ARCHIVED - Corrective Action Requests (CARs) issued to XL Foods Inc. as a result of the CFIA’s in-depth review of the plant

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E. coli is commonly found in the digestive tract of cattle. Contamination of meat can occur when animals are slaughtered, especially during de-hiding and evisceration. Companies are required to have control measures in place to address these risks.

Based on the observations of the CFIA’s in-depth review team, a Corrective Action Request (CAR) was issued requiring the company to address issues related to its management of E. coli O157:H7.

During an in-depth review or audit situation, all findings are issued CARs immediately.

Findings related to the management of E. coli O157:H7 risks:

The company had an appropriate plan to control food safety risks which had been verified by the CFIA. However, the plan, known as hazard analysis and critical control points plan (HACCP), was not being fully implemented or regularly updated. Specific observations included:

  • lack of detailed documents outlining required steps when product was positive for E. coli O157:H7 or when there were a high number of positives in a 24-hour period
  • inconsistent trend analysis on positive samples and no process to include test results from client establishments
  • insufficient record keeping related to ongoing monitoring and validation of processes, procedures, and equipment maintenance (e.g., 12 of 100 water nozzles clogged in the primary carcass wash area)
  • deficiencies in sampling techniques and procedures, such as inconsistent sampling and no established monitoring program

The CFIA also issued a number of other CARs which pointed to general maintenance and sanitation issues that may be found in a high-volume plant - particularly if the plant is older. These issues would not typically be expected to contribute to E. coli O157:H7 contamination.

Findings related to maintenance and sanitation:

  • refrigeration units had not been cleaned as frequently as is required in the company’s written sanitation plan
  • ice build-up was observed on freezer doors
  • water was dripping from piping
  • a drain near the rendering room was emitting a foul odour
  • there was condensation above exposed containers of product in the sampling and weighing areas
  • sanitizer was dripping from overhead structures onto product below
  • the company had no effective monitoring procedures to ensure that equipment design meets requirements
  • the evisceration table thermometer was not functioning properly
  • some employees were not wearing beard nets
  • employees sorting beef trim touched contaminated product without following appropriate washing and sanitizing procedures

Plant staff were immediately notified of these findings as they were observed. In addition, the CFIA issued a CAR when product from XL Foods Inc. sampled by the US Food Safety and Inspection Service (FSIS) at the Canada-US border tested positive for E. coli O157:H7.

Why weren’t the problems found during the in-depth review identified during routine inspection?

In general, routine day-to-day inspections focus on key hazard control points where food risks are the greatest. Less critical aspects of production and facility maintenance are assessed, but less frequently. Therefore, some of the maintenance/sanitation issues found may not have been present on the day they were assessed.

In this case, the in-depth review or audit assessed all aspects of the plant operations and CARs were issued based on all observations as is the normal process. Normally, many of the findings of the in-depth review would have been addressed by face-to-face and day-to-day interactions with management. However, during an in-depth review or audit situation, all findings are issued CARs immediately.

The in-depth review determined that there was no one single factor that would lead to E. coli O157:H7 contamination; the combination of several deficiencies could have played a role. By themselves, each of these findings would not typically signal an immediate concern during the course of normal inspection activities.

In order to maintain ability to export, the XL Foods Inc. plant has been subjected to eight foreign audits over the past four years. Through these audits, issues were identified and each time the company acted on all findings.

What is a Corrective Action Request (CAR)?

Canadian Food Inspection Agency (CFIA) inspectors are in constant communication with plant management throughout the production day at federally registered meat establishments. When an inspector observes a potential issue of concern, they inform plant management.

In addition to day-to-day interaction with plant officials, CFIA inspectors may also issue a Corrective Action Request (CAR) when a formal response from the company is required. Once the CFIA issues a CAR, the plant operator is required to commit to an action plan to address the issue and prevent it from re-occurring.

CARs may be issued for a range of situations, from minor deficiencies to more serious concerns. If a food safety risk is identified, the CFIA requires action. For situations where there is no immediate food safety risk, the CFIA may allow the company more time to take corrective action.

The CFIA verifies that the plant’s corrective action measures have been effectively implemented. If the corrective action plan is not successful or if the operator is unwilling or unable to address the problem, the CFIA has a number of options, depending on the nature of the issue. Enforcement options include the following:

  • shutting down production lines
  • suspending the plant’s operating licence
  • prosecution