China 2013 Audit Poultry Processing Inspection System 151D
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United States Department of Agriculture Food Safety and Inspection Service Washington, D.C. 20250 Li Chunfeng Deputy Director General General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) Beijing, People's Republic of China AUG 3 0 2013 Dear Dr. Li: The Food Safety and Inspection Service (FSIS) of the United States Department of Agriculture (USDA) conducted an on-site verification audit ofthe People' s Republic of China (PRC) poultry processing inspection system from March 4-19, 2013. FSIS submitted the draft audit report on June 28, 2013 and PRC responded on August 29, 2013 with a few minor suggestions. The draft audit report was update with your suggestions. Enclosed is a copy of the final audit report for poultry processing inspection system. This report was published on the FSIS website (http://wvvw.fsis.usda.gov) on August 30,2013. As all outstanding issues have been resolved, the PRC may proceed with certifying a list of poultry processing establishments as meeting the FSIS requirements. These certified establishments may then begin exporting processed (heat-treated/cooked) poultry products to the United States under the conditions established in FSIS' April 2006 final rule; i.e. only processed poultry products produced from poultry slaughtered under FSIS inspection in the United States or in a country eligible to export slaughtered poultry to the United States. If you have any questions, please contact me at telephone number 202-720-6400, facsimile number 202-720-7990, or by e-mail at internationalequivalence@fsis.usda.gov. 9;ls~:V- Andreas Keller {:;~ Director International Equivalence Staff Office of Policy Program Development Enclosure Dr. Li Chunfeng 2 Scott SiridelaT, US Embassy, Beijing, China Ralph Bean, Acting minister Counselor for Agriculture Affairs Michael Riedel,- Senior Attache Ryan R. Scott, Agricultural Attache Morgan Perkins, F AS, North Asia Area Director Casey Bean, OASA, FAS Catherine Fulton, OASA, FAS Cecilia S. Choi, EB, State Department AI Almanza, Administrator, FSlS Carmen Rottenberg, Acting Chief of Staff, OA William C. Smith, Asst. Administrator, OlEA Jane Roth, Deputy Asst. Administrator, OlEA Vincent Fayne, Director, MCAD, OlEA Dee Dee Fumey, FSlS, OA Daniel Engeljolm, Asst. Administrator, OFO Rachel Edelstein, Assistant Administrator, OPPD Soumaya Tohamy, Deputy Asst. Administrator, OPPD Mary Stanley, Director, IPD, OPPD Ronald K. Jones, Deputy Asst. Administrator, OFO Andreas Keller, Director, IES, OPPD Rick Hanies, Director, EPS, OPPD Rita Kishore, Deputy Director, EPS, OPPD Linda Chittum, Acting Director, liD, OFO Shaukat Syed, Director, lAS, OlEA Francisco Gonzalez, lAS, OlEA Cham1aine McGee, EPS, OPPD Priya Kadam, IES, OPPD FSIS:OIA:lES:PKadam: ChinaPoultryProcessingFinalAuditReportLetter08-30-2013.docx FINAL REPORT OF AN AUDIT CONDUCTED IN TI-IE PEOPLE'S REPUBLIC OF CHINA March 4 through 19, 2013 FSIS AUDIT OF THE FOOD SAFETY SYSTEM GOVERNING THE PRODUCTION OF PROCESSED POULTRY INTENDED FOR EXPORT TO THE UNITED STATES OF AMERICA Food Safety and Inspection Service United States Department of Agriculture 1 Executive Summmy This audit report describes the outcome of an on-site corrective action verification audit conducted by the U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) on March 4-19, 2013, to determine whether the People's Republic of China's (PRC) food safety system governing poulh·y processing remains equivalent to that of the United States (U.S.), with the ability to produce products that are safe, wholesome, unadulterated, and properly labeled. This audit was necessary to assess the effectiveness of the corrective actions the PRC submitted in response to the December 1-21, 2010, verification audit. The March 2013 poultry processing audit was conducted concunetitly with an equivalence audit of the PRC's poultry slaughter inspection system, for which the observed findings are included in a separate report. Representatives from the Certification and Accreditation Administration (CNCA), China Inspection and Quarantine (CIQ) Shandong province, and USDA's Foreign Agricultural Service (FAS) accompanied the FSIS auditors during the audit. The audit focused on the ability of the Central Competent Authority (CCA), the General Administration for Quality and Safety Inspection and Quarantine (AQSIQ), to regulate processed poultry production. FSIS audited four poultry processing establishments, the CCA headquarters, and the CIQ Shandong province govenunent offices. Detenninations concerning the effectiveness of the PRC's food safety program focused on perfom1ance within the following six equivalence components: (1) Govenunent Oversight, (2) Statutory Authority and Food Safety Regulations, (3) Sanitation, (4) Hazard Analysis and Critical Control Point Systems, (5) Chemical Residue Programs, and (6) Microbiological Testing Programs. Based on the analysis of the corrective actions submitted by the PRC in response to the 2010 audit and the results of the 2013 audit, FSIS concludes that the CCA has adequately addressed all previously identified concems. Therefore, the PRC's processed poultry inspection system meets the equivalence components for FSIS equivalence criteria. Because all outstanding issues have been resolved, the PRC may proceed with certifying a list of establishments eligible to export processed (heat-treated/cooked) poultry products to the United States, as long as the raw poultry is sourced from countries that FSIS determined to have a poultry slaughter inspection system equivalent to the U.S. system. FSIS submitted the draft audit report to PRC on July 1, 2013 and PRC responded on August 29, 2013 with no substantive issues with the report. 2 TABLE OF CONTENTS 1. INTRODUCT-ION 2. AUDIT OBJECTIVE, SCOPE, AND METHODOLOGY 3. LEGAL BASIS FOR THE AUDIT 4. BACKGROUND 5. GOVERNMENT OVERSIGHT 6. STATUTORY AUTHORITY AND FOOD SAFETY REGULATIONS 7. SANITATION 8. HAZARD ANALYSIS AND CRITICAL CONTROL POINT SYSTEMS 9. CHEMICAL RESIDUE PROGRAMS 10. MICROBIOLOGICAL TESTING PROGRAMS 11. EXIT MEETING 12. CONCLUSIONS 13. ATTACHMENTS TO THE AUDIT REPORT 3 ABBREVIATIONS AND SPECIAL TERMS USED IN THE REPORT AI-IVB Animal Husbandry and Veterinary Bureau AQSIQ Administration of Quality and Supervision and Inspection Quarantine CCA Central Competent Authority (AQSIQ) CFR Code ofFederal Regulations CIQ China Inspection and Quarantine Authority (Branch and Provincial) CNAS China National Accreditation Service for Conformity Assessment CNCA Certification and Accreditation Administration E. coli Escherichia coli FSB Entry-Exit Food Safety Bureau FSL PRC Food Safety Law FSIS Food Safety and Inspection Service GB Guobiao HACCP Hazard Analysis and Critical Control Point Lm Listeria monocytogenes MOA Ministry of Agriculture MOI-l M.inish-y of Health PPIA Poultry Products Inspection Act PRC People's Republic of China RTE Ready-to-Eat Salmonella spp. Salmonella species SSOP Sanitation Standard Operating Procedures u.s.c. United States Code 4 USDA United States Department of Agriculture VIC Veterinarian-in-Charge 5 1. INTRODUCTION The Food Safety and Inspection Service (FSIS) of the United States Department of Agriculture (USDA) conducted an on-site corrective action verification audit of the People's Republic of China's (PRC) poultry processing inspection system on March 4-19, 2013. This audit was conducted simultaneously with an FSIS on-site equivalency verification audit of the PRC's poultry slaughter inspection system, for which the observed findings are included in a separate report. The audit began with an entrance meeting on March 4, 2013, in Beijing with the participation of representatives from the General Administration of Quality Supervision, Inspection and Quarantine's (AQSIQ) Central Competent Authority (CCA); the Certification and Accreditation Administration (CNCA); Inspection and Quarantine (CIQ) from the Shandong province; representatives from USDA's Foreign Agriculhiral Service (FAS) at the United States EmbassyBeijing; and the FSIS audit team. The FAS provided assistance with translations and travel logistics. 