EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL Directorate F - Food and Veterinary Office Ares(2011)1039065 DG(SANCO) 2011-8849 - MR FINAL FINAL REPORT OF AN AUDIT CARRIED OUT IN THE RUSSIAN FEDERATION FROM 06 TO 15 JUNE 2011 IN ORDER TO EVALUATE THE FOOD SAFETY CONTROL SYSTEMS IN PLACE GOVERNING THE PRODUCTION OF POULTRY MEAT AND POULTRY MEAT PRODUCTS INTENDED FOR EXPORT TO THE EUROPEAN UNION (FOLLOW-UP)
Executive Summary This report describes the outcome of an audit carried out by the Food and Veterinary Office in the Russian Federation, from 6 to 15 June 2011. The objectives of the audit were to evaluate whether the official control system for poultry meat destined for export to the European Union can provide equivalent guarantees to those required under European Union legislation and to verify the effectiveness of the guarantees and corrective actions submitted to the Commission services in response to the recommendations of the previous poultry audit report of 2009. The report concludes that although two out of seven applicable recommendations from the previous Food and Veterinary Office audit covering poultry meat have been satisfactorily addressed by the Competent Authority and the rest of them are in the process of being addressed, the current system for official controls of poultry meat intended for export to the European Union is still not able to fully deliver the guarantees required in the relevant export certificate. Improvement is still needed in the areas of procedures granting approval for establishments for European Union exports, training, animal welfare, systems based on Hazard Analysis and Critical Control Points principles and post-mortem inspection. The report includes a number of recommendations addressed to the Russian Competent Authority and aimed at rectifying the identified shortcomings and enhancing the control system in place. I
Table of Contents 1 INTRODUCTION...1 2 OBJECTIVES...1 3 LEGAL BASIS...1 4 BACKGROUND...2 4.1 HISTORICAL BACKGROUND...2 5 FINDINGS AND CONCLUSIONS...2 5.1 LEGISLATION AND IMPLEMENTING MEASURES...2 5.2 COMPETENT AUTHORITY...3 5.3 OFFICIAL CONTROLS OF PRODUCTION AND PLACING ON THE MARKET...4 5.3.1 APPROVAL PROCEDURES...4 5.3.2 CONTROLS SPECIFIC TO FARMS, AND TO SLAUGHTERHOUSES: ANTE-MORTEM AND POST-MORTEM INSPECTION. ANIMAL WELFARE ATTESTATION...5 5.3.3 CONTROLS AT ESTABLISHMENT LEVEL...7 5.3.4 OFFICIAL SAMPLING...9 5.4 LABORATORIES...9 6 OVERALL CONCLUSIONS...10 7 CLOSING MEETING...10 8 RECOMMENDATIONS...10 ANNEX 1 - LEGAL REFERENCES...12 II
ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT Abbreviation CA CCA EU KMAFAM FBO FVO HACCP OV Rosselkhoznadzor SVS Explanation Competent Authority Central Competent Authority European Union Mesophyllic aerobic and facultative anaerobic microorganisms count Food Business Operator Food and Veterinary Office Hazard Analysis and Critical Control Points Official Veterinarian Federal Service for Veterinary and Phyto-sanitary Surveillance State Veterinary Service III
1 INTRODUCTION The audit took place in the Russian Federation from 6 to 15 June 2011 and was undertaken as part of the Food and Veterinary Office's (FVO) planned audit programme. The audit team comprised two inspectors from the FVO and one national expert. 2 OBJECTIVES The objectives of the current audit were to: evaluate whether the official control system for poultry meat destined for export to the European Union (EU) can provide equivalent guarantees to those required by EU legislation and in particular Commission Regulation (EC) No 798/2008. verify the effectiveness of the guarantees and corrective actions submitted to Commission services in response to the recommendations of the previous FVO audit report of DG(SANCO) 2009-8357. In pursuit of these objectives, the audit team proceeded as follows: an opening meeting was held on 6 June 2011 with the Competent Authority (CA). At this meeting the audit team confirmed the objectives of, and itinerary for the audit, and requested additional information required for the satisfactory completion of the audit; the following sites were visited: Competent authority visits Central level (CCA) 1 Rosselkhoznadzor - Opening and closing meeting Regional level 1 Regional Office Laboratory visits Central laboratory 1 Inter-regional State 1 Laboratory Primary production Farms 1 Broiler farm Food processing facilities Slaughterhouses 2 Cutting plants 2 Attached to the slaughterhouses visited representatives from the CCA accompanied the audit team during the whole audit. 3 LEGAL BASIS The audit was carried out in agreement with the Russian Authorities and under the general provisions of EU legislation and, in particular: Article 46 of Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls in third countries performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules; Full legal references are provided in ANNEX I. Legal acts quoted in this report refer, where applicable, to the last amended version. 1
