analyzing effectiveness of program activities
• Procedures for sampling product for contamination
• Methods of risk assessment
• Packaging and labeling requirement directly related to food safety
Initial In-Country Approvals Required
A significant aspect of imported meat and poultry products that many people may
not realize is that individual establishments cannot make application to the FSIS to
export their products to the United States. The establishment must first make a
request to the inspection officials in its respective country. The government of the
country then must make a formal written request to the FSIS stating its desire to
become eligible to export meat or poultry products to this country.
A Recent Case of Import Inspection Gone Right
In early November 2007, the U.S. Department of Agriculture’s Food Safety
and Inspection Service (USDA FSIS) instituted additional import requirements for
meat and poultry products from Canada, including increased testing for
Salmonella, Listeria monocytogenes and E. coli O157:H7 and increased levels of
reinspection by FSIS at the U.S. border. FSIS also announced that it would
immediately audit the Canadian food safety system, focusing on Ranchers Beef,
Ltd. and other similar establishments exporting beef to the U.S., based on information provided by the Canadian Food Inspection Agency (CFIA).
FSIS had previously identified this Canadian plant, which has ceased operations, as a likely source of the multi-state outbreak of E. coli O157:H7 infections
linked to the Topps Meat Co. As the result of that recall investigation, FSIS delisted Ranchers Beef, Ltd., Canadian establishment number 630, on Oct. 20, 2007,
due to unsafe practices and inadequate testing.
The agency stated, “These measures are being taken to further ensure the
equivalency of the system already in place. We continue to work together with
our food safety partners both domestically and internationally to ensure imported
meat and poultry products are produced under systems at least equivalent to
those in the United States.”
By Nov. 27, however, William James, Acting Assistant Administrator of FSIS’s
Office of International Affairs, issued a letter to William Anderson, CFIA’s Director
Meat Programs Division, advising that FSIS would “resume normal levels of product examinations of exported Canadian meat and poultry products, and pasteurized egg products at U.S. import houses,” as well as normal levels of testing for
Listeria monocytogenes and Salmonella in ready-to-eat products.
“FSIS will continue testing of raw ground beef, raw beef manufacturing trim,
boxed beef, and subprimals normally sent for grinding for E. coli O157:H7,”
James wrote. “Testing for E. coli O157:H7 will proceed at levels to be determined
after completion of an analysis of eligible imported beef products from all equivalent countries.”
James stated that two audits were completed under the FSIS reinspection
program. One audit reviewed investigative actions by the Canadian Food
Inspection Agency of unsafe practices of Ranchers Beef,
and recall events associated with that establishment. A
second audit conducted a follow-up review of seven
Canadian establishments that were either delisted or
received Notices of Intent to Delist during FSIS’ May
1-June 6, 2007, audit of Canada’s inspection system,
and reviewed beef slaughter establishments similar
to Ranchers Beef with regard to start-up and operations. “The audits indicated the unsafe practices in
Ranchers Beef were not employed by other establishments,” James wrote, “and that corrective actions were in
place in the seven establishments identified in the audit earlier
this year. Additionally, the increased testing has not revealed any
problems with Canadian products exported to the United States.”
FSIS responds by providing the foreign officials with information describing all the food safety requirements
applied to domestically produced meat
and poultry products. At this point, the
country is requested to provide a written description of its meat and/or poultry inspection program. Separate reviews
are conducted for meat (beef, pork,
lamb and goat) and poultry (chicken,
turkey, ducks, geese and ratites) because
there are separate U.S. laws for regulating the two classes of animals. A country wishing to export both meat and
poultry products would undergo a separate review for each. To assist the country in identifying what information to
provide, FSIS sends a series of questions
addressing the control of animal diseases, sanitation procedures, slaughter
and processing controls, microbiological
and chemical residue prevention programs, and the mechanisms in place to
enforce their respective laws and regulations, as well as to prevent economic
fraud.
It is important to point out that the
animal disease review conducted by
FSIS is separate from the animal health
review conducted by the USDA’s
Animal and Plant Health Inspection
Service (APHIS). The FSIS review
focuses primarily on zoonotic diseases
and the health of animals when they are
presented for slaughter while the
APHIS review focuses on preventing
the introduction of animal diseases into
the U.S. Meeting all U.S. requirements
in both programs is mandatory for
exporting to this country.
FSIS technical experts (and outside
experts if necessary) review the country’s submission and assess the adequacy of its inspection program.
Frequently, it is necessary for the country to provide additional data to further
clarify their legal requirements, operating procedures, and so on.
If the technical experts determine
that the information submitted by the
exporting country demonstrates their
meat or poultry inspection program
provides the same level of protection,
FSIS will send a team of experts to the
country to conduct an on-site inspection. The purpose of this audit is to provide first-hand verification that the pro-