2. AUDIT OBJECTIVE, SCOPE, AND METHODOLOGY FSIS' objective for the audit was to verify that the PRC's food safety system governing poultry processing is equivalent to that of the United States (U.S.), with the ability to produce and export products that are safe, wholesome, unadulterated, and properly labeled. In pursuit of this objective and prior to the on-site verification audit, FSIS reviewed and analyzed the proffered corrective actions and accompanying references submitted by the CCA to address findings FSIS identified in the 2010 audit as not being equivalent for each of the components of the poultry processing inspection system. Representatives from the CNCA, CIQ-Shandong, and PAS-Beijing accompanied the FSIS auditors throughout the audit. Determinations concerning program effectiveness focused on performance within the following six equivalence components upon which system equivalence is based: (1) Government Oversight, (2) Statutory Authority and Food Safety Regulations, (3) Sanitation, (4) Hazard Analysis and Critical Control Point (HACCP) Systems, (5) Chemical Residue Programs, and (6) Microbiological Testing Programs. FSIS auditors evaluated the implementation of management control systems developed by the PRC to ensure that poultry inspection verification and enforcement activities are standardized. The govemment offices audited included the CCA headquarters in Beijing, and the CIQ Shandong Provincial office along with interviews of representatives from tlu·ee CIQ local offices in the Shandong province. To verify the CCA's ability to provide consistent government oversight, FSIS visited four poultry processing establislunents identified by the CCA as eligible to export poultry products to the United States. During establislm1ent visits, FSIS placed its emphasis on the CCA's ability to provide oversight of inspection personnel through supervisory reviews conducted in accordance 6 with Title 9 U.S. Code ofFederal Regulations (CFR), Part 381.196 and the in-plant inspectors' ability to verify industry compliance with the associated laws and regulations. This 2013 verification audit did not include visits to the analytical laboratories because the auditors did not report systemic deficiencies with the teclmical support of the poultry processing inspection system in the 2010 audit report. A copy of the 2010 report can be viewed on the FSIS Web site at www..f~is.usda.gov/OPP DEIFA R/China!China2010_Poult1y _Processing. pdf Audit Scope Summary Sectors Audited Central Authority Competent Authority Offices Provincial Office No. 1 Locations AQSIQ, Beijing 1 Shandong Entry-Exit Inspection and Quarantine Bureau, Qingdao Qingdao, Weifang, Dezhou 3 Local Offices • • • Poultry Processing Establishments 4 • Qingdao 9-Alliance Group, Ltd Zhucheng Waimao Co., Ltd Weifang Legang Food Co., Ltd Zhong' AO Holdings Group Co., Ltd 3. LEGAL BASIS FOR THE AUDIT AND AUDIT STANDARDS The audit was conducted under the specific provisions ofthe United States' and the PRC's laws and regulations, specifically: U.S. Poultry Products Inspection Act, Title 21 United States Code (U.S.C.) 451 , et seq.) U.S Poultry Products Inspection Regulations regarding eligibility to import to the United States (9 CFR 381.196) PRC Food Safety Law (FSL), 2009 PRC Administrative Rules on Quarantine of Animal (Decree No.6), January 21,2010 While the audit standards include applicable legislation and procedures submitted to FSIS by the PRC, this audit included a review of the proffered corrective actions submitted to FSIS by the PRC in response to the 20 I 0 audit findings as part of the of the document review and the equivalence determination process. 7 4. BACKGROUND . The PRC first requested an initial equivalence determination of its poultry processing inspection system in May 2004, for which FSIS conducted on-site audits in 2004. In 2006, FSIS determined that the PRC's poultry processing inspection system was equivalent to that of the U.S. The PRC was added to the list of countries eligible to export processed poultry to the United States with the following stipulation: processed heat-treated poultry products must be derived from flocks slaughtered under (1) the U.S. inspection system or (2) the inspection system of another country eligible to export slaughtered poultry products to the United States. Only such poultry would be permitted to be imported into the United States in accordance with 9 CFR § 94.6 (b), 9 CFR 381, and the Poultry Products Inspection Act (PPIA). This restriction is in place because USDA's Animal and Plant Health Inspection Service (APHIS) does not consider the PRC to be free of Highly Pathogenic Avian Influenza (HPAI) and Exotic Newcastle Disease (END). As a result of this APHIS animal disease status designation, exports to the United States ofraw poultry from AI and END affected regions of the PRC are prohibited. After conducting a comprehensive analysis of the PRC' s Food Safety Law 2009 and all relevant legislation supporting the PRC's poultry processing inspection system, FSIS conducted a verification audit in 2010 to reaffirm the ongoing equivalence status of the PRC's processed poultry inspection system, which is required to reinstate their export eligibility. However, there were several findings that needed corrective actions, which are detailed in the 2010 audit report (wwwfsis. usda.gov/OPP DEIFAR/China/China201 0_Poult1y_Processing.pdj). The PRC submitted corrective actions in response to th~ 2010 findings . In July 2011, the PRC submitted two manuals, Inspection Quarantine Manual for Poult1y Exported to America (IQMPES) and Microorganism Monitoring Program for Export Poult1y Products (Jv!MEPP). FSIS reviewed and analyzed the corrective actions and these manuals as a precursor to conducting the 2013 verification audit. During the 2013 audit, tl1e PRC submitted revisions to the manuals, changing the name, content, and version numbers of both manuals, while improving many sections from earlier versions. The inspection manual has been changed to Inspection Quarantine and Supervision Work for Poultry Products Exported to the US. Handboo!C' (IQSWPPEUH version 1.1). The microbe manual has been changed to Monitoring Programfor Microbes in Export Poult1y Products (MPMEPP version 1.0). FSIS auditors verified the adequacy of the coiTective actions that the CCA had proff ered in response to the 2010 audit findings and then reassessed FSIS' prior determination of equivalence for the PRC 's poultry processing inspection system. 5. GOVERNMENT OVERSIGHT The first of the six components that the FSIS auditors reviewed was Government Oversight. The evaluation included a review and analysis of corrective actions the CCA submitted in response to the 2010 audit findings. Based on the analysis of the corrective actions the PRC submitted in response to the 2010 audit and the results ofthe verification activities conducted in the 2013 8 audit, FSIS concludes that the CCA has adequately addressed the identified concerns reported for this equivalence component. Therefore, the PRC's poultry processing inspection system continues to meet-FSIS equivalence criteria for this component. In the 2010 audit, the FSIS auditors confirmed that the State Council of the PRC delegates to AQSIQ the authority to administer the poultry processing inspection system for exports. AQSIQ serves as the CCA responsible for the safety offood products, promulgation of regulations on food inspection, and the sole authority to enforce the laws and regulations governing the export system. Registration and certification of import/export food enterprises is conducted by two major bureaus of the CCA: the Certification and Accreditation Administration (CNCA) and the Entry-Exit Food Safety Bureau (FSB). These bureaus verify that establishments fulfill official requirements before they grant the establishments' certification to export. Funding for CCA operations is provided by the central government and supplemented by fees assessed by the goverrunent on exported products. The auditors also determined that the PRC Ministry of Agriculture (MOA) and the Ministry of Health (MOH) interact with the CCA to maintain appropriate regulation of the production of poultry products for export. Under tllis arrangement, the China National Accreditation Service for Conformity Assessment (CNAS) and the CCA, have promulgated the national standard that provides the general requirements for laboratory quality systems. FSIS auditors observed that the CCA delegates to inspection and quarantine bureaus (CIQ) located throughout the country the responsibility to implement inspection of animals and animal products and to regulate poultry processing activities at establislunents producing products for export. The organizational structure for the delegation of authority has not changed since the 2010 audit. In the 2010 audit, tl1e