4 BACKGROUND 4.1 HISTORICAL BACKGROUND Currently the Russian Federation is not allowed to export poultry meat and poultry meat products to the EU. This was the second audit in this field to the country after the Russian Federation requested to be listed for export to the EU of the above mentioned commodities. A previous audit took place in 2009 (ref. DG(SANCO)/2009-8357 hereinafter referred to as Report 2009-8357) which highlighted deficiencies inter alia in relation to procedures granting approval for establishments, ante-mortem and post mortem inspections, implementation of Hazard Analysis and Critical Control Points (HACCP) plans, sampling requirements and the knowledge of EU requirements by staff directly involved in the official controls in establishments. Report 2009-8357, published on the Health and Consumers Directorate-General internet site at http://ec.europa.eu/food/fvo/ir_search_en.cfm, made a number of recommendations to the CA. An action plan successfully targeting some of the recommendations of the report was received from the CA. However, this follow-up audit covered poultry meat only, since the audit team was informed by the CA that, at present, the Russian Federation does not intend to export poultry meat products to the EU. Therefore the implementation of recommendation 3 of Report 2009-8357 which was The CAs should guarantee that food additives (other than colorants and sweeteners) used in the establishments wishing to export to the EU are among those listed in Directive 95/2/EC was not verified by the audit team. 5 FINDINGS AND CONCLUSIONS 5.1 LEGISLATION AND IMPLEMENTING MEASURES Legal requirements Article 46 of Regulation (EC) No 882/2004 states that Commission experts may carry out official controls in third countries in order to verify the compliance or equivalence of third-country legislation and systems with the relevant EU legislation. Findings There is an extensive number of legal acts and procedures regarding official controls in the Russian legislation. The audit team noted that: according to Russian legislation (point 5.2 Chapter V, of Customs Union Commission Decision No 317, 18 June 2010) establishments wishing to export to another country have to comply with the requirements of the importing country. the relevant EU legislation had been translated into the Russian language and published on the CA's website and distributed to the regional services of the CA, to the laboratories involved and to the food business operators (FBOs) in the form of an electronic copy. Although there are no specific provisions in Russian legislation requiring the implementation of procedures based on HACCP principles by the FBOs, the audit team was informed that HACCP is a prerequisite for EU exports and saw evidence in all establishments visited that checking the existence of a HACCP plan was a part of the pre-approval for EU export inspection. 2
Recommendation 7 of Report 2009-8357 states The CAs should ensure that FBOs do not use any substance other than potable water to remove surface contamination from poultry meat and poultry meat products intended for export to the EU unless use of these substances have been approved by the EU legislation as required in Article 3 (2) of Regulation No 853/2004 (EC). The audit team was informed by the CA that the use of chlorine based anti-microbial treatment of poultry meat is no longer permitted in the Russian Federation since 1 January 2010. However, the use of non-chlorine compounds is still allowed. The CA informed the audit team that only potable water would be used for washing poultry meat in establishments approved for EU exports. This is however, not part of the established draft procedure for EU approval (see Chapter 5.3.1). The CA informed the audit team about their intention to include a check on decontaminants in the aforementioned draft procedure. The audit team saw evidence that in one of the establishments visited, during the EU pre-approval inspection the CA detected the use of non-chlorine decontaminants and actions were taken to eliminate this practice. A more detailed description of the Russian legal system covering the poultry sector can be found in Report 2009-8357. Conclusions The current Russian Federation legislation and CA procedures, once they are put in force, should provide the necessary guarantees for poultry meat to be exported to the EU. Recommendation 7 of the previous report can be considered as adequately addressed provided that official controls ensure that decontaminants are not used in relation to EU exports. 5.2 COMPETENT AUTHORITY Legal requirements Article 46 of Regulation (EC) No 882/2004 specifies that official controls carried out in third countries by Commission experts shall have particular regard to the organisation of the third country's competent authorities, their powers and independence. This article also refers to other issues such as the training of staff in the performance of official controls, the existence and operation of documented control procedures and control systems based on priorities. Article 47 of Regulation (EC) No 882/2004 states that third countries intending to export goods to the EU shall provide the Commission with information on the follow-up given to the recommendations made pursuant to controls referred to in Article 46 of the same Regulation. Findings The audit team was informed by the CA that in accordance with Government Decision 1009 (14 December 2009) the responsibilities for official controls of poultry meat for export to the EU are carried out by the following institutions of the Ministry of Agriculture: Rosselkhoznadzor (Federal Service for Veterinary and Phyto-sanitary Surveillance) State Veterinary Service (SVS) of Agriculture. Rospotrebnadzor (Federal Service for the Protection of Consumer Rights and Human Well-being) an agency of the Ministry of Health no longer functions as a CA for the poultry meat export sector. Regarding the structures and competencies in the two CAs there have been no changes since the last FVO audit covering the same topic (see Report 2009-8357). The audit team noted that the CAs have sufficient number of qualified staff to perform official controls on poultry meat. 3
