16 hours of continuing education per year to obtain a new authorisation offered by SENASICA and it is valid for 2 years.

AS audited, MVO completed the training as per the Mexican requirements. The MVO's training was given by SENASICA and various universities.

2.4 Export controls

The SENASICA registers the TIF establishments eligible for export of meat and meat products to Canada. The operator makes an application to SENASICA for issuance of the export certificate. Thereafter, SENASICA's official reviews the documents and conducts final inspection of product and transport container. Export health certificate is then printed and issued by the MVO assigned to the export establishment. The copy of the export health certificates, seals and stamps are kept under lock and control of MVO.

The Canadian import requirements are electronically available to the OVM. However, in few cases, the MVO was unable to retrieve the Canadian export requirements. Furthermore, SENASICA sends email notifications to the State supervisors. As audited, the State supervisor communicated the updated Canadian import requirements to the MVO and operator via email. The bilingual labelling (English and French) requirement for consumer prepackaged meat product for export to Canada wasn't implemented at all audited establishments as stipulated in the Canadian requirements for bilingual food labelling.

At the audited establishments, labels were either only in English or English and Spanish for products intended for export to Canada.

2.5 Import controls

The SENASICA is responsible for negotiating certification and export requirements. The SENASICA assess the foreign country's meat inspection system and give the approval for establishments eligible to export to Mexico. The importing products and live animals are inspected at their arrival at the points of entry, ports and airports as required in the Federal Law of Animal Health Article 32 to 36. The Official staff of the Secretariat is responsible for import inspection at the point of entry. No border inspection points, ports or airports were visited during this audit

2.6 Enforcement framework

Non-compliance related to food production, humane treatment and transportation of animals are sanctioned according to provisions of the Federal Animal Health Act (Article 1, 2, 167, 168 and 169) and the Federal Weights, Measures and Standardization Act. The MVO and the MVRATIF have the legal power at the establishments to suspend or stop the production and certification activities, detain animals, products and equipment.

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

3.1 Animal identification

The Federal Law of Animal Health provides legal basis for the implementation of traceability systems for animals and products of animal origin. The livestock production units are registered in the National Livestock Census managed by SADER. As per National Cattle Individual Identification System (SINIIGA), and the NOM001-SAG/GAN-2015, bovine are individually identified. The individual identification is a unique and permanent number assigned to the animal (birth or at importation) and remains active until death or slaughter of animal. Other animals such as sheep and goat have official documents to ensure the traceability.

As audited, the cattle were individually identified. However, caprine weren't identified individually at the farm. After receiving at the slaughter establishment, caprine were identified by documents as a lot for traceability purposes. The individual animal identification other than bovine National Animal Identification System for Bovines for other animal species will be incorporated in future.

3.2 Ante-mortem and humane handling controls

As described in the NOM-009-ZOO-1994, the MVO or MVRATIF conducts the ante-mortem inspection within 24 hours before slaughter. The ante-mortem inspection includes the physical check of the animal and document review. The veterinarian signs off the ante-mortem inspection and slaughter authorization inspection cards prior to slaughtering of animals. The operator segregates all suspect animals for further inspection. The operator at the audited slaughter establishments had an animal welfare officer responsible to develop and implement the animal welfare program.

At the audited swine slaughter establishment, the compromised and non-ambulatory pigs were moved with a cart to the emergency stunning area at the slaughter floor without being stunned in the pen. The non-ambulatory bovine is stunned on site, and the dead or non-ambulatory bovines weren't permitted for slaughter.

The stunning was done by using mechanical or electrical stunning techniques. The operator's animal welfare officer and SENASICA monitored the effectiveness of the stunning techniques on a daily basis.

The CFIA auditors observed halal ritual slaughter at the caprine slaughterhouse. The ritual cut wasn't always a single fluid, uninterrupted cut of the neck. At the time of the audit, the SENASICA was aware of the recurrence of the non-compliance, but didn't take any immediate corrective actions. Furthermore, regulatory requirements weren't available to prevent the undue suffering of animals exposed to ritual slaughter.

4. Slaughter and post-mortem controls

The sequential numbers were used to identify each carcass prior to entry of the carcass into the evisceration room. These numbers were recorded in the Information Technology system. The operator monitored the correlation between the carcass, red/white viscera and head, while the official veterinarian verified the correlation.