auditors reported that the CCA allowed establishment-paid inspectors to conduct regular pre-operational sanitation verification at processing establishments. The use of establislm1ent-paid inspectors conducting inspection activities could result in biased decisions leading to the export of unsafe poultry products to the United States. This arrangement constituted a conflict of interest and did not meet the requirements for ultimate control and supervision over the official activities of all employees of the system, as articulated by FSIS import regulations (9 CFR 381.196). As a corrective action, AQSIQ proposed to employ goverrunent officials to conduct all official sanitation verification. During the 2013 audit, FSIS auditors verified tl1at the CCA has implemented measures to ensure that employees of the PRC govermnent perform official enforcement of regulatory requirements tlu-ough cross referencing the ID badges and names of the CIQ inspectors observed performing inspection work with the following: the CIQ office employment database; an employee pay stub; training records; and a list of nan1es of CIQ employees, including tl1ose interviewed. The employment records demonstrated that personnel conducting inspection activities were employees of the PRC government. The CCA hires and utilizes official employees to conduct inspection duties, including sanitation. The CIQs hire official staff assigned to work at establislunents producing cooked poultry products destined for the United States and retain employee records. PRC employees are issued ID cards, with or without photos, and assigned specific numbers that correlate to the respective CIQ Bureau database. Based on review of the 9 documentation, FSIS auditors determined that inspection personnel who are performing governn1ent oversight are employees of CIQ. In the 2010 audit, the auditors found that the provincial CIQs oversaw the inspection system by designing and implementing inspection procedures as per PRC 's national standards. The PRC's standards are in addition to those standards imposed by other importing countries. Auditors also found that CIQ procedures were not consistently applied throughout the country. FSIS concluded that this autonomy created significant variation in the application ofthese standards among provinces. FSIS auditors reported that a recurring finding in the PRC ' s system was the lack of standardized inspection procedures and thus the lack of govenm1ent oversight of its inspection personnel. · In July 2011, the PRC submitted its response to this finding with two manuals, Inspection Quarantine Manual for Poult1y Exported to America (IQMPES) and Microorganism Monitoring Program for Export Poult1y Products (MMEPP). The purpose of the manuals is to implement consistent inspection and verification activities of the systems across provinces that have establishments identified as eligible to export poultry products to the United States. To maintain consistency in the implementation of inspection procedures across all the provinces, the CCA trained inspectors assigned to eligible establislunents on these manuals. In the 2013 audit, the CCA identified one province (Shandong) with tiu-ee branch CIQ Offices as having four eligible establishments to export poultry products to the United States. The auditors noted that the CCA revised the manuals it had provided to FSIS in the 2011 response, creating ti1e new ti1e Inspection and Quarantine and Monitoring Manual for PoultJy Exported to America (IQMMPEA), and the Microorganism Monitoring Program for Export Pou!tJy Products (MMEP P). The auditors confirmed that the CCA had disseminated the two newly revised manuals, IQMMPEA and MMEPP, to the CIQ offices and establislm1ents and reviewed training records for inspection persmmel at ti1e provincial CIQ, and local CIQ offices. FSIS auditors confirmed consistent application of inspection procedures in all establislunents. During the 2013 audit, the PRC submitted revisions to the previous manuals, changing the name, content, and versions numbers of both manuals while improving many sections from earlier versions. The inspection manual was changed to Inspection Quarantine and Supervision Work for Poult1y products Exported to the U.S. Handbook (IQSWPPEUH version 1.1 ). The microbe manual was changed to Monitoring Program for Microbes in Expqrted Poultty Products (MPMEPP version 1.0). Based on analysis of the current revised manuals, the auditors concluded that the CCA had standardized inspection procedures across ti1e CIQ offices and the four establislunents within the Shandong province. In the 2010 audit, the auditors observed that the CCA provided training to the newly hired inspection personnel and developed provisions for ongoing training. However, the auditors observed that the CIQ inspectors did not demonsh·ate an ability to verify that implementation of Hazard Analysis and Critical Control Point (HACCP) and microbiological testing programs was consistent with PRC requirements. In response, AQSIQ provided training on HACCP, Sanitation Standard Operating Procedures (SSOP), Listeria monocytogenes (Lm), and sanitation in 2012. 10 In the 2013 audit, the auditors interviewed CCA officials and CIQ supervisory and in-plant officials on the contents of the two manuals, inspection procedures, HACCP, sanitation, microbiological hazards for Ready-to-Eat (RTE) products, and microbiological sampling and testing procedures and practices. The FSIS auditors confirmed that inspection personnel were trained on the fundamentals ofthe aforementioned inspection activities. The inspection persmmel were able to identify all components of the written HACCP progran1s maintained by the establishments, including microbiological hazards for RTE products. To :further assess inspection personnel ' s lrnowledge ofHACCP, RTE programs, and supervisory assessment, the auditors developed mock scenarios seeking projected actions expected for each scenario. CIQ personnel were able to successfully demonstrate the knowledge required to make decisions and take actions in accordance with the regulations of the system. Also during the verification activities, FSIS confirmed that CIQ supervisory personnel conducted and documented periodic evaluations of employee performance. Supervisors were interviewed and asked to describe: (1) their preparation work/method prior to conducting subordinate evaluation; (2) the types of questions asked of an employee during the evaluation regarding inspection duties and knowledge ofHACCP principles; (3) whether or not the evaluation included onsite observation in the performance of inspection activities and any sample questions that are asked during the observation; (4) whether or not establishment written programs and testing results are reviewed with the employee; and (5) the type of feedback (oral or written) provided to an employee. The auditors detem1ined that the supervisors were lrnowledgeable on these five items. Auditors reviewed and discussed with the supervisors a sample of a completed evaluation form, Official Patrolling Supervision Record. The auditor noted that the form did not contain the employee's nan1e, but instead contained the establishment number. The auditors asked how one would know which employee was evaluated. CIQ supervisor explained that the employee's nan1e appears in the body of the document. Supervisors were asked to describe the procedures to handle employees who demonstrate an inability to perform inspection duties at a satisfactory level. It was explained that for an employee deemed unfit for duty, CIQ provides additional training and the employee's weaknesses are discussed. If the employee continues to be w1able to perform inspection duties adequately, the person is transferred to another agency. The auditors concluded that supervisors had the ability to effectively assess a subordinate's knowledge, skills, and ability in the performance of inspection activities and had a process to remove an employee who is not able to satisfactorily perform inspection duties. Based on the analysis of the conective actions the PRC. submitted in response to the 2010 audit and the results of the current verification activities conducted in the 2013 audit, FSIS concludes that that the CCA has adequately addressed previously identified concerns. The CCA has hired government inspectors to conduct verification activities and trained those employees to perform the work. The CCA has also created and disseminated two manuals that can be uniformly implemented across all establishments exporting processed poultry to the United States. FSIS also detem1ined that supervisory staff demonstrated the ability to effectively assess a 11 subordinate's knowledge, skills, and ability in the performance of inspection activities and had a process to remove an employee who was not able to satisfactorily perfonn official duties. Therefore, the PRC's poultry process inspection system meets FSIS equivalence criteria for this component. 6. STATUTORY AUTHOIUTY AND FOOD SAFETY REGULATIONS The second of the six equivalence components that FSIS auditors reviewed was Statutory Authority and Food Safety Regulations. This component pertains to the legal authority and the regulatory framework utilized by the CCA to impose requirements equivalent to those governing the system of processed poultry inspection organized and maintained in the United States. Based on analysis of the corrective action submitted by the PRC in response to the 2010 audit and the results of the current verification activities conducted in the 2013 audit, FSIS concludes that the CCA has adequately addressed previously identified concerns reported with this equivalence component. Therefore, the PRC's poultry processing inspection system meets FSIS equivalence criteria for this component. In 2010, FSIS auditors reported that the PRC's inspection system of processed poultry provided requirements for processed poultry inspection activities; establislunent construction; control over inedible and condemned materials; and daily inspection and periodic supervisory reviews of official establislm1ents. In the 2013 audit, FSIS auditors confirn1ed that these requirements had not changed. In the 2010 audit, the auditors reported that establishment-paid inspectors were conducting official pre-operational sanitation verification at processing establislm1ents. This finding was presented to the CCA as an issue that constituted a potential conflict of interest. As a corrective action, AQSIQ proposed to employ government officials to conduct all official sanitation verification activities. In 2013, FSIS auditors verified that the CCA has implemented measures to ensure that employees of the PRC perform official enforcement of regulatory requirements through cross referencing the ID badges and names of the CIQ inspectors observed performing inspection work with CIQ office employment database, an employee pay stub, training records and a list of names of CIQ employees, including those interviewed. The employment records demonstrated that personnel conducting inspection were PRC employees. The CCA hires and utilizes official employees to conduct inspection duties, including sanitation. The CIQs hire official staff assigned to work at establislunents producing cooked poultry products destined for the United States and retain employee records. PRC employees are issued ID cards, with or without photos and assigned specific numbers that con-elate to the respective CIQ Bureau database. This potential conflict of interest involving establishment-paid officials conducting inspection activities has apparently been resolved. In the 2013 audit, FSIS auditors interviewed supervisory and in-plant CIQ persom1el to verify their knowledge of U.S . requirements, CCA regulations, and the two manuals, as well as to determine their ability to conduct supervisory reviews. The auditors also observed and 12 interviewed in-plant CIQ inspectors as they performed their assigned duties related to the verification of the adequacy of the establislunents' HACCP and operational sanitation programs. During an observation assessment of inspection activities, an auditor discussed the operational cooking records with the CIQ inspectors and asked the inspectors to describe specific features within the record that aid in determining compliance and accuracy of the records. Inspectors were asked to provide the critical control point (CCP) process step, the critical limit and frequency of monitoring for each CCP of the records reviewed, and the number of CCPs within the HACCP plan. Upon returning to the establishment's conference room, the auditors reviewed with the inspectors the HACCP plan for each of the CCPs against the records reviewed during the plant tour. The inspectors were also asked to describe the components of a HACCP program and the type of training received. FSIS auditors found that supervisory and in-plant inspectors were knowledgeable about their responsibilities and had the competency to perform their duties. A minor one-time observation occurred at one establishment regarding a design flaw of the establishment's recordkeeping form; the fonn did not account for additional temperature verification checks being conducted by the establislm1ent Quality Control personnel. These additional temperature verification checks were not described in the HACCP plan. During the discussions with the inspector, he articulated measures expected to be taken by both the plant and himself regarding compliance of critical limits and product safety, which would correct the recordkeeping form and the HACCP plan to account for the additional temperature verification checks. He was able to demonstrate through the additional temperature verification checks that the product had met the critical limit and was safe. However, he failed to say he would document the noncompliance though he had earlier described as part of his training the need for documentation of the noncompliance along with the name of the noncompliance fonn to be used. It is unclear why he did not list tilis activity during the discussion; however, the inspector eventually stated he would document the noncompliance. A noncompliance record was produced for this incident. The auditors also reviewed and discussed the revised form Pre-Operational Inspection Official Onsite Verification ofCooked Plants, which deals with sanitation and is generated and maintained by the CIQ officials, and verified that officials prepared detailed documentation of observed findings, which includes preventive measures by the establishment and verification notation for corrective actions and signatures of the CIQ inspectors. The CCA introduced this revised official form for-completion by ti1e CIQ inspectors conducting pre-operational sanitation inspections and verification. The establishment must complete the form Pre-Operational Record ofCooked Plants to document pre-operational facility reviews. During an observation assessment of sanitation activities, the inspectors were asked to describe tile specific sanitation reviews conducted before and during operations, as well as specifics regarding the establishment procedures. The auditors were able to observe, in one plant, scheduled hand washlng and sanitizing via a portable cart wheeled into each room by two Quality Assurance (QA) employees. Employees washed their hands at the cart, and the QA employee sprayed a sanitizer on their gloved hands before they returned to work. This activity occurred every 30 minutes. The inspector stated that poultry meat, wllich falls on the floor, is placed inside plastic lined inedible trash cans and only designated plant employees discard.the trash into a locked chamber compartment at the end of the day. 13 In accordance with the analysis of the cmTective action submitted by the PRC in response to the 2010 audit and the results of the verification activities conducted in the 2013 audit, FSIS concludes that the CCA has adequately addressed previously identified concerns reported with this equivalence component. Therefore, the PRC's poultry processing inspection system meets FSIS equivalence criteria for this component. 7. SANITATION The third of the six equivalence components that the FSIS auditors reviewed was sanitation. FSIS requires that the inspection system provide requirements for sanitation, for sanitary handling of products, and for the development and implementation of sanitation standard operating procedures. In the 2010 audit, there were no major findings with this component and FSIS had concluded that the CCA had effectively implemented its requirements for sanitation and sanitary handling of poultry products intended for export to the United States. As a result, the PRC had met the requirements for this equivalence component. In the 2013 audit, the auditors verified this observation and concluded that there were no concerns. Therefore, the PRC's poultry processing inspection system meets FSIS equivalence criteria for this component. In the 20 I 0 audit, the FSIS auditors reviewed legislation, regulations, and official instructions and confirmed that the CCA exercised its legal authority to require establislunents to develop and implement sanitation programs and ensure sanitary handling of products. The auditors found that the establislunents were maintaining sanitary conditions in accordance with AQSIQ Directive No. 20, 2002, Regulation on Administration ofSanitary Registration and Enrollment for Establishments ofFood for Export, and GB/T 20094-2006, AQSIQ National Standard, Code ofHygienic Practice for Registration on Abaltoir and Meat Processing Establishments. In 20 I 0, the auditors observed that the CCA required establislunents to conduct biannual sanitation audits, as required by the PRC regulation. During review of the biannual sanitation audit records, FSIS suggested improvements for in-depth reviews of these audits. During the 2013 audit, FSIS auditors found no systemic issues with this component. Establishments identified, documented, and corrected sanitation deficiencies noted during preoperational and operational inspection. The updated versions of the inspection manual had been distributed to the goverrunent offices and establishments. CIQ officials effectively verified the adequacy of the implementation of the sanitation progran1, documented their findings, and verified adequacy of the conective actions. The FSIS auditors conducted onsite observations of the facilities and operational activities and concluded that, overall, the establislm1ent's facilities were well maintained and in good repair, and sanitary controls were effectively implemented to prevent the development of insanitary conditions. FSIS concludes that the CCA effectively implements its requirements for sanitation and sanitary handling of poultry products intended for export to the United States. As a result, the PRC meets the requirements for this equivalence component. 14 8. HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) SYSTEMS The fourth of the six equivalence components reviewed by FSIS was HACCP systems. The inspection system must require that each official establishment develop, implement, and maintain a HACCP plan. Based on the analysis of the corrective action submitted by the PRC in response to the 2010 audit and the results of the verification activities conducted in the 2013 audit, FSIS concludes that the CCA has adequately addressed the previously identified concerns reported with regard to this equivalence component. Therefore, the PRC's poultry processing inspection system meets FSIS equivalence criteria for this component. In the 2013 audit, the FSIS verified that the CCA had issued regulations that require each official establishment develop, implement, and maintain a HACCP system. The auditors evaluated the design and implementation ofHACCP programs at four certified processing establishments. The auditors observed that the CCA exerts its legal authority by requiring operators to comply with HACCP system mles. In the 2010 audit, FSIS conducted an onsite audit and reported to the CCA the following findings related to this component of the system: Establishments failed to specifically identify Listeria monocytogenes (Lm) in their hazard analysis as a potential biological hazard reasonably likely to occur in the post-lethality processing envirom11ent. However, establislunents did have sanitary controls in place controlling the post-lethality environment. The stabilization step for heat-treated products was not identified in the hazard analysis in some establishments. Establislunents omitted processing steps in the product flowchart, thus the hazard analysis of the entire process was incomplete. CIQ officials did not recognize inadequacies of the HACCP plans that included omitted processing steps in the flow chart, identifying missing stabilization steps, and identifying Lm as a potential biological hazard. The national standard outlining requirements for HACCP systems (GB/T 19538-2004) does not require preventive measures as part of the corrective actions to deviations from critical limits. In response, the CCA proposed that as cmTective actions, it would develop and distribute manuals containing inspection procedures to ensure the uniform implementation of regulatory requirements at establislunents that produce cooked poultry products for export to the United States. The CCA also indicated that it would train CIQ persollilel on the contents of the manuals and would require that establislunents comply with the HACCP regulations of the system. 15 In the 2013 audit, the auditor verified that the corrective actions proffered by the CCA to address the 2010 audit findings had been adequately implemented. Specifically, the CCA had provided to CIQ officials and establislunents a copy of the updated inspection manual requiring that establislunents recognize Lm as a biological hazard likely to occur in the post-lethality processing environment. The auditors verified that the establislunent's HACCP plan did include Lm as a biological hazard. In the Inspection Quarantine and Supervision Work for Poult1y products Exported to the US. Handbook version 1.1, (IQSWPPEUH) manual Section 3.4.2.2.2, the CCA has referenced 9 CFR 381.150 for lethality of Salmonella and stabilization for Clostridium perfi·ingens in cooked poultry products as well as FSIS Appendix B for additional controls of Clostridium perfi·ingens. Furthermore, the inspection manual requires that establishments identify, in their Sanitation Standard Operating Procedures (SSOP) or in their pre-requisite program, Clostridium perfi'ingens as a pathogen to be controlled during stabilization of cooked poultry product destined for the United States. FSIS auditors conducted on-site observations and verified that recordkeeping maintained by the establislunents adequately documented monitoring of cooking and cooling temperatures of products. The auditors reviewed establislunents' HACCP programs and detennined that all steps were included in the flow chart to permit analysis of each step in the process. In addition, the CCA updated the inspection manual with a requirement for establishments to provide preventive measures when a deviation occurs. The auditors reviewed records for documented deficiencies and found that the establislm1ents' stated preventive measure for the deviations was noted. These records included verification statements and the signature ofthe CIQ inspector verifying acceptability of the corrective action. FSIS auditors also verified that the establislunents received a copy of the inspection manual. The auditors interviewed inspection officials and reviewed records maintained by these officials assigned to provide inspection at the audited establislunents. FSIS auditors found that a series of controls was in place to ensure that only raw poultry products that arrive from eligible poultry slaughter establislunents are accepted by further processing establislm1ents. Authorized establislunents are poultry slaughter plants that have implemented systems to ensure that slaughtered flocks meet regulatory requirements regarding health management, husbandry practices, and compliance with drug withdrawal protocols. CIQ officials at the slaughter establislunents verify during ante mortem inspection that the aforementioned requirements are met by reviewing the Record of Veterinmy Ante-lvlortem Inspection ofExport Poulfly Processing Plant and Quarantine Certificate. The processing establislunents include a "receiving of raw materials" step in their hazard analysis and receive the Quarantine Certificate as proof of raw material originating from an approved source plant. Additionally, CIQ officials conduct verification activities associated with the receipt of raw products. Based on the above analysis, FSIS concluded that the PRC's inspection system meets the requirement for this equivalence component. 16 9. CHEMICAL RESIDUE PROGRAMS The fifth of the six equivalence components reviewed by FSIS was Chemical Residues. The inspection system must have a chemical residue control program that is organized and administered by the national government. This includes random sampling of internal organs and fat of carcasses for chemical residues as identified by the exporting country's meat and poultry inspection authorities or by FSIS as potential contaminants, as well as methods to deter recmrence of chemical residue violations. CIQ officials verify that the raw poultry received at the poultry establishments comes from an approved source and meets the residue control program requirements. FSIS auditors verified that raw products utilized by the poultry processing establishments are derived from authorized poultry slaughter establishments that comply with the AQSIQ residue control progran1 for exported poultry products. This component will be further discussed in the draft audit report for initial equivalence for poultry slaughter inspection. 