Final Report Of An Audit Conducted In The United States February 5th, through February 22nd, 2013 Evaluating The Food Safety Systems Governing The Production Of Meat And Poultry Products Intended For Export To Canada
7. Animal Disease Controls

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CFIA auditors evaluated Animal Disease Controls, including review of mechanisms for animal identification, control of condemned and restricted product, implementation of the requirements for non-ambulatory disabled cattle and specified risk materials (SRM), and procedures for sanitary handling of returned and reconditioned product.

The auditors learned that ante-mortem inspection procedures for poultry did not necessarily involve inspection by USDA-FSIS of all lots of live poultry entering establishments.

FSIS Response:

Per FSIS Directive 6100.3 and 9 CFR 381.70(a) Inspection program personnel (IPP) are to perform ante-mortem inspection on the day of slaughter. 9 CFR 381.70(a) provides that FSIS is to perform an ante-mortem inspection of poultry, where and to the extent considered necessary by the Administrator (i.e., as needed). In poultry establishments, Inspectors In Charge (IIC's) have the discretion to have IPP perform ante-mortem inspection on each lot of poultry at their establishments, even though ante mortem inspection of every lot is not a mandatory requirement or specified as a country requirement in the Export Library for Canada. Additional information about ante mortem inspection such as instructions for doing lot by lot inspection can be found at the following link.
Ante-mortem Inspection PDF (153 kb)

CFIA Follow-up:

FSIS is requested to amend the requirements in the export library to include lot by lot ante-mortem inspection in all USDA-FSIS official establishments producing poultry meat products for export to Canada.

The auditors found that red meat slaughter and processing establishments did not consistently identify the risk of Bovine Spongiform Encephalopathy (BSE) as a hazard likely to occur in their HACCP system.

FSIS Response:

FSIS requires all beef slaughter and processing establishments prior to operations to reassess for any hazards associated with BSE and SRMs.

Only hazards determined to be reasonably likely to occur are required to be addressed in HACCP. Potential food safety hazards may be adequately and just as effectively addressed by well-designed pre-requisite (PR) programs. Many establishments will use a combination of HACCP, SSOPs and pre-requisite programs to control SRMs. Although SRMs may be found in cattle of all ages (e.g. tonsils; distal ileum), certain beef slaughter or processing establishments may be able to support that SRMs are not a hazard reasonably likely to occur. FSIS regulations (9 CFR 310.22(e)(1) require beef establishments to incorporate SRM controls (HACCP, SSOP) or preventions (PR programs) to support hazards of SRMs from being likely to occur. For example, beef grinding establishments may determine that SRM is not a hazard reasonably likely to occur since they as part of a PR program receive only boneless beef or cuts from cattle LT30. There are no likely hazards of SRMs associated with the processing of boneless beef. Other establishments may require purchase specifications as a pre-requisite program to support their decision. FSIS will accept decisions that are reasonably supported. FSIS conducts in-depth Food Safety Assessments at all FSIS official establishments at least once every 4 years or more often for cause.

CFIA Follow-up:

FSIS is requested to review hazard analysis at the concerned slaughter establishment to ensure that SRM is identified as a hazard likely to occur and is properly addressed. Similar approach should be followed in all USDA-FSIS official beef slaughter establishments exporting meat products to Canada.

The United States strengthened their feed ban in 2008. This enhancement prohibits the use of the brain and spinal cord derived from cattle 30 months of age and older to be use in any animal feed. When compared to Canada, items such as the skull, the trigeminal ganglia, the eyes, the palatine tonsils and the dorsal root ganglia from OTM cattle and the distal ileum of cattle of all ages which would be considered as SRM in Canada, are considered inedible in the United States and while not allowed into the human food chain, are allowed into the normal inedible rendering stream.

FSIS Response:

The US Food and Drug Administration (FDA) stopped allowing ruminant meat & bone meal to be fed to ruminants in 1997. In beef slaughter facilities, prior to 2008, all of the SRMs could go to rendering, and then the rendered material could be fed to non-ruminants. After the 2008 rule, brain and spinal cord from cattle 30 months and older have to be disposed of by some non-feed method, and the remaining rendered material is still fed according to the 1997 rule (to non-ruminants). Today, most slaughter facilities vacuum out the brain and spinal cord of their 30 month & older cattle, into a container (a tank or mini-bulk) and once full the tank usually goes to the landfill. The effectiveness of the US feed ban was taken into consideration by the OIE as part of the process to determine the BSE risk category of the US. The US was classified as having negligible risk for BSE on May 28, 2013.

The auditors found inconsistent controls in place to ensure that exteriorized brain tissues falling from OTM animals' stunning hole onto the floor are not directed into the SRM stream. Of the three beef slaughter establishments observed, one establishment vacuumed the heads of OTM animals and corked the stunning hole, a second vacuumed the head of OTM animals but did not plug the stunning hole; and a third did not apply either of these controls.

FSIS Response:

Composition and standards for inedible blood meal are under FDA and APHIS jurisdiction, not FSIS. FDA indicates when the Canadians implemented their enhanced feed controls, they interpreted their SRM definition to include drippings from the nasal cavity and stun hole. Ultimately, standards for inedible blood are not under FSIS jurisdiction.

CFIA Follow-up:

FSIS is requested to coordinate a response with FDA/APHIS to provide assurances that inedible dried bovine blood and blood meal products exported to Canada meet Canadian import requirements. Please refer to the CFIA's Animal and Public Health Import Requirements for Rendered and Inedible Products (January 8, 2013).

CFIA import policy regarding inedible dried bovine blood and blood meal products from the U.S. requires Official Zoosanitary Export Certificate stating that their blood collection method prevents contamination of blood with SRM (such as CNS from OTM cattle). FSIS is requested to make appropriate amendments in the export library.

The auditors also learned that of all the beef establishments visited, none had validation evidence to establish that all dorsal root ganglia of animals over thirty months was being removed from the edible and inedible meat streams either prior to or at the time of boning. It was explained that the boning practices were a control measure for the related BSE hazard.

FSIS Response:

FSIS' position is that dorsal root ganglia (DRGs) are known to be closely associated with the beef vertebral column and that hand and equivalent boning procedures do not pose a significant risk for introducing SRMs into edible product. FSIS has indicated a willingness to study this further [FR Notice 03-025F - July 13, 2007].

FSIS requirements in 9 CFR 318.24 prohibit the use of SRM vertebral bones in production of beef Advanced Meat Recovery (AMR) product and preclude any amount of CNS and ganglial tissue in AMR product (i.e. meat). Although FSIS HACCP and SSOP requirements already require establishments to validate and maintain programs to ensure effectiveness, FSIS has not determined that there is a significant risk to public health and a basis for IPP to expect more from establishments regarding DRG.

CFIA Follow-up:

FSIS is requested to provide the validation demonstrating that hand boning and equivalent boning procedures do not pose a significant risk of introducing SRMs into edible product. They are also requested to share with CFIA the status of the proposed study [FR Notice 03-025F - July 13, 2007] on the above subject.

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