The post-mortem inspection of the bovine, swine and caprine carcasses and parts was completed as stipulated in the NOM-009-ZOO-1994. The official veterinarian at the carcass station located before the final wash was responsible to make sure of the wholesomeness and suitability of carcass and its parts for human consumption. The palpation, incision, visual inspection was generally used to detect pathologies and defects on the head, tongue, kidneys, red and white offals. The carcass with local pathologies and defects were marked and railed out or trimmed directly on the evisceration line. After trimming of the local pathologies and defect, the official veterinarian re-verified the carcass and allowed the carcass to bear the health mark before entering the chiller.

A CCP was used to control the presence of fecal, ingesta and milk before the final wash. The operator monitored 100 % of the carcasses before the end of the evisceration room. The SENASICA official veterinarian verified the number of carcasses as stipulated in Food Safety and Inspection Service (FSIS) directive # 6420.2 rev.1 of 2017.

World Organisation for Animal Health (WOAH; founded as Office International des Épizooties (OIE)) recognizes Mexico as a negligible BSE risk status. Only bovine born and raised in Mexico were slaughtered at the audited establishments. The operator verified the animal's age at the head station and verified animal teeth to determine if the animal was under (UTM) or over 30 months of age (OTM). The operator identified and segregated SRM. The SRM is shipped for domestic market for human consumption or sent to a rendering facility.

Auditors noted deficiencies related to SRM removal and identification at bovine TIF establishments. The distal ileum wasn't completely removed at one of the TIF establishments. The OTM carcasses were only identified with green ink at the end of front legs resulting in difficulty to identify carcasses in the cooling area.

The CFIA auditors observed the presence of contamination (fecal, hair and foreign material) on the bovine, caprine and swine carcasses present in the coolers. The employees at the evisceration line were scraping the contamination instead of trimming at the caprine slaughter establishment. Auditors noted systemic presence of hair and fecal contamination on the caprine carcasses at and after the zero tolerance station. The operator zero tolerance monitoring documents demonstrated that the carcass was free of contamination but contamination was actually present during the audit.

The inspection legend (health stamp) marked on the carcass was not readable at all the slaughter establishments visited. The auditors noted that the official inspection of caprine carcasses didn't include the incision of the lymph nodes when needed as stipulated in the program.

5. Processing controls

5.1 Antimicrobial controls

In Mexico, there is no specific regulation to regulate the use of microbial intervention. The use of microbial intervention depends on international norms and the export requirements of the foreign countries such as EU, USA and Canada.

The antimicrobial agents currently approved for use in Mexico are lactic acid, acetic acid, citric acid and per acetic acid. These agents are used for the final washing of carcasses at the end of the evisceration line and as microbiological control for products fallen on the floor. The concentration of the antimicrobial agents during operations is controlled using a control point.

5.2 Chilling and freezing controls

As described in NOM-008-ZOO-1994, the maximum refrigeration temperature shall be 4°C and optimal temperature within freezer areas shall be at least -18°C. At the audited establishments, chilling and freezing controls were implemented as per the requirements.

5.3 Retained water control program

The Mexican national legislation didn't establish requirements related to retained water control program for bovine, caprine and swine. The auditors observed the use of air chilling at the audited bovine, swine and caprine slaughter establishments. However, common steps like final carcass wash, antimicrobial treatment with solutions of bactericides have a potential to promote the retention of water. The Canadian requirements require slaughter establishments to complete the annual validation for retained water.

5.4 Allergen control program

The periodic verification of the allergens is included in the "Mexican manual of inspection and verification of the food safety system for the official inspection personnel" at the exporting TIF establishment. The operator's allergen control procedure included all Canadian priority food allergens. The allergens were indicated in the list of ingredients on the label for meat products to be exported to Canada. The allergen control program was implemented and verified at the audited establishments.

5.5 Lethality treatment

The CFIA visited one processing establishment producing non-ready-to-eat meat product. The products are considered as ready-to cook and were frozen. Most of the non-ready-to-eat meat products are stuffed meat products such as meat cabbage roll, enchiladas, quesadillas, and taquitos. The source of the meat used for stuffing is only from Canadian and American establishments eligible to export to Canada.

The meat stuffing is cooked in the bag in a horizontal autoclave or in boiler. The cooking step is validated, monitored and verified using a CCP. After cooking, meat products are at once frozen in the blast freezer in a blast freezer at -37°C for 40 minutes.

6. Preventive control plans

As required by the Federal Animal Health Act chapter II article 18, the TIF establishments do a risk analysis, establish critical control points, operating procedures and sanitation standards. As audited in slaughter and processing establishments, the operator established and implemented the HACCP and pre-requisites program. The SENASICA verifies the daily implementation of HACCP and pre-requisite program controls. The SENASICA ensures satisfactory levels of compliance with Mexican requirements by verification of sanitation, HACCP and pre-requisite programs.

In Mexico, the different elements of HACCP and pre-requisite programs are implemented at the slaughter, processing and storage establishments. The CFIA auditors noted deficiencies related to elements of HACCP and prerequisite programs at slaughter and processing establishments. These deficiencies included condensation over the exposed meat and meat products, rusty overheads in various areas of establishments, worn out/broken food contact surfaces, debris in the various areas of establishments, and inconsistent monitoring and recording of CCPs and implementation of good hygienic practices. The CFIA auditors also noticed that the monitoring frequency of CCPs was not adequate to control the hazard such as presence of contamination and defects on the carcasses in cooling rooms.

7. Microbiological controls

The microbiological controls include self-monitoring by the food business operator and official sampling by SENASICA. At the slaughter and meat processing establishments visited, the operator tested carcasses and meat products on a daily, weekly or monthly basis following the FSIS sampling frequency specific to the type of product. The bovine and swine carcasses were tested for generic E. coli and Salmonella spp using sponge method as per the frequency prescribed by FSIS. The meat and meat products derived from bovine and are considered as precursor material for the preparation of finished raw ground meat were tested for the presence of E. coli O157:H7/NM according to procedures described in Control Measures for Escherichia coli O157:H7/NM in Raw Beef Products. The testing laboratory method used to test the E.coli 0157:H7/NM. The FSIS methods AOAC 031002 and 091301 were used to test the E. coli 0157:H7/NM. The caprine and swine carcasses were tested for generic E. coli and Salmonella.

The processing establishment producing non-ready-to-eat meat products implements microbiological monitoring plan for meat products and environment. The operator completes sampling for Listeria monocytogenes, Salmonella for all type of meat products and E. coli 0157:H7 for bovine meat products during the day of production. The product remains at the establishment until receipt of negative results. The operator completes environmental swab sampling on twice a month basis for the detection Listeria monocytogenes.

For official sampling, the SENASICA develops microbiological sampling program annually. The official microbiological sampling program monitors and detects pathogenic or indicator microorganisms to meet the international regulations applicable to the TIF establishments authorized to export meat and meat products. The targeted micro-organisms are E. coli O157:H7, Shiga toxin-producing E. coli (STEC), Listeria monocytogenes and Salmonella spp.

The SENASICA gives official annual microbiological sampling program to each State supervisor for distribution to the respective TIF establishments. The MVO or MVRATIF completes sampling and submit the samples to accredited laboratories. In case of non-compliances, MVO, State supervisor and food business operator receives notification from the laboratories. The follow-up actions include suspension of the export certification, and root cause analysis and appropriate corrective actions. The samples for official microbiological sampling program weren't collected at 3 slaughter establishments in 2 Mexican states in January and February 2019.

8. Chemical residue controls

The SENASICA implements national residues control program to monitor, prevent and control toxic residues and pollutants in animal products. The number of samples depends upon the slaughter volume and type. The Central office of SENASICA develops and send sampling schedule to the State supervisor. The MVO and MVRATIF do the sampling as per the sampling plan. The National Center for Animal Health Monitoring Services (CENAPA) laboratories conduct testing and analysis. Appropriate follow-up was completed in response to the non-compliant results.

In Canada, imported meat products are subjected to routine monitoring for chemical residues. The results are assessed and must meet the Canadian maximum residue limits. The maximum residue limits for veterinary drug residues are established by Health Canada.

9. Closing meeting

The closing meeting was held at the SENASICA headquarter in Mexico City on April 02, 2019. At the meeting, the CFIA lead auditor presented a summary of audit preliminary establishments and systemic findings.

10. Conclusions

Overall, the audit results showed that meat inspection system governing the production of bovine and swine meat and meat products and processed meat products in Mexico are performing as intended in an adequate manner and demonstrated an acceptable implementation of controls for all areas.

In January 2020, the CCA confirmed that the audited caprine and ovine slaughter establishment is no longer interested to export caprine and ovine meat to Canada. Therefore, the CCA didn't provide an action plan to rectify the CFIA findings observed at this establishment. Following the review of the findings related to the government oversight, sanitation, post-mortem, HACCP, building maintenance and animal welfare at the audited caprine and ovine slaughter establishment, the CFIA is unable to conclude that Mexico's caprine and ovine meat inspection system is equivalent to that of Canada at this time. A follow-up onsite audit will be required to complete the review of caprine and ovine meat inspection system.

11. Recommendations

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