10. MICROBIOLOGICAL TESTING PROGRAMS The last of the six equivalence components that the FSIS auditors reviewed was Microbiological Testing Programs. This component pertains to regulatory requirement for the inspection system to have a microbiological testing progran1, organized and administered by the national government. Both the CCA and the establishments certified for export to the United States are to employ control measures to prevent adulteration of both post-lethality exposed and non-exposed Ready-to-Eat (RTE) products by Lm and Salmonella spp. Furthennore, the CCA must conduct verification sampling and testing for Lm, and Salmonella spp in post-lethality exposed RTE products, product contact surfaces, and environmental surface samples, to verify that an establishment's control measures are effective in controlling these pathogens. Based on the analysis ofthe corrective actions submitted by the PRC in response to the 2010 audit and the results of the current verification activities conducted in the 2013 audit, FSIS concludes that the CCA has adequately addressed previously identified concerns reported with this equivalence component. Therefore, the PRC's China's processed poultry inspection system meets FSIS equivalence criteria for this equivalence component. The following analysis explains this decision. In 2010 audit, FSIS conducted an audit and reported to the CCA the following findings related to this component of the system: • The CCA needed to provide clear direction concerning the FSIS definition ofRTE products as outlined in 9 CFR 430.1. • Among the provinces audited, CIQ officials had not uniformly implemented sampling protocols to assess effective establishment control measures for Lm in the post-lethality 17 processing envirmm1ent. CIQ officials did not verify that the methods used by the establislm1ents to test the product and the environmental samples were adequate for the intended analysis of Lm. During the audit, the PRC discussed a zero tolerance policy for Lm and Salmonella spp. in RTE products. However, the auditors were unable to identify any specific legislation or written procedures describing a zero tolerance policy. The auditors observed that a 25g test portion was used for Salmonella, though FSIS requires a minimum of 325g test portion. In response to the 2010 audit findings, the CCA proffered corrective actions to address each of the findings reported. The CCA indicated that it would develop a Microorganism Monitoring Program for Export Poultry Products (MMPEPP), which would specifically describe the method required to monitor microorganisms, including Lm in products and in the processing environment. The CCA also indicated that in the newly issued regulations, Listeria and Salmonella were specifically mentioned as pathogens of concern to be controlled in the production of cooked products. Furthermore, the CCA stated that the MMPEPP would include the requirement for Lm and Salmonella, testing and would clearly state that there is a zero tolerance for Lm and Salmonella in cooked poultry products and require uniforn1 monitoring of pathogen controls for Lm in products and the processing envirmm1ent. The manual was revised to require a 325g san1ple for detecting Salmonella in cooked poultry products for export. Finally, the CCA indicated in its response that it would implement training of officials on each of the items included in the proffered corrective action. During the 2013 audit, the auditors verified that the CCA had included the FSIS definition of RTE, as written verbatim in 9 CFR 430.1, in its Inspection, Quarantine and Supervision Work for Poullly Products Exported to the US. Handbook (IPSWPPEH) version 1.1, and that the CIQ inspectors were knowledgeable ofthis definition. The CCA developed the Monitoring Program for Microbes in Export Poultry Products (MPMEPP) version 1.0 which includes provisions for mandatory testing for Lm and Salmonella and states that there is zero tolerance for these pathogens in RTE products in Appendices 2 and 4. The auditors also verified that the CCA has updated the manual to include 325g test portion for Salmonella testing. FSIS auditors, interviewed CIQ inspectors and found that they conduct product testing for Lm and Salmonella on a monthly basis. If a positive sample is found, either by govenm1ent testing or by establishment testing, the CCA will initiate additional testing of food contact and environmental surfaces. The auditors verified that this is consistent with the official instructions contained in Appendix 2, Section 3 .1.1.1 of the MPMEPP version 1.0. Product that is positive is either destroyed or reheated to destroy the pathogens and retested in a manner consistent with the instructions contained in Section 3.1.6 ofthe MPMEPP version 1.0. The CCA will also conduct an in-depth verification assessment of an establishment that produced product that tested positive for Lm or Salmonella. In addition, the establishments are required to initiate enhanced cleaning and sanitizing of the enviromnent and food contact surfaces. After analysis of the MPMEPP version 1.0 manual, FSIS determined that the CCA developed requirements and responsibilities for both regulatory verification and establishment 18 implementation of microbiological controls. Specifically, in Section 3, Jvfonitoring Procedures, of the MPMEPP version 1.0, the CCA references the 10,000 series of FSIS directives covering RTE products, Lm testing, and intensified verification sampling, as well as 9 CFR 430.4, and PRC's GB 16869. In MPMEPP version 1.0, Appendix 2 and Appendix 4, the CCA provides instructions for control and verification of Lm testing of product, food contact surfaces and the environment for the CCA and establishments. The CCA conducts three types of sampling as described in Appendix 2: regular, enhanced, and conventional. In the MPMEPP version 1.0, Section 3 .1.1.1, the CCA provides instructions to inspection personnel to conduct regular product sampling on a monthly basis. When a positive result occurs from either regular product sampling or conventional sampling, the CCA initiates enhanced monitoring once every 2 weeks (Section 3.1.7. 1), collecting samples from 10 FCS, 5 environment, 3 product, and 1 brine sample (if needed) while citing FSIS Directive 10,300.1 (Section 3.1.7.2). In conventional sampling, all plants are sampled once every 4 years similar to FSIS sampling described in Directive 10,240.5. MPMEPP version 1.0, Section 3.2.3, describes the conventional frequency at which the CCA will sample food contact surfaces and processing environn1ent. MPMEPP, Section 3.1.7.3 provides enhanced monitoring and comprehensive testing for seasonal facilities that have not undergone continuous regular sampling. For the establishments, the CCA provides instructions in MPMEPP version 1.0, Appendix 4, regarding sampling and testing for Lm. In Section 2, the CCA mandates sampling of product, food contact surfaces, and envirorunental surfaces. Fwthermore, Sect~on 4.1 mandates that establishments control Lm hazards through HAACP, SSOP, or prerequisite programs. The rest of Appendix 4 provides mandates for what to do when a positive sample is detected: sampling size, frequency, sampling method, recordkeeping, and enhanced procedures. The CCA is responsible for evaluating the establishment's Lm control plans and verifies the adequacy of its implementation. Based on the above analysis, FSIS concluded that the PRC's inspection system meets the requirement for this equivalence component. 11. EXIT MEETING An exit meeting was held on March 19,2013, in Beijing with AQSIQ. At this meeting, the FSIS auditors presented their observations made during the audit. 12. CONCLUSIONS In the 2013 audit, FSIS analyzed and verified the PRC's proffered corrective actions to previous findings of systemic impact that were identified in the 2010 audit. This audit involved the following equivalence components: (1) Governn1ent Oversight; (2) Statutory Authority and Food Safety Regulations; (4) Hazard Analysis and Criti.cal Control Point (HACCP) Systems; and (6) Microbiological Testing Programs. FSIS found that the PRC adequately addressed each of 19 the findings. Component 5, Chemical Residue Progranis, is discussed in the draft audit report for initial equivalence for poultry slaughter inspection. Based on the analysis of the conective actions submitted by the PRC in response to the 20 I 0 audit and the results of the verification activities conducted in the 20 13 audit, FSIS concludes that the CCA has adequately addressed all previously identified concerns reported. Therefore, the PRC's poultry processing inspection system meets FSIS equivalence criteria for all system components. With all outstanding issues resolved, the PRC may certify a list of establishments eligible to export processed (heat-treated/cooked) poultry products to the United States, as long as the raw poultry is sourced from countries that have been determined by FSIS to have an equivalent poultry slaughter inspection system. Audit Team: Francisco Gonzalez, DVM Senior Program Auditor (On-site auditor) Charmaine McGee, DVM Export Program Staff (On-site auditor) ~ ~ ~),) ·-{s: (l f:,/ Priya Kadam, Ph.D Senior Microbiologist/Senior Equivalence Officer 13. ATTACHMENTS TO THE AUDIT REPORT None at this time. 20 United States Department of Agriculture Food Safety and Inspection Service Foreign Establishment Audit Checklist 1. ESTABLISHMENT NAME AND LOCATION Zhucheng Waimao Co., LTD/Shandong Delicate Food Co., Ltd. East end of Mizhou Road Zhucheng, Shandong, PRC 2. AUDIT DATE March 8, 2013 3. ESTABLISHMENT NO. 4. NAME OF COUNTRY People’s Republic of China 3700/03409 5. NAME OF AUDITOR(S) 6. TYPE OF AUDIT Drs. Gonzalez and McGee X ON-SITE AUDIT DOCUMENT AUDIT Place an X in the Audit Results block to indicate noncompliance with req uirements. Use O if not applicable. Part A - Sanitation Standard Operating Procedures (SSOP) Basic Requirements Part D - Continued Economic Sampling Audit Results 7. Written SSOP 33. Scheduled Sample 8. Records documenting implementation. 34. Species Testing 9. Signed and dated SSOP, by on-site or overall authority. 35. Residue Sanitation Standard Operating Procedures (SSOP) Ongoing Requirements Part E - Other Requirements 10. Implementation of SSOP's, including monitoring of implementation. 36. Export 11. Maintenance and evaluation of the effectiveness of SSOP's. 37. Import 12. Corrective action when the SSOP's have failed to prevent direct product contamination or adulteration. 38. Establishment Grounds and Pest Control 13. Daily records document item 10, 11 and 12 above. 39. Establishment Construction/Maintenance Part B - Hazard Analysis and Critical Control Point (HACCP) Systems - Basic Requirements 40. Light 41. Ventilation 14. Developed and implemented a written HACCP plan . 15. Contents of the HACCP list the food safety hazards, critical control points, critical limits, procedures, corrective actions. 42. Plumbing and Sewage 16. Records documenting implementation and monitoring of the HACCP plan. 43. Water Supply 44. Dressing Rooms/Lavatories 17. The HACCP plan is signed and dated by the responsible establishment individual. Hazard Analysis and Critical Control Point (HACCP) Systems - Ongoing Requirements 18. Monitoring of HACCP plan. 19. Verification and validation of HACCP plan. 45. Equipment and Utensils 46. Sanitary Operations 47. Employee Hygiene 48. Condemned Product Control 20. Corrective action written in HACCP plan. Part F - Inspection Requirements 21. Reassessed adequacy of the HACCP plan. 22. Records documenting: the written HACCP plan, monitoring of the critical control points, dates and times of specific event occurrences. Part C - Economic / Wholesomeness 49. Government Staffing 50. Daily Inspection Coverage 23. Labeling - Product Standards 51. Enforcement 24. Labeling - Net Weights 25. General Labeling 26. Fin. Prod. Standards/Boneless (Defects/AQL/Pork Skins/Moisture) Part D - Sampling Generic E. coli Testing 27. Written Procedures 52. Humane Handling 53. Animal Identification 54. Ante Mortem Inspection 55. Post Mortem Inspection 28. Sample Collection/Analysis Part G - Other Regulatory Oversight Requirements 29. Records Salmonella Performance Standards - Basic Requirements 56. European Community Directives 30. Corrective Actions 57. Monthly Review 31. Reassessment 58. 32. Written Assurance 59. FSIS- 5000-6 (04/04/2002) Audit Results X FSIS 5000-6 (04/04/2002) Page 2 of 2 60. Observation of the Establishment Processing Establishment No. 3700/03409 FSIS auditors observed electrical cords bundled on top of several workstations’ lamps, one overhead electrical outlet with exposed wires and frayed conduit that had been rendered difficult to clean. FSIS auditors received copies of documented corrective actions and official verification prior to the completion of the audit. The evidence provided demonstrated an effective corrective action and adequate official verification. 61. NAME OF AUDITOR Drs. Gonzalez and McGee 62. AUDITOR SIGNATURE AND DATE United States Department of Agriculture Food Safety and Inspection Service Foreign Establishment Audit Checklist 1. ESTABLISHMENT NAME AND LOCATION Weifang Legang Food Co., Ltd. Honghe Town of Changle County Shandong, PRC 2. AUDIT DATE March/12/2013 3. ESTABLISHMENT NO. 4. NAME OF COUNTRY People’s Republic of China 3700/03435 5. NAME OF AUDITOR(S) 6. TYPE OF AUDIT Drs. Gonzalez and McGee X ON-SITE AUDIT DOCUMENT AUDIT Place an X in the Audit Results block to indicate noncompliance with req uirements. Use O if not applicable. Part A - Sanitation Standard Operating Procedures (SSOP) Basic Requirements Part D - Continued Economic Sampling Audit Results 7. Written SSOP 33. Scheduled Sample 8. Records documenting implementation. 34. Species Testing 9. Signed and dated SSOP, by on-site or overall authority. 35. Residue Sanitation Standard Operating Procedures (SSOP) Ongoing Requirements Part E - Other Requirements 10. Implementation of SSOP's, including monitoring of implementation. 36. Export 11. Maintenance and evaluation of the effectiveness of SSOP's. 37. Import 12. Corrective action when the SSOP's have failed to prevent direct product contamination or adulteration. 38. Establishment Grounds and Pest Control 13. Daily records document item 10, 11 and 12 above. 39. Establishment Construction/Maintenance Part B - Hazard Analysis and Critical Control Point (HACCP) Systems - Basic Requirements 40. Light 41. Ventilation 14. Developed and implemented a written HACCP plan . 15. Contents of the HACCP list the food safety hazards, critical control points, critical limits, procedures, corrective actions. 42. Plumbing and Sewage 16. Records documenting implementation and monitoring of the HACCP plan. 43. Water Supply 44. Dressing Rooms/Lavatories 17. The HACCP plan is signed and dated by the responsible establishment individual. Hazard Analysis and Critical Control Point (HACCP) Systems - Ongoing Requirements 18. Monitoring of HACCP plan. 19. Verification and validation of HACCP plan. 45. Equipment and Utensils 46. Sanitary Operations 47. Employee Hygiene 48. Condemned Product Control 20. Corrective action written in HACCP plan. Part F - Inspection Requirements 21. Reassessed adequacy of the HACCP plan. 22. Records documenting: the written HACCP plan, monitoring of the critical control points, dates and times of specific event occurrences. Part C - Economic / Wholesomeness 49. Government Staffing 50. Daily Inspection Coverage 23. Labeling - Product Standards 51. Enforcement 24. Labeling - Net Weights 25. General Labeling 26. Fin. Prod. Standards/Boneless (Defects/AQL/Pork Skins/Moisture) Part D - Sampling Generic E. coli Testing 27. Written Procedures 52. Humane Handling 53. Animal Identification 54. Ante Mortem Inspection 55. Post Mortem Inspection 28. Sample Collection/Analysis Part G - Other Regulatory Oversight Requirements 29. Records Salmonella Performance Standards - Basic Requirements 56. European Community Directives 30. Corrective Actions 57. Monthly Review 31. Reassessment 58. 32. Written Assurance 59. FSIS- 5000-6 (04/04/2002) Audit Results X FSIS 5000-6 (04/04/2002) Page 2 of 2 60. Observation of the Establishment Processing Establishment No. 3700/03435 39. FSIS auditors identified structural deficiencies that included accumulation of residue on the outer surfaces of a tumbler in the raw product area and coils of electrical cords on workstation lamps in the cooked product area. FSIS auditors received copies of documented corrective actions and official verification prior to the completion of the audit. The evidence provided demonstrated an effective corrective action and adequate official verification. 