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Management Response and Action Plan (MRAP): Meat Programs Evaluation

The Evaluation of the Meat Programs (2016) focussed on the operation of the Meat Programs (Meat and Poultry products) over the five-year period from 2009-2014, and assessed domestically produced and distributed products, exported products, imported products, and recalls.

The Management Response Action Plan (MRAP) to the Evaluation of the Meat Programs (2016) proposes 15 actions, integrated into the ongoing Agency Transformation and Improved Agency Inspection Modernization initiatives, designed to address the six opportunities for improvement in program efficiency and risk-based programming identified in the Meat Programs Evaluation.

Summary of the Meat Programs MRAP
Evaluation Recommendation Action Plan and Target Date(s)
1. For those HACCP plans evaluated by inspectors as unacceptable, the CFIA should clarify which represent serious issues. The CFIA will consider how categorization of non-compliance may be incorporated into the ongoing integrated Agency Inspection Modernization (iAIM)-related activities described in the Action Plan for Recommendation #5, in order to facilitate program reporting and management. Prior to full-scale implementation, a preliminary study will be conducted in 2018. The impact of the categorization for non-compliances will be assessed once sufficient data have been collected via the Action Plan activities of Recommendation #5 to support an evaluation (estimated spring 2019).
2. To improve meat program efficiency, there should be less emphasis on carcass-by-carcass inspection in slaughter inspections done by the CFIA. The CFIA will continue to work closely with stakeholders on a modernised approach to the manner in which hog carcass-by-carcass inspection is performed. This includes a pilot project in hog slaughter inspection in winter 2017.
3. In import inspections, organoleptic (sensory) inspections should be reduced or eliminated. The CFIA will update inspection procedures to take a more risk-based approach to the organoleptic verification of products. Updated inspection procedures will be implemented in winter 2018.
4. The CFIA should coordinate its performance measurement reporting for its meat programs to provide comprehensive results reporting. The CFIA will coordinate performance measurement reporting for its meat programs, synchronizing the new centralized approach with CFIA's implementation of both the new Federal Policy on Results and CFIA's Program Management Framework in spring 2018.
5. The CFIA should increase the degree to which CVS tasks are based on risk, including the historical compliance record. The CFIA is conducting research and consulting with stakeholders to identify and implement improvements to the incorporation of risk information in the inspection of meat and poultry products by 2018/2019.
6. The CFIA should examine opportunities to provide increased flexibility in the delivery of Daily Shift Inspection Presence requirements. The CFIA will conduct research and consult with stakeholders to evaluate the feasibility of taking a more risk-based approach to core food safety activities while continuing to satisfy export requirements. Preliminary analysis and decisions on next steps will be made by summer 2018.

Evaluation: Meat Program
Evaluator: CFIA Audit and Evaluation Branch, Evaluation Directorate
CFIA Program Area: Food
Report Approved by Evaluation Committee: March /2017

Recommendation 1 - For those HACCP plans marked by inspectors as unacceptable, the CFIA should clarify which ones represent serious issues.

Management Response: Agree.
Management Response (Agree or Disagree and if Disagree, reason why) Action Plan and Target Date Lead

CFIA Management agrees with the recommendation.

CFIA requires all non-conformities in HACCP plans to be addressed and recognizes the need for improvement. This will help CFIA to better report on sector performance, and to manage non-compliances on the basis of their risk.

CFIA has started implementing the Integrated Agency Inspection Model (iAIM) in its inspection activities to improve the consistency of activities. A crosswalk between the Safe Food for Canadians Regulations (SFCR) and CVS tasks will be developed once SFCR comes into play. Once iAIM is fully implemented a full review will be conducted and changes made where required.

  1. Investigate how iAIM procedures can better differentiate between a HACCP plan non-conformity that is potentially serious vs one that is less serious, in order to facilitate reporting and management.
  2. Wave 3 of iAIM will incorporate categorization of non-compliance. The Standard Inspection Procedure has been updated and sent for translation.
    Target date: Q3 2017/18
  3. An alignment document will be developed to link relevant sections of the SFCR and CVS tasks.
    Target date: Q2 2018/19
  4. Investigate impact to iAIM after CVS Updates have been implemented and data has had time to be collected, reviewed and analyzed.
    Target date: Approximately 1 year post CVS

    Update implementation

National Inspection Division, Operations

Recommendation 2 - To improve meat program efficiency, there should be less emphasis on carcass by carcass inspections in slaughter inspections done by the CFIA.

Management Response: Agree.
Management Response (Agree or Disagree and if Disagree, reason why) Action Plan and Target Date Lead

CFIA Management agrees with the recommendation.

The outcomes of CFIA's meat program can be achieved in a more effective and efficient way by modifying the manner in which carcass by carcass inspection is performed.