The CCA informed the audit team that a draft procedure on export certification for poultry meat is in preparation. According to this draft procedure, if all the relevant EU requirements are complied with, a pre-export certificate would be issued by an official veterinarian (OV) (an employee of SVS) at the establishment and based on this document Rosselkhoznadzor would issue the EU export certificate. Recommendation 4 of Report 2009-8357 was The CCA should provide guarantees that the principles of the veterinary certificates for the relevant commodities equivalent to those laid down in Directive 96/93/EC, in particular concerning the awareness of the EU requirements by any OV participating in the EU Export certification chain, are adhered to. A two-week training session (from 23 May to 3 June 2011) which included practical exercises and establishment visits, covered inter alia food sampling for microbiological analyses, Good Hygiene Practices, HACCP, certification and listing of establishments, was provided by the EU Commission for the Russian CA within the framework of the EU's Better Training for Safer Food programme. The participants (25 CA representatives) are obliged to disseminate through training courses the information and knowledge acquired (i.e. to OVs scheduled to participate in EU export certification). One of these training courses where this information was to be distributed took place during the course of the FVO audit. However at the time of the audit the knowledge from this two-week training course has yet to percolate down to the OVs carrying out the actual controls on the ground as was evidenced by deficiencies in knowledge of the OVs in the establishments visited. Conclusions The CAs have appropriate structure and sufficient number of qualified staff to perform official controls on poultry meat. Although training courses have been centrally organised on EU requirements, the officials involved in the direct control and supervision of establishments (i.e. OVs) have not yet been made aware of all these requirements. Therefore recommendation 4 of the previous report can be considered as only partially addressed. 5.3 OFFICIAL CONTROLS OF PRODUCTION AND PLACING ON THE MARKET 5.3.1 Approval procedures Legal requirements Paragraphs (1) and (2) of Article 12 of Regulation (EC) No 854/2004 establish certain requirements for establishments involved in exports of products of animal origin into the EU, namely to appear on lists drawn up and updated by the CA in accordance with this Article. Findings Recommendation 1 of Report 2009-8357 stated The CCA should guarantee that only those establishments with standards equivalent to those of the EU, in particular with relevant requirements laid down in Sections II and V of Annex III to Regulation (EC) 853/2004 and Annex II to Regulation (EC) No 852/2004 are included in the list of establishments authorized for exporting products to the EU, in line with Article 12 of Regulation (EC) No 854/2004. In order to address this recommendation a procedure, which takes into account the relevant EU requirements (including HACCP and compliance with microbiological criteria), to approve establishments for possible EU exports, has already been drafted by Rosselkhoznadzor and includes a comprehensive checklist. However neither this procedure nor the checklist are yet in force. According to the CCA, the final version will take into account the results of the current FVO audit. 4
The audit team reviewed the EU export pre-approval reports of the two establishments visited. Upon the request of the FBOs wishing to export poultry meat to the EU, a commission, comprising Rosselkhoznadzor and SVS regional inspectors, assessed the establishments compliance. Based on the CAs' findings FBOs prepared corrective action plans to rectify deficiencies. After the follow-up visits, the regional CAs reported to the central headquarters of Rosselkhoznadzor that one establishment was compliant and the other one would be compliant by the commencement of the FVO audit. However, in the latter case the audit team found that some of the deadlines in the FBO s action plan to correct the deficiencies were scheduled beyond the planned FVO audit timeframe. Although the establishments visited by the audit team were considered by the CA as fully compliant with EU requirements, the audit team found deficiencies related mainly to sanitary conditions, hygiene practices and structures in both of them (one with easily correctable deficiencies whilst the other one had several more serious shortcomings). Detailed description of the findings can be found in Chapter 5.3.3 of this report. At present, an establishment s approval license for the national market, which contains the description of activities (e.g. slaughterhouse, cutting plant, etc.), is renewed annually by the SVS. The audit team was informed by the CCA that once the Russian Federation is eligible to export poultry meat to the EU, the CCA will grant EU approval numbers to EU compliant establishments indicating the activities approved for EU exports. Conclusions Although improvement was noted by the audit team, the current system in place does not yet fully guarantee that only those establishments with standards equivalent to those of the EU are included in the intended list of establishments authorized for EU exports. Therefore, recommendation 1 of the previous report cannot be considered as adequately addressed. 