61. NAME OF AUDITOR Drs. Gonzalez and McGee 62. AUDITOR SIGNATURE AND DATE United States Department of Agriculture Food Safety and Inspection Service Foreign Establishment Audit Checklist 1. ESTABLISHMENT NAME AND LOCATION Zhongao Holdings Group Co., Ltd No. 1999 Central Street Qingyun County Shandong, PRC 2. AUDIT DATE March/14/2013 3. ESTABLISHMENT NO. 4. NAME OF COUNTRY People’s Republic of China 3700/03439 5. NAME OF AUDITOR(S) 6. TYPE OF AUDIT Drs. Gonzalez and McGee X ON-SITE AUDIT DOCUMENT AUDIT Place an X in the Audit Results block to indicate noncompliance with req uirements. Use O if not applicable. Part A - Sanitation Standard Operating Procedures (SSOP) Basic Requirements Part D - Continued Economic Sampling Audit Results 7. Written SSOP 33. Scheduled Sample 8. Records documenting implementation. 34. Species Testing 9. Signed and dated SSOP, by on-site or overall authority. 35. Residue Sanitation Standard Operating Procedures (SSOP) Ongoing Requirements Part E - Other Requirements 10. Implementation of SSOP's, including monitoring of implementation. 36. Export 11. Maintenance and evaluation of the effectiveness of SSOP's. 37. Import 12. Corrective action when the SSOP's have failed to prevent direct product contamination or adulteration. 38. Establishment Grounds and Pest Control 13. Daily records document item 10, 11 and 12 above. 39. Establishment Construction/Maintenance Part B - Hazard Analysis and Critical Control Point (HACCP) Systems - Basic Requirements 40. Light 41. Ventilation 14. Developed and implemented a written HACCP plan . 15. Contents of the HACCP list the food safety hazards, critical control points, critical limits, procedures, corrective actions. 42. Plumbing and Sewage 16. Records documenting implementation and monitoring of the HACCP plan. 43. Water Supply 44. Dressing Rooms/Lavatories 17. The HACCP plan is signed and dated by the responsible establishment individual. Hazard Analysis and Critical Control Point (HACCP) Systems - Ongoing Requirements 18. Monitoring of HACCP plan. 19. Verification and validation of HACCP plan. 45. Equipment and Utensils 46. Sanitary Operations 47. Employee Hygiene 48. Condemned Product Control 20. Corrective action written in HACCP plan. Part F - Inspection Requirements 21. Reassessed adequacy of the HACCP plan. 22. Records documenting: the written HACCP plan, monitoring of the critical control points, dates and times of specific event occurrences. Part C - Economic / Wholesomeness 49. Government Staffing 50. Daily Inspection Coverage 23. Labeling - Product Standards 51. Enforcement 24. Labeling - Net Weights 25. General Labeling 26. Fin. Prod. Standards/Boneless (Defects/AQL/Pork Skins/Moisture) Part D - Sampling Generic E. coli Testing 27. Written Procedures 52. Humane Handling 53. Animal Identification 54. Ante Mortem Inspection 55. Post Mortem Inspection 28. Sample Collection/Analysis Part G - Other Regulatory Oversight Requirements 29. Records Salmonella Performance Standards - Basic Requirements 56. European Community Directives 30. Corrective Actions 57. Monthly Review 31. Reassessment 58. 32. Written Assurance 59. FSIS- 5000-6 (04/04/2002) Audit Results FSIS 5000-6 (04/04/2002) Page 2 of 2 60. Observation of the Establishment Processing Establishment No. 3700/03439 The sanitary conditions and general operations of the establishment currently meet FSIS’s requirements and appear to comply with the PRC requirements. 61. NAME OF AUDITOR Drs. Gonzalez and McGee 62. AUDITOR SIGNATURE AND DATE United States Department of Agriculture Food Safety and Inspection Service Foreign Establishment Audit Checklist 1. ESTABLISHMENT NAME AND LOCATION Qingdao Nine-Alliance Group Co., Ltd. Weihai West Road Laixi, Qingdao Shandong, PRC 2. AUDIT DATE March 7, 2013 3. ESTABLISHMENT NO. 4. NAME OF COUNTRY People’s Republic of China 3700/03447 5. NAME OF AUDITOR(S) 6. TYPE OF AUDIT Drs. Gonzalez and McGee X ON-SITE AUDIT DOCUMENT AUDIT Place an X in the Audit Results block to indicate noncompliance with req uirements. Use O if not applicable. Part A - Sanitation Standard Operating Procedures (SSOP) Basic Requirements Part D - Continued Economic Sampling Audit Results 7. Written SSOP 33. Scheduled Sample 8. Records documenting implementation. 34. Species Testing 9. Signed and dated SSOP, by on-site or overall authority. 35. Residue Sanitation Standard Operating Procedures (SSOP) Ongoing Requirements Part E - Other Requirements 10. Implementation of SSOP's, including monitoring of implementation. 36. Export 11. Maintenance and evaluation of the effectiveness of SSOP's. 37. Import 12. Corrective action when the SSOP's have failed to prevent direct product contamination or adulteration. 38. Establishment Grounds and Pest Control 13. Daily records document item 10, 11 and 12 above. 39. Establishment Construction/Maintenance Part B - Hazard Analysis and Critical Control Point (HACCP) Systems - Basic Requirements 40. Light 41. Ventilation 14. Developed and implemented a written HACCP plan . 15. Contents of the HACCP list the food safety hazards, critical control points, critical limits, procedures, corrective actions. 42. Plumbing and Sewage 16. Records documenting implementation and monitoring of the HACCP plan. 43. Water Supply 44. Dressing Rooms/Lavatories 17. The HACCP plan is signed and dated by the responsible establishment individual. Hazard Analysis and Critical Control Point (HACCP) Systems - Ongoing Requirements 18. Monitoring of HACCP plan. 19. Verification and validation of HACCP plan. 45. Equipment and Utensils 46. Sanitary Operations 47. Employee Hygiene 48. Condemned Product Control 20. Corrective action written in HACCP plan. Part F - Inspection Requirements 21. Reassessed adequacy of the HACCP plan. 22. Records documenting: the written HACCP plan, monitoring of the critical control points, dates and times of specific event occurrences. Part C - Economic / Wholesomeness 49. Government Staffing 50. Daily Inspection Coverage 23. Labeling - Product Standards 51. Enforcement 24. Labeling - Net Weights 25. General Labeling 26. Fin. Prod. Standards/Boneless (Defects/AQL/Pork Skins/Moisture) Part D - Sampling Generic E. coli Testing 27. Written Procedures 52. Humane Handling 53. Animal Identification 54. Ante Mortem Inspection 55. Post Mortem Inspection 28. Sample Collection/Analysis Part G - Other Regulatory Oversight Requirements 29. Records Salmonella Performance Standards - Basic Requirements 56. European Community Directives 30. Corrective Actions 57. Monthly Review 31. Reassessment 58. 32. Written Assurance 59. FSIS- 5000-6 (04/04/2002) Audit Results x FSIS 5000-6 (04/04/2002) Page 2 of 2 60. Observation of the Establishment Processing Establishment No. 3700/03447 39. Establishment Construction/Maintenance FSIS auditors observed several long electrical cords bundled with pieces of wire and repaired with electrical tape that rendered them difficult to clean. There was also one frayed electrical cord near exposed frozen RTE products. CIQ officials documented these structural deficiencies and ensured implementation of adequate corrective action within 48 hours. An air-line water trap was not adequately closed and sealed causing its contents to spray in the surrounding area. FSIS auditors received copies of documented corrective actions and official verification prior to the completion of the audit. The evidence provided demonstrated an effective corrective action and adequate official verification. 61. NAME OF AUDITOR Drs. Gonzalez and McGee 62. AUDITOR SIGNATURE AND DATE
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File Type : PDF File Type Extension : pdf MIME Type : application/pdf PDF Version : 1.6 Linearized : No Author : USDA FSIS Create Date : 2013:08:30 11:58:58-05:00 Keywords : Foreign, Audit, Reports, -, China, 2013;, FAR Modify Date : 2013:09:04 12:39:43-04:00 Language : en XMP Toolkit : Adobe XMP Core 5.2-c001 63.139439, 2010/09/27-13:37:26 Creator Tool : KMBT_C450 Metadata Date : 2013:09:04 12:39:43-04:00 Producer : Adobe Acrobat 10.11 Paper Capture Plug-in Document ID : uuid:5a80bd76-8880-49e8-bb75-5aabd80a5733 Instance ID : uuid:38079f68-2f88-431e-912c-6fbfb1c07de9 Format : application/pdf Title : China 2013 Audit - Poultry Processing Inspection System Description : Foreign Audit Reports - China 2013 Creator : USDA FSIS Subject : Foreign Audit Reports - China 2013, FAR Page Mode : UseOutlines Page Count : 30EXIF Metadata provided by EXIF.tools