CFIA is looking at amending the approach to current hog carcass inspection. These changes would allow CFIA to focus more on food safety concerns during carcass inspection instead of routine defect detection. Such changes would align with similar initiatives currently implemented by some of our major trading partners.

Explore a modernized slaughter inspection approach for hogs in 2017-2018.

  1. CFIA's Domestic Food Safety System Directorate already completed work on new procedures in 2016.
  2. The Agency is testing the procedures through a pilot in Winter 2017. CFIA will work with employees and other stakeholders to address any potential concerns and ensure readiness.
Domestic Food Safety Directorate, PPB

Recommendation 3 - In import inspections, organoleptic (sensory) inspections should be reduced or eliminated.

Management Response: Agree.
Management Response (Agree or Disagree and if Disagree, reason why) Action Plan and Target Date Lead

CFIA Management agrees with the recommendation.

Routine organoleptic re-inspection of imported meat products that have already been verified and certified for export to Canada by an accepted foreign meat inspection authority is of limited usefulness. Reducing the number of these inspections can maintain food safety, while freeing up inspection capacity to focus on areas where risks can be effectively reduced.

  1. Revise import inspection procedures to reduce the reliance on systematic/routine organoleptic verification of products (clarify when inspectors should exceptionally conduct a full organoleptic verification).
    Target date: June 2018
  2. Implement the new procedures.
    Target date: December 2018
Food Import Export and Consumer Protection Directorate

Recommendation 4 - The CFIA should coordinate its performance measurement reporting for its meat programs to provide comprehensive results reporting

Management Response: Agree.
Management Response (Agree or Disagree and if Disagree, reason why) Action Plan and Target Date Lead

CFIA Management agrees with the recommendation.

Bringing together performance information currently collected by various parts of the agency will enable the Agency to improve how it assesses its overall performance and reports on this.

CFIA is currently working on a one-food program performance measurement approach and framework that will bring food program performance information into a single central program performance node for assessment and reporting. The node will be located in the Domestic Food Safety Directorate.

  1. Establish an inventory of current meat program performance measures and reports, and identify the organizational groups who currently populate the indicator information/reports.
    Target date: Q1 2017/18
  2. Maintain accountability for collecting and preliminary analysis of current meat hygiene performance measures with current owners, and have this information forwarded to the Domestic Food Safety System Directorate's Performance Measurement team for compilation, overall analysis, and consolidated reporting out.
    Target date: Q3 2017/18
Domestic Food Safety Directorate, PPB

Recommendation 5 - The CFIA should increase the degree to which CVS tasks are based on risk, including the historical compliance record.

Management Response: Agree.
Management Response (Agree or Disagree and if Disagree, reason why) Action Plan and Target Date Lead

CFIA Management agrees with the recommendation.

CFIA is researching changes to inspection to incorporate risk information to improve the selection of risk controls and the tasking of work. Such a risk-based approach means that inspection effort and attention is focussed on those items and places where it has the greatest positive impact.

  1. Operations Branch is creating CVS updates for its meat processing establishments
    Target date: Q Q3/4 2017/18 and Q1 2018/19
  2. Once CVS Updates has been approved and all consultations completed implementation in meat processing establishments will start.
    Target date: Q3/Q4 2017/18 and Q1 2018/19
  3. CFIA is in the data collection phase of the Establishment Risk Based Assessment Model (ERA) in facilities producing meat products [ERA informs the frequency and intensity of inspection activities for food facilities inspected by the CFIA, depending on the facility's risk profile].
    Target date: Q4 2018/19
National Inspection Division, Operations

Recommendation 6 - The CFIA should examine opportunities to provide increased flexibility in the delivery of Daily Shift Inspection Presence (DSIP) requirements.

Management Response: Agree.
Management Response (Agree or Disagree and if Disagree, reason why) Action Plan and Target Date Lead

CFIA Management agrees with the recommendation.

CFIA Management considers that meat program outcomes may be achievable under a risk-based system that does not require a systematic CFIA inspection of each individual facility on a per-shift basis.

It is acknowledged that certain foreign authorities (e.g., the USDA Food Safety Inspection Service) operate under legal constructs that require a per-shift inspection in all meat facilities producing for the US market

  • CFIA will continue to work with USDA under the auspices of the Regulatory Cooperation Council to advance work in this specific area.
  • CFIA will also explore the option of conducting separate risk-based activities for core food safety purposes vs activities done on a per-shift basis solely in order to satisfy this export requirement.
  1. Evaluate the feasibility of doing risk-based inspections (vs DSIP) less frequently than at least once per-shift in meat processing plants that are not producing for the US market.
    Target date: Q1 2018/19
Domestic Food Safety Directorate, PPB
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