Final Report of an Audit Conducted In Argentina September 9th, through September 25th, 2013
Evaluating the Food Safety Systems Governing the Production of Beef And Poultry Meat Products Intended for Export to Canada
8. Slaughter/Processing Controls
The CFIA auditor reviewed Slaughter/Processing Controls, which included ante-mortem inspection procedures, ante-mortem disposition, humane handling and humane slaughter, post-mortem inspection procedures, post-mortem disposition, implementation of HACCP systems in all establishments, and implementation of a testing program for generic E. coli in slaughter establishments and E. coli O157:H7 in beef slaughter establishments. SENASA staff was very engaged in monitoring humane handling and stunning procedures. The lairage facilities were very well constructed and maintained with few exceptions. With respect to humane handling and humane slaughter the following findings were noted in some establishments:
- At 2 establishments, beef carcasses were noted to have extensive bruising, and not all bruised areas were removed before the carcasses passed into the cooler. Bruises were noted on both cows and young cattle although both categories of cattle appeared in good physical condition otherwise. The CFIA auditor discussed the need to reach back to the farm and trucking companies as the animals were arriving at the establishment with the bruises.
- At one beef establishment, several animals had not been properly stunned and were stunned with multiple stuns. The company took immediate action to correct the employee's work and said they would be purchasing a different stun gun.
- Many fractured wings were noted in 2 poultry plants. One VIC attributed this to the stunning procedure rather than improper catching techniques.
- Several instances of common contact of unapproved beef carcasses with equipment were identified by the CFIA auditor at various establishments. The companies and SENASA staff agreed to follow up to correct these situations.
Ante-mortem inspection was conducted according to regulation by SENASA at all the sites visited. It is done in a careful manner and includes a detailed review of documentation. In poultry establishments, the VIC also receives the pre-slaughter sheet the day before which contains information similar to the Canadian flock sheets. It is worth mentioning that farms are required to have a veterinarian on staff who must report any diseases of concern to SENASA, which highlights the focus on the farms for the production of safe food. Stunning was very well done and controlled at all poultry facilities. For poultry, the documents received with the live animals include the: (1) Registro criador – the farm registration information, (2) DT-e – the official transit document, (3) Remito – commercial documents, and (4) Certificado lavado y desinfección de camiones - official washing and sanitation certificate. In the case of cattle, the DTe includes the date of the vaccination for FMD and brucellosis.
There is normally a 2 hour resting for the birds between arrival at the plant and slaughter, but the birds normally receive ante-mortem inspection as the trucks arrive at the plant. There is no time prescribed in SENASA Regulations but there does not appear to be an issue in meeting CFIA's requirements that birds receive ante-mortem inspection within 24 hours of being slaughtered. If there is high mortality, necropsies may be performed to determine the cause.
The companies were very engaged in ensuring humane handling and proper facilities for the receipt of live animals and were quick to follow up when a non-compliance was identified. However, the auditor noted numerous carcasses that were bruised at 2 beef plants that were judged to have occurred prior to arrival at the plants, and in some cases the bruising was not adequately trimmed on the kill floor before moving to chilling. The humane handling and trimming requirements were both discussed with plants and SENASA.
SENASA requires that live cattle be washed in order to reduce microbial contamination prior to slaughter. This includes washing the parts of the animal where the cuts will be made during the dressing procedures. All beef plants audited used hyper-chlorinated water from 5-15 ppm for this purpose, and washing occurred at several points, including after receiving and just prior to slaughter and the animals were visibly clean before slaughtering. This may be part of the reason for the low rates of detection of Salmonella and E. coli O157:H7.
SENASA has legal requirements for GMPs and SSOP implementation but HACCP is not currently a legal requirement. However, all the plants visited had implemented a HACCP plan, in most cases to meet export country requirements. If the plant has a HACCP plan, it is monitored by SENASA staff through random checks. However, there may be no record to show that the verification has taken place unless an issue is identified and it would then be recorded on the Report of Official Control.
The beef post-mortem inspection meets the CFIA requirements with the exception of failure to incise the lateral retropharyngeal lymph nodes at all 5 beef plants that were audited. The CCA agreed to follow up and have this corrected immediately.
For poultry, the line speed is related to good practices and is based on the plant's operational capacity. The official veterinarian may order a reduction in line speed if there are problems and if it is determined that it is required. There is an official inspection station post defeathering where the majority of condemned birds are removed. There are 2 subsequent inspection points, 1 post evisceration (point # 1), where the viscera, carcass and internal cavity are inspected, and a subsequent inspection point (Point # 2) after evisceration and final washing just prior to the chill tank. There are normally 2 inspectors or auxiliary staff performing 100% inspection of both the carcass and the viscera at Inspection Point #1. In addition, a certain percentage of birds must be inspected post chilling. At this inspection station, SENASA verifies that chickens are properly sorted and sent to cut-up as required so that fractures, bruises and minor pathological lesions defects are removed.
There were no issues identified in the canning facility.
A mock recall is conducted at least once per year in all establishments. No issues were identified.
Poultry slaughter plants must have documented systems for process controls and written procedures that are approved by the CCA. Poultry must meet the required microbiological standard, as outlined in Resolution # 198/95 that requires that Salmonella spp. be absent in 25 g. All plants had at least one re-processing station where contaminated birds were washed before being returned to the evisceration line, and the employees performing this task are trained to assess birds for suitability to be returned to the line. A post-mortem report is completed for all lots which details the condemned birds.
Unlike in Canada, Argentina does not require the removal of the oil sac during the evisceration and carcass dressing for poultry.
The CFIA auditor noted that the light intensity of 300 lux was not sufficient, and several establishments had much higher intensities to address this concern. CFIA recommends that the CCA reviews the design of the work stations in poultry plants to ensure that space and light intensity is adequate for the inspection staff and company personnel to effectively perform their respective tasks related to inspection or re-conditioning contaminated birds. Related deficiencies were noted at inspection points 1 and 2 in different establishments and these were discussed with the CCA.
The requirements for generic E. coli testing are outlined in Circular 3834/2008. For poultry, the sample is taken by carcass swabbing. For beef, generic E. coli is used as an indicator of carcass contamination. SENASA requires that carcasses be tested at a rate of one test per 300 carcasses using the sponge method on 4 carcass sites: the rump, flank, brisket and neck. The company must graph the results so they are easy to interpret and SENASA has set acceptable, marginal and unacceptable limits. For carcasses, the limits are: acceptable (<5 cfu/cm2), marginal (5-100 cfu/cm2) and unacceptable (>100 cfu/cm2).
For the chemical residue program, (Plan Nacional de Control de Residuos e Higiene en Alimentos (CREHA), SENASA field staff are informed about the samples that need to be taken for chemical residues testing every 2 months and access the plant-specific plan on-line through a password protected system. Each plant is assigned a level of sampling based on the production and the export market. SENASA local staff receives all the results of the chemical residue testing, regardless if the result is positive or negative. If a result is positive, SENASA will trace back to the producer, and the next 5 shipments from that producer will be sampled. In addition, and the violator's name is published on the SENASA website.
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