According to USDA’s Food Safety and Inspection Service (FSIS), foreign countries that export meat, poultry, and egg products to the United States are required to establish and maintain inspection systems that are equivalent to those of the United States. FSIS audits foreign inspection systems and re-inspects meat and poultry at the port-of-entry to ensure that foreign countries have maintained equivalent inspection systems.
But with budget cuts and an outdated system, is the FSIS system working? And can we count on other countries to uphold U.S. standards?
FSIS’ 2013 plan for inspections was lofty, but for the most part, unmet. The plan for trim and other raw ground beef components from imports included 850 inspections, but only 470 were actually done. Imported intact products were scheduled to have 2,200 inspections in 2013, but only received 870. Despite the lack of inspections, FSIS maintains it has strict standards for imports.
FSIS makes two types of equivalence determinations: determinations of initial equivalence (termed “eligibility”) for countries that are not yet trading partners, and determinations of whether equivalence is being maintained by countries that are currently eligible.
Foreign countries go through a review process before they become eligible to export meat, poultry, or egg products to the United States. Countries are not required to adopt an identical inspection system, but it does have to be an equivalent one. The evaluation of a country’s inspection system to determine eligibility involves two steps: a document review and an on-site audit.
The document review is an evaluation of the country’s laws, regulations, and other written information, focusing on five risk areas:
• sanitation controls;
• animal disease controls;
• slaughter and processing controls;
• residue controls; and
• enforcement controls.
But the two-part review still does not guarantee a country is in with their exports. The process then is posted in the Federal Register for public comment before a final decision is made. Once a final rule is issued, that foreign country’s inspection system is then responsible for certifying individual exporting establishments to FSIS and for providing annual re-certification documentation. According to FSIS, after a final rule, it continues with regular on-site inspections.
Foreign inspection certificates are required to accompany all imported meat, poultry, and egg products. These certificates must indicate the product name, establishment number, country of origin, name and address of the manufacturer or distributor, quantity and weight of contents, list of ingredients, species of animals it was derived from, and identification marks. The certificate must also bear the official seal of the foreign government agency responsible for the inspection, along with the signature of an agency official. This certificate must be in both English and the language of the foreign country.
U.S. Customs and Border Protection
Importers of any merchandise into the United States must file an entry form with U.S. Customs and Border Protection (CBP) within five working days after the shipment arrives at a U.S. port-ofentry. For meat and poultry shipments, FSIS requires that two additional documents—the original certificate from the country-oforigin indicating the product was inspected and passed by the country’s inspection service and is eligible for export to the United States, and an import inspection application and report. CBP also requires the importer to post a bond, usually an amount to cover the value of the shipment plus duties and fees. Meat and poultry shipments remain under bond and subject to recall by CBP until FSIS notifies them of the results of the re-inspection.
According to FSIS, upon arrival at a U.S. port-ofentry, all meat and poultry shipments must be re-inspected by an FSIS import inspector before they are allowed into this country. Every lot of product is given a visual inspection for appearance and condition, and checked for certification and label compliance.
In addition, the Automated Import Information System (AIIS) assigns various other types of inspection including product examinations and microbial and chemical laboratory analysis. Egg products are reinspected at the facility where they are taken for further processing. About 65 FSIS inspectors carry out re-inspection at approximately 150 official import establishments.
Shipments that pass reinspection are allowed to enter U.S. commerce and are treated as domestic product. Shipments from all countries except Canada are stamped with the official USDA mark of inspection. Canadian shipments carry the Canadian mark of inspection and an export stamp. If a shipment does not meet U.S. requirements, the containers are stamped “U.S. Refused Entry,” and within 45 days must be exported, destroyed, or converted to animal food, if an appropriate request for diversion is approved by FDA.
Residue and microbial testing
In order to export to the United States, a foreign country must have a residue control program with standards equivalent to U.S. standards. Statutes require that foreign residue control programs include:
• random sampling of animals at slaughter;
• the use of approved sampling and analytical methods;
• testing of appropriate target tissues for specific compounds; and
• testing for compounds identified by the USDA or the country-of-origin as potential contaminants.
FSIS randomly samples meat, poultry, and egg products for violative chemical residues under the National Residue Program. The compounds included in the import residue plan reflect the testing done in the U.S. domestic residue program. FSIS can initiate a special sampling plan when there is a need to monitor a country for residues of a specific compound, based on detection of violative residues at U.S. port-of-entry or other information concerning risk to human health. Decisions about product acceptability are based on U.S. tolerances or action levels.
Microbial testing is also conducted on imported meat and poultry products. The microbial testing plan for imported products, like that for residues, is modeled after the microbial testing plan for domestic products. Assignment for sampling product lots is generated through the AI- IS. Different products are tested for different pathogens:
• Ready-to-eat meat and poultry products are subject to testing for Listeria monocytogenes and Salmonella at a random rate.
• Dried and semi-dried fermented sausages are randomly sampled for E. coli O157:H7, Listeria monocytogenes, Staphylococcus aureus, enterotoxin and Salmonella.
• Raw ground beef and raw ground beef components are randomly sampled for E. coli O157:H7. Random samples from each production lot of imported, pasteurized egg products are tested for Salmonella. In addition, pasteurized, liquid egg products in small, intact containers (up to 5 pounds), that bear a shelf life claim may also be tested for Listeria monocytogenes. Unpasteurized egg products are subject to random testing for the presence of residues only. Additional testing could be initiated if a public health problem is identified.
If a residue or microbial violation occurs in meat, poultry or egg products, the frequency of inspection is increased for all shipments of similar product from the violative foreign establishment until a record of compliance is re-established.
Inspection of product labels
FSIS import inspectors check labels on both shipping containers and retailsize packages. Labels on retail packages of meat or poultry shipped to the United States must meet U.S. labeling requirements. Product labels must be in English and must include:
• product name;
• foreign establishment number and country-of-origin shown directly under the product name;
• name and address of the manufacturer or distributor;
• net quantity of contents in pounds and ounces or liquid measure;
• list of ingredients; and
• if applicable, safe handling instructions and nutrition information.
Despite U.S. regulations, some countries are having their own packing regulation nightmares, which could feed into the growing price of protein products.
Moves to deregulate meat inspection are placing both consumers and New Zealand’s export reputation at risk, according to news reports.
The lead story in Metro’s March issue, Scandal in the Slaughterhouse, chronicles a three-year battle between government-employed inspectors and meat packing companies.
Using leaked documents and first-hand accounts, journalist Max Rashbrooke shares a series of food safety violations in the nation’s packing industry, along with mistakes and failures on the part of the government.
According to his report, a number of meat shipments from New Zealand have been rejected by the U.S., raising fears that the meat industry there could suffer a crippling export blow.
The revelations in Metro’s story include: Meat companies are being allowed to inspect their own product for things like fecal contamination.
Inspectors employed by meat companies are being given financial incentives not to slow down production by identifying contaminated meat.
The Ministry of Primary Industries (MPI) allowed company-employed inspectors on the job with just two days’ training, as opposed to the 20 weeks that government inspectors have.
MPI failed to inform export markets about key details of the new system.
In one incident, an unqualified worker was allowed to inspect carcasses—and MPI may have misled the European Union when it inquired about the incident.
Poorly trained companyemployed inspectors are unable to do the job properly, leading to numerous incidences of diseases and defects being missed.
Checks on company-employed inspectors are being manipulated so that their failures are not picked up.
The remaining government inspectors are being pressured not to raise their concerns.
Since 2012, seven shipments of New Zealand meat have been rejected by the U.S. for having fecal contamination.
It’s not unusual to read bits and pieces on Australian animal welfare problems, but the industry maintains a beef processing plan that is praised by most countries. All Australian Export Beef packing plants are regulated by the Australian government through the Australian Quarantine and Inspection Service (AQIS).
To help meet the growing animal welfare expectations, the processing industry developed the Australian Livestock Processing Industry Animal Welfare Certification System (AAWCS).
The AAWCS is an independently audited certification program used by Australian livestock processors to demonstrate compliance with the industry best practice animal welfare standards, titled the “Industry Animal Welfare Standards for Livestock Processing Establishments Preparing Meat for Human Consumption.”
The AAWCS covers all animal welfare activities at a participating livestock processing establishment— from reception of livestock at the establishment to the point of humane processing.
Other beef exporters are facing political nightmares.
While Russia is in the midst of a crisis with Ukraine, the country may be adding to the growing problems with the end of Ukraine imports, and even possible sanctions from other countries. According to Russian Agriculture Minister Nikilai Fyodorov, there is a possibility that Russia will stop the import of all meat and food products from Ukraine, in part because of the political instability.
In addition, according to one of the largest meat processors in the country, Cherkizovo, the Russian meat processing industry is highly fragmented and suffers from overproduction at the lower end of the market. In 2012, the company sold 127,403 tons of meat products.
According to a report from Agrorucom, “Growth in production of cattle for slaughter in 2016 will equate to 4.5 percent” in the country. But labor problems are expected to continue in the country, which could add to meat production woes.
Russia banned most meat imports from the U.S. last year because of the feed additive ractopamine. New reports are coming in that Russia is asking for more guarantees before they will lift the bans. “Imports from these two plants will be resumed as soon as the issue with refrigerators, from which supplies are due to come, is resolved,” Russia’s veterinary and phytosanitary watchdog (VPSS) spokesman Alexei Alekseenko said. — Traci Eatherton, WLJ Editor