Final Report of an Audit Conducted In Four European Union Member States February 3rd Through February 21st, 2014
Evaluating The Food Safety Systems Governing The Production of  Beef And Beef Products For Export To Canada

9. Microbiological Controls

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Them CFIA auditors reviewed the microbiological controls, which included the control over E. coli O157 and the implementation of relevant process hygiene and food safety criteria according to Regulation (EC) no 2073/2005.

According to Regulation (EC) no 2073/2005, food business operators are required to ensure that foodstuffs comply with the relevant microbiological criteria set out in Annex I. To this end the food business operators at each stage of food production, processing and distribution, including retail, must take measures, as part of their procedures based on HACCP principles together with the implementation of good hygiene practices, to ensure the following:

  1. that the supply, handling and processing of raw materials and foodstuffs under their control are carried out in such a way that the process hygiene criteria are met;
  2. that the food safety criteria applicable throughout the shelf-life of the products can be met under reasonably foreseeable conditions of distribution, storage and use.

Consequently, the beef slaughter/processing establishments are required to meet applicable process hygiene criteria as well as food safety criteria. Operators are required to chart their results in order to assess trends. The establishments visited generally met the requirements for microbiological criteria.

With respect to the control of E. coli O157, EU does not specially regulate this pathogen and it is the operator's responsibility to consider E. coli O157 as a hazard likely to occur in its HACCP plan. Although one MS has a surveillance program in place to test for this pathogen in certain products and some operators are testing carcasses, trims or ground beef to meet clients' requirements, none of the establishments audited were performing robust N-60 sampling procedures on precursor materials for raw ground beef as required under the Canadian policy described in chapter 4, Annex O of the Meat Hygiene Manual of Procedures.

In accordance with Regulation (EC) no 853/2004, FBOs are not allowed to use any substance other than potable water to remove surface contamination from products of animal origin, unless use of the substance has been approved by the Commission. The European Commission recently adopted in 2013 a measure to permit lactic acid on bovine carcasses to reduce microbial contamination. The conditions of this measure are stated in Regulation (EC) no 101/2013.

  • None of the plants audited were performing robust N-60 sampling procedures for E. coli O157 on precursor materials for raw ground beef as is required under the Canadian policy described in chapter 4, Annex O of the Meat Hygiene Manual of Procedures.
  • With the exception of France, none of the MSs audited had national microbiological monitoring sampling plans for E. coli O157 in raw beef products.
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