Dairy Import Activities
1.7 Dairy Product Sampling

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In addition to the sampling and analysis required by the importer, CFIA verifies compliance by taking monitoring samples. Samples are selected based on risk of the product itself, its history of compliance, by country or manufacturer, environmental scans etc.

In light of historical trends, volumes of dairy imports and general risk, cheese is the main focus for sampling and analysis, and protocols have been designed for imported cheese versus other imported dairy products.

1.7.1 Imported Cheese Sampling Protocol

This protocol has been established to document a compliance history of imported cheeses, by variety and manufacturer. This protocol is used by CFIA for sampling and may be used by the importer as a guideline for analyses to perform and the number of samples to select.

1.7.1.1 Types of Laboratory Analysis

Lab analyses can include microbiological, phosphatase, compositional and chemical residue testing to evaluate compliance to regulatory requirements.

i. Microbiological: Samples are analysed for the pathogens E. coli, Staphylococcus aureus, Salmonella, Listeria monocytogenes using acceptable test methodologies; MFO-14; MFHPB-20; MFHPB-30; AOAC methods. The Standard Methods for the Examination of Dairy Products by the American Public Health can be consulted for other methodologies. The HC website provides a reference of laboratory methods in the Compendium of Analytical Methods.

Preference is given to methods which have been validated for the commodity concerned preferably in relation to reference methods elaborated by international organizations.

While methods should be the most sensitive and reproducible for the purpose, methods used for in-house plant testing often sacrifice to some degree sensitivity and reproducibility in the interest of speed and simplicity. They should, however, be proven to give a sufficiently reliable estimate of the information needed.

In the case of sampling bulk cheese, follow the directions provided in Dairy Sampling Procedures for aseptic sampling.

ii. Phosphatase: The phosphatase enzyme in milk is destroyed by pasteurization temperatures. Phosphatase testing is required when there is doubt as to whether the product has been made from raw or pasteurized milk. This analysis is requested to validate claims which may be made on the packages

iii. Compositional: Cheese is tested for percent milk fat and percent moisture. This is related to compositional standards as per the DPR, and label declarations.

iv. Chemical residues: Chemical residues are analyzed by the CFIA as per the annual monitoring plans or sampling alerts. If chemical residues are found, the importer may be required to request or perform subsequent testing.

1.7.1.2 Cheese Sampling Summary

In order to have meaningful data for product compliance, it is important that appropriate sampling be done to get an accurate representation of the lot of the imported product. The following table outlines the number of sub-samples according to lot size to be taken for various lab analyses.

The following table outlines the number of sub-samples according to lot size to be taken for various lab analyses.
Analysis Lot Size Sub-Samples
Microbiological Any 5
Composition, Additives < 50 2
Composition, Additives 50 - 500 3
Composition, Additives > 500 5
Phosphatase Any 3
Chemical Residues Any as per sampling plan
Extraneous Material Any 3
Calcium, Omega-3
Nutrient content Claims
Any as per sampling plan

For more overall information about sampling, especially aseptic sampling of techniques, please refer to the Dairy Sampling Procedures.

1.7.1.3 Determination of Compliance Status

For each variety, manufacturer and size of imported cheese coming into, Canada, a compliance status is established. Sampling priority is given to unpasteurized (raw milk) cheese and cheeses without historical data (new varieties). Compliance status is based on historical data, type (pasteurized or unpasteurized), country of origin, manufacturer, cheese variety and size.

The categories for compliance status are new cheese, normal and directed. An explanation of the switching rules regarding the compliance status of cheese can be found in Appendix 14.

1.7.1.3.1 New cheese (no history)

A new cheese, for the purposes of sampling and analyses, is a cheese never before imported into Canada from a specific foreign manufacturer. The compliance status of new cheeses must be established. In some instances, the determination of new product status may have to be made in consultation with the Dairy Specialist. Some examples of new cheeses are as follows:

Examples:

  1. Brie cheese is manufactured by foreign manufacturer A, and imported into Canada on a regular basis by a number of Canadian importers. One of the Canadian importers would like to begin to import Brie cheese manufactured by foreign manufacturer B. Since the Brie cheese from this foreign manufacturer has never been imported into Canada, it is considered to be a new product for the purposes of sampling.
  2. Cream cheese is manufactured by foreign manufacturer C and is imported regularly into Canada. A Canadian importer would like to begin to import cream cheese with herbs, manufactured by the foreign manufacturer C. Cream cheese with herbs is considered to be a new dairy product even though cream cheese made by the same manufacturer has been imported into Canada on a regular basis.
  3. Emmental cheese (10 kg package) manufactured by foreign manufacturer D is imported regularly. A Canadian importer would like to begin importing Emmental cheese in a 500 g package manufactured by the same manufacturer D. This cheese is considered to be a new product since no history exists on Emmental cheese (500 kg package) from this manufacturer.

For new cheese being imported into Canada, a complete laboratory analysis (all microbiological analyses and fat and moisture for compositional analyses) for the original lot is performed by a private laboratory to ensure that the product meets Canadian standards for microbiological and compositional analyses as described in Dairy Sampling Procedures. The product is sampled by a CFIA Inspector and sent to a private laboratory. The importer is responsible for the cost of the analysis for the first shipment. The sample results are sent directly to the Inspector by the private laboratory who then inputs this information into a National database. Results of the initial laboratory sampling are used to determine the compliance status of the cheese. This status, in turn, is used to determine the frequency of sampling and the types of analysis required for future shipments of the same product, from the same foreign manufacturer by any importer. (See Appendix 15 for the type of information collected in the database).

If no infractions are found, the cheese is assigned to Normal Status for sampling. However, failure to meet any microbiological or composition standard will result in future shipments of the same cheese being assigned to Directed Status for sampling. (See sections below for more information and for further actions to be taken).

1.7.1.3.2 Normal Status

Imported cheese with no history of non-compliance and/or new cheese with satisfactory analyses are assigned a Normal Status. In addition to the importer's lab analyses controls for this cheese, product is sampled and analysed once a year (microbiological and compositional) under the CFIA monitoring program, with priority given to microbiological sampling of cheese made with raw milk. This sampling is conducted by CFIA staff at no cost to the importer. If no infractions are found with this sampling the product maintains the Normal Status frequency level. Cheese may also be sampled for chemical residue monitoring under the CFIA chemical residue monitoring program.

1.7.1.3.3 Directed Status

When a cheese fails to meet microbiological or compositional standards either on the initial sampling (new cheese) or during the annual monitoring sampling it is assigned to Directed Status. The follow-up analysis may be limited to the pathogen(s) or compositional parameter of concern (e.g.: 5 sub-samples analyzed for S. aureus only). The product must be Held by the importer until satisfactory analysis results are received.
Note: A CFIA detention is issued if the inspector has reasons to believe that it is required.

When cheese fails to meet microbiological standards, the next ten (10) lots of this cheese imported by any importer, nationally, are sampled by a CFIA inspector. Eight (8) out of ten (10) lots are analysed at the importer's expense at a private laboratory. Two (2) of the ten lots are analysed at CFIA laboratories.

Copies of all results of analysis from a private laboratory are sent directly to the CFIA office in addition to the importer. To return to Normal Status frequency level, 10 consecutive lots must be satisfactory.

When a cheese fails to meet the compositional standards, the inspector will refer to Dairy Sampling Procedures for instructions.

See Appendix 16 and Appendix 14.

1.7.1.4 Products with Non-Satisfactory Results

Follow-up procedures in Dairy Sampling Procedures are used when a cheese fails to meet microbiological, compositional or chemical residue standards.

Infraction information may be brought to the attention of the Area Dairy Specialist. For non-satisfactory results with food safety implications, and when the lot has been distributed, the Area Recall Coordinator is informed and a risk assessment requested. An incident file on IMS is opened.

The inspector makes the importer aware of all non satisfactory and satisfactory results. In the case of non satisfactory results the importer, in addition to subsequent sampling, provides the Inspector with written corrective actions and preventative measures to prevent reoccurrence. A copy of the importer's written communication with their supplier is one way the importer can prove follow up action to the inspector.

If cheese is imported by a food manufacturing facility usually covered by other programs (e.g. Food Safety and Fair Labelling, Meat, Fish), appropriate inspection staff are advised when the dairy inspector is planning to sample at this location. When unsatisfactory analytical results are received, the related program is contacted for follow up.

1.7.2 Other Imported Dairy Products Sampling Protocol

Imported dairy products are monitored under various annual CFIA dairy sampling plans and may be collected either at registered facilities or non-registered facilities (e.g. bakeries). Follow directions given in Table 2 and Dairy Sampling Procedures. If non satisfactory results identify an emerging issue, sampling program procedures are developed related to the risk and the National database is used to track results.

In order to have meaningful data for product compliance, it is important that appropriate sampling be done to get an accurate representation of the lot of the imported product. The following table outlines the number of sub-samples according to lot size to be taken for various lab analyses.

The following table outlines the number of sub-samples according to lot size to be taken for various lab analyses.
Product Analysis Lot Size Sub-Samples
Butter, frozen products, milk products Microbiological Any 5
Butter, frozen products, milk products Composition, Additives < 50 2
Butter, frozen products, milk products Composition, Additives 50 - 500 3
Butter, frozen products, milk products Composition, Additives > 500 5
All dairy products Phosphatase Any 3
Butter Chemical Residues Any as per sampling plan
Powders Microbiological Any 5
Powders Salmonella Any 2 composited samples
Powders Composition/Chemical Residue/Additives Any 1 (composite)
Fluid Milk, Evaporated Milk, Powdered Milk Vitamin Analysis Any 3
Raw Milk (farm samples) Chemical Residues Any as per sampling plan
Nutrient Content Claims Calcium, Omega-3 Any as per sampling plan

If dairy products are imported by a food manufacturing facility usually covered by other programs (e.g. Food Safety and Fair Labelling, Meat, Fish), appropriate inspection staff are advised when the dairy inspector is planning to sample at this location. When unsatisfactory analytical results are received, the related program is contacted for follow up.

1.7.3 Repeated Non Satisfactory Results

Consultation with the Country of Origin
Depending on the product and the analytical test found non satisfactory, the National Program Representative is advised and may initiate consultation with officials of the product's country of origin. This consultation is to advise about the non-satisfactory findings.

Border Lookout
In case of recurrent problems where other measures have not resulted in compliance, a border lookout may be created. The CFIA Border Lookout is a system used to control products at the border through the Canada Border Services Agency (CBSA) with a mechanism to inform the CFIA of the arrival of these products into Canada. The standard procedure consists of CBSA notifying the Import Service Centre (ISC) of the targeted shipment at the border. The ISC reviews the import documentation and makes a decision regarding the importation. If the documentation is in order, the ISC will inform the local CFIA staff of the arrival of the dairy product (for established follow up action) and advises CBSA to allow entry. If the documentation is not in order, the load will not be released into Canada. The Border Lookout provides the information and direction required to reduce or manage imports with identified risks.

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