5.3.2 Controls specific to farms, and to slaughterhouses: Ante-mortem and post-mortem inspection. Animal welfare attestation. Legal requirements The poultry meat export certificate in Regulation (EC) No 798/2008 outlines requirements concerning ante- and post-mortem inspections, which should be carried out in line with Chapter V of Section IV of Annex I to Regulation (EC) No 854/2004. The poultry meat export certificate as per Regulation (EC) No 798/2008 should state that the requirements of Directive 93/119/EC have been met. Findings Controls in farms The audit team noted adequate biosecurity measures and sanitary conditions at the broiler farm visited. All the relevant records (e.g. treatments, vaccination, mortality, feed and water consumption, sampling results, etc.) were available for the audit team. Water was regularly tested by the FBO. The audit team was informed by the FBO that each feed consignment is accompanied with a quality and a veterinary certificate. Official controls are regularly carried out at least once per year by the SVS district office and with the same frequency by the SVS regional office. The latter controls aim to verify the controls carried out by the district. The inspection reports were made available for the audit team. 5
Ante-mortem and post-mortem inspection Recommendation 2 of report 2009-8357 stated: The CCA should provide guarantees concerning ante-mortem and post-mortem inspection as required by the export health certificate for poultry meat in Regulation (EC) No 798/2008. Procedures and conditions for ante-mortem and postmortem inspection should be at least equivalent to those required in Chapter V of Section IV of Annex I to Regulation (EC) No 854/2004. In all establishments visited the ante-mortem inspection was carried out both at the farm of origin and at the slaughterhouse. At the farm of origin the OV checks the flock records and carries out a flock inspection of the birds and then an examination report ( AKT ) is issued which is valid for three days. Based on the examination report a veterinary attestation valid for the number of birds to be slaughtered over one day is issued. This attestation accompanies the birds with the first truck to the slaughterhouse. An Annex is attached to this document, which contains the records on treatments with veterinary medicinal products, if any and their withdrawal periods. In addition to the veterinary attestation a transportation document accompanies each truck of birds providing identification. At the slaughterhouse ante-mortem inspection is carried out by the OV or by a FBO s veterinarian under the supervision of the OV. Ante-mortem inspection consists of inspection of birds, documentary, identification and animal welfare checks on each truck of birds. Although it is not a requirement, the temperature of a random number of birds is taken. The audit team noted that in general, ante-mortem inspection was adequately carried out both at the farm of origin and at the slaughterhouse. However, OVs knowledge on animal welfare was limited to birds' density requirements and there were no records on animal welfare checks carried out during ante-mortem inspection at the slaughterhouse. The ante-mortem inspection records were available for the audit team. According to the Government Decision No 14.10.94N13-7-2/173 post-mortem inspection should be carried out by OVs. The audit team noted in the establishments visited that the post-mortem inspection was carried out by FBO veterinarians under the supervision of an OV. The post-mortem inspection records are kept and signed by both of them. These records were available for the audit team. However, no clear legislation/instruction exists on this supervisory task (i.e. to what extent). This cannot be considered as equivalent to EU requirements (Point 1, Part B, Chapter V, Section IV, Annex I to Regulation (EC) No 854/2004). Although some of the deficiencies found during the previous audit had been eliminated by the CA, the following shortcomings related to post-mortem inspection were identified by the audit team (some of them already identified in the previous report): in one of the slaughterhouses visited carcasses were washed after evisceration, before the post-mortem inspection, and there was no system to enable the OV to assess properly possible faecal contamination (paragraph 5 of Chapter IV Section II of Annex III to Regulation (EC) No 853/2004); in both establishments visited the space available for the inspectors did not allow them to carry out their post-mortem inspection tasks properly and to have adequate access to hand washing facilities (paragraph 6 of Chapter IV Section II of Annex III to Regulation (EC) No 853/2004); in both establishment visited there was no clear correlation between the carcasses and the corresponding offal (paragraph 6 of Chapter IV Section II of Annex III to Regulation (EC) 6
Conclusions No 853/2004); Official controls at farm level and ante-mortem inspection were found, in general, to be well organised. However, due to the deficiencies described above and the unclear extent of OV involvement in supervision on FBO's veterinarians, the current system for post-mortem inspection cannot be considered as fully equivalent to that of the EU. Therefore recommendation 2 is regarded as partially addressed. 5.3.3 Controls at establishment level Legal requirements The export health certificate for the relevant commodities contained in Regulation (EC) No 798/2008 requires an FBO to implement a programme based on HACCP principles. Annex II to Regulation (EC) No 852/2004. Chapter II and III of Section II of the Annex III to Regulation (EC) No 853/2004. Article 4 and 10 of Regulation (EC) No 852/2004. Findings a) General findings There was permanent presence of OVs in both establishments visited. Furthermore a number of veterinarians employed by the FBOs were present on a daily basis. There were no official auxiliaries working in the establishments visited. A detailed description of the control system at establishment level can be found in point a) Chapter 5.3.4 of Report 2009-8357. b) Slaughterhouses and cutting plants The audit team visited two slaughterhouses with cutting plants attached. One of them had easily correctable deficiencies whilst the other one had several shortcomings. The audit team noted the following deficiencies in hygiene practice, sanitary conditions and maintenance of the premises (note: not all deficiencies were present in both establishments): surfaces (floors, walls and equipment) were not maintained in a sound condition and were not easy to clean and disinfect in contravention of paragraph 1 (a), (b), (f) Chapter II of Annex II to Regulation (EC) No 852/2004 (in one establishment visited this being critical); premises were not protected against the formation of condensation in contravention of paragraph 2(b), Chapter I of Annex II to Regulation (EC) No 852/2004; Condensation was observed in some instances above exposed product. bad hygiene practices were observed in several instances (the same person was handling exposed meat, offal and cardboard boxes; inadequate storage conditions for wrapping materials in the packing room (e.g. they were stored on a container used for inedible meat); some of the doors opening to the outside were not pest-proof; wooden pallets and dirty plastic separator plates were used in the storage area for not fully protected meat; etc.). These are not in line with the provisions of paragraph 3 Chapter IX of Annex II to Regulation (EC) No 852/2004. Most of these deficiencies had not been recorded in the official control reports. Although these deficiencies were present in both establishments visited, they were considered as compliant with EU requirements by the CA (see also Chapter 5.3.1). 7
Recommendation 8 of Report 2009-8357 stated: The CCA should provide guarantees concerning the animal welfare attestation contained in the veterinary certificate for poultry meat in Regulation (EC) No 798/2008. In particular, that the stunning of birds is carried out in line with Article 6 of Chapter II, of Directive No 93/119/EC. However, the audit team noted inadequate stunning of birds in one of the slaughterhouses visited; No immediate action was taken by FBO to remedy this situation. c) HACCP and own checks Recommendation 5 of Report 2009-8357 stated The CCA should ensure that the FBOs put in place, implement and maintain a permanent procedure or procedures based on HACCP principles as is set out in the relevant export certificates. Both establishments visited had HACCP plans implemented. However the audit team found some deficiencies related to these plans. in both establishments visited no verification procedures by the FBO for monitoring of critical control points were in place; (official controls by the OVs were included in the HACCP plans and were regarded as verification procedures); in one establishment visited post-mortem inspection was a part of the FBO s HACCP plan; The audit team was informed by the CCA that some of these deficiencies had already been corrected during the course of the audit. Nevertheless, these deficiencies were not detected during the CA's EU pre-approval inspection. In both establishments visited the audit team noted that there is a reliable traceability system in place operated by the FBO, which facilitates the identification by the OV of the origin of the product. Recommendation 6 of report 2009-8357 stated The CAs should ensure that poultry meat and poultry meat product samples taken by FBO and officials for microbiological analysis are taken in line with the Regulation (EC) No 2073/2005. In the establishments visited extensive sampling by the FBO had been carried out following the national sampling requirements for products and for potable water (detailed description of national sampling requirements can be found in point c), Chapter 5.3.4 of Report 2009-8357). In addition since April 2011 FBOs have begun to take samples for microbiological analyses taking into account the requirements of Regulation (EC) No 2073/2005 (i.e. neck skin samples). The audit team noted that neck skin samples were analysed for Salmonella in accordance with the Russian national method (GOST 52814-2007). However, the audit team was informed by the CA that this method is the same (translated into Russian) as the reference method (ISO 6579) defined in EU legislation. Water sