NOV O 9 2017
Dr. Odilson Luiz Ribeiro e Silva
Under Secretary of the Office of International Affairs (SRI) Ministry of Agriculture, Livestock and Food Supply (MAPA) Esplanada dos Ministerios, Bloco D, Edificio Sede, 3° andar, Sala 300 70.043-900 Brasilia, DF BRAZIL
Dear Dr. Ribeiro e Silva,
Enclosed is a copy of the final audit report for the FSIS onsite audit conducted from May 15 through June 2, 20 17. The comments received from the Government of Brazil are included as an attachment to the report.
FSIS continues to evaluate your response to the FSIS audit as part of its overall assessment of Brazil's meat inspection system to assure that it remains eq~valent to that of the United States. In addition to Brazil's actions in response to the FSIS audit findings, FSIS posed questions regarding Brazil's raw beef and thermally processed, commercially sterile inspection system. FSIS posed these questions, in part, because of trends in point of entry violations indicating potential systematic issues and the subsequent suspension of raw beef exports.
The answers to these questions and FSIS's audit findings will guide the scope and frequency of future equivalence verification activities. Future verification activities may include additional in-country audits and increased frequencies at which FSIS reinspects products from Brazil at the United States point-of-entry. If you have any questions, please feel free to contact me directly at firstname.lastname@example.org.
Executive Summary This report describes the outcome of an onsite equivalence verification audit conducted by the Food Safety and Inspection Service (FSIS) from May 15 to June 2, 2017.
The purpose of the audit was to determine whether Brazil's meat inspection system remains equivalent to that of the United States, with the ability to export products that are safe, wholesome, unadulterated, and correctly labeled and packaged. At the time of this audit, Brazil was approved to export raw intact, ready-to-eat (RTE), not ready-to-eat (NRTE) processed, and thermally processed, commercially sterile (TPCS) meat.
The audit focused on six system equivalence components:
(1) Government Oversight (e.g., Organization and Administration);
(2) Government Statutory Authority, Food Safety, and Other Consumer Protection Regulations (e.g., Inspection System Operation, Product Standards and Labeling, and Humane Handling);
(3) Government Sanitation;
(4) Government Hazard Analysis and Critical Control Points (HACCP) System;
(5) Government Chemical Residue Testing Programs; and
(6) Government Microbiological Testing Programs.
The FSIS auditors identified the following systemic findings: Government Oversight
The Central Competent Authority (CCA) has not developed policies and procedures to identify potential areas where conflicts of interest could arise between inspection personnel and the regulated establishments where they work;
The CCA does not verify that regulatory information provided to supervisory official veterinarians is consistently communicated to their subordinates;
The CCA does not verify that in-plant inspectors perform their assigned duties in a manner that is consistent with the issued instructions; and
The CCA has not developed procedures to standardize the assessment of competence and performance of in-plant inspection personnel assigned to United States-certified establishments.
Government Statutory Authority and Food Safety and Other Consumer Protection Regulations
The implemented post-mortem inspection procedures are inadequate to ensure that only wholesome carcasses, free of contamination and defects receive the mark of inspection;
Brazilian TPCS product reinspected at United States point-of-entry demonstrates a trend of abnormal container violations; and
Higher-level officials did not adequately review and follow-up on periodic supervisory reports and plans of action. Government Sanitation
Inspection personnel do not adequately enforce sanitation regulatory requirements to prevent the creation of insanitary conditions and direct product contamination. Government HACCP System
Inspection personnel do not accurately assess the design and implementation of the establishments HACCP systems, and do not conduct adequate verification sampling of products. Government Chemical Residue Testing
The official methods of chemical analysis used by the government laboratories is inconsistent with FSIS requirements; and
The CCA has not instructed establishments and in-plant inspectors to hold livestock carcasses selected for residue sampling until acceptable results are received.
During the audit exit meeting, the CCA committed to address the preliminary findings as presented. FSIS received a written response from the CCA addressing all outstanding concerns identified in the draft final audit report. FSIS will evaluate the adequacy of the proposed corrective actions and base its activities for future equivalence verification on the information provided.
International CoordinationLExecutiv0 Office of International Coordination
BSE SRM AND HACCP
BSE MRR policy, a free pass to trade Transmissible Spongiform Encephalopathy TSE Prion aka mad cow disease around the globe...tss
Regions classified by APHIS as having either negligible risk or controlled risk for Bovine Spongiform Encephalopathy (BSE)
9 CFR 92.5
Regions of negligible risk for BSE
LOL! (laugh out loud) pot calling kettle black...tss
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