Food > Meat and Poultry Products > Manual of Procedures > Chapter 11  

ANNEX D

SUBJECT:

Frequency of visits to free-standing meat processing plants eligible to export to the U.S.

The following procedures apply to all free-standing meat processing plants that are eligible to export to the U.S. This information was originally sent out in the form of a memorandum dated August 19, 2005.

1. Changes to the Frequency of inspection in registered meat processing establishments:

The United States Department of Agriculture (USDA), Food Safety and Inspection Service (FSIS) has indicated to the Canadian Food Inspection Agency (CFIA) that it does not consider the CFIA Frequency of Inspection Level (FOIL) system to be equivalent to US measures. The FSIS has indicated to the CFIA that it does not consider that products produced under FOIL pose an increased public health risk - nonetheless, the FSIS is requiring daily visits in facilities because of a legal interpretation indicating that daily visits must be performed to satisfy the US regulatory requirement for ‘continuous inspection’. Establishments where slaughter operations are taking place are considered to be under such inspection on days when slaughter takes place - on days where there is no slaughter, these plants are considered as free-standing processing plants and will need to have a CFIA visit.

The CFIA has been provided until August 22, 2005 to undertake action according to the following plan:

Immediate Action (upon receipt of this memorandum)

• CFIA inspectors in free-standing processing facilities to consult with their supervisor and, re-arrange their work schedules to increase the frequency of visits as much as possible to daily.

Short-term (by September 12th, 2005)

• CFIA inspectors to be trained and begin use of streamlined Multi-Commodity Activities Program (MCAP) Inspection procedures. The changes will provide more flexibility for scheduling and reporting of inspection activities and visits.
• Daily inspection visits to take place in affected establishments, with limited exceptions, by this time.

Medium term (before January 2006)

• A critical review of MCAP-Inspection tasks to be performed - streamline and reduce tasks if possible and validate the number of hours required per week to inspect free-standing meat processing plants.

Long term (no later than June 30, 2007)

• A scientific study will be designed and performed in order to provide the necessary evidence in support of less than daily inspections in free standing meat processing plants.

2. Changes to the MCAP-Inspection Guide:

With regards to the proposed changes to the MCAP-Inspection Guide, these consist of:

• The period of an individual MCAP inspections changes from a "per visit" to a "per week" basis. Thus, each inspection will now last the entire scheduled week (and, if necessary, any additional days of operation requested by the operator and approved by the CFIA) - note that the amount of time expected to be spent in the plant does NOT change as a result of this modification;

• MCAP tasks that are currently scheduled in meat processing plants as "once per visit" ("V" frequency) are now scheduled as "once per week" ("W1" frequency); the frequency of tasks scheduled less frequently [for ex., "once every 2 weeks", "once a month", etc.] does not change;

• A Daily Attendance Register (ref. attached) will have to be completed by the inspectors to indicate any visit at the establishment. This information will have to be compiled by the Areas in order to provide a quarterly update report to FSIS as required. This will have to be done until the MCAP Facility module can be modified to capture, track and report this information.

The inspector and their supervisor are to schedule their inspection and other official CFIA activities in the plant to ensure that :

• an inspector has visited the plant at least once a day¹ during the week; and
• for each individual shift, all of the assigned (weekly and other) tasks for the inspection-week have been completed

Note¹
"Once a day": only if the plant is eligible to export to the USA; otherwise, the establishment should still have inspection visits 2, 3 or 5 times per week depending on their overall compliance rating.

Specific changes for stand-alone meat processing plants:

• At the beginning of the week, the inspector creates a single MCAP inspection, and prints off the Inspection Worksheet. The inspector leaves the MCAP inspection open in the computer until the end of the week (e.g., open Monday, close Sunday).

• The inspector records the results of the daily visits on the Inspection Worksheet and, usually, only needs to input data into the MCAP system at the end of the week;

  • Tasks rated 1 or 2: The data could be entered at the end of the week and the inspection date could be the specific day where the task was done or the end of the week if the task was evaluated throughout the week.

  • Tasks rated 3, 4 or 5: The inspection date in the system must correspond to the actual date where the deficiency was noticed.

• If there is an immediate need to generate an "Outstanding Task Report" (i.e., when a task is rated 4 or 5), the inspector generates the report on the day of that particular visit.

  Notes: In case of multi-shift establishments, a separate inspection must be created each week for each approved work shift.

Specific changes for slaughter plants with processing activities:

• The inspector creates an MCAP inspection on a daily basis
• These inspections will include all the slaughter, prerequisites and export (if applicable) tasks;
• Processing activities will be evaluated at the same frequency as in stand-alone processing establishment (i.e., once / week) - the inspector will have to select or deselected the tasks as required in MCAP.

3. Changes to FSEP audit procedures:

With regards to FSEP audit procedures, depending on the type of audit or verification now being performed, the following changes apply:

A. Registered Establishments currently undergoing or scheduled for FSEP recognition:

• No changes are planned to FSEP activities in these establishments
• Note that activities undertaken under FSEP recognition should be credited against the requirement for daily CFIA presence in the facility.

B. Registered Establishments that are FSEP recognized and scheduled for FSEP partial audits:

• No changes are planned to FSEP activities in these establishments, i.e., the audits will continue to take place on a quarterly basis as planned.
• The CFIA inspector participates in these audits, to the extent possible
• Note that activities undertaken under FSEP partial audit and any related follow-up should be credited against the requirement for daily CFIA presence in the facility.

C. Registered Establishments that are FSEP recognized and where FSEP "mini-audit" verifications are taking place:

• The "mini-audit" verifications continue to take the place of the MCAP food safety related inspection activities but the time scale of the overall audit is changed from one month to one quarter;

• During daily visits to the plant, if the inspector identifies a non-compliance food safety issue (prerequisites or CCPs), they are to deal with it as described in the FSEP Verification policy. Non-food safety items are managed under MCAP as before.

• The audit report is completed at the end of the quarter and provided to the operator as is now being done. The Establishment Inspection Reports (CFIA/ACIA 1427) for the other months in the quarter are generated as before in such plants, only the form will indicate in the comments box that "the tracking of all food safety related compliance issues is done through the FSEP audit report for the quarter which will be attached to the report for the month at the end of the quarterly audit".

It is emphasized that inspectors are not being asked to modify the overall amount of time spent performing inspection activities in registered establishments, but to optimize this time by scheduling their visits to facilities in the most efficient manner possible. Doing so will allow the CFIA to meet this new export requirement in the least disruptive manner possible.

If you have any questions regarding these instructions, you should first contact your immediate supervisor. Supervisors should contact the area program network chief if they need additional clarification.

Annex C | Annex D | Annex D-1 | Annex E | Annex J (PDF) | Annex K (PDF) | Annex L | Annex M | Annex Q |
Annex R | Annex S | Annex T | Annex U | Annex W | Annex W-1 | Annex W-1 | Annex X | Annex Y |
Annex Z | Annex Z-1 | Annex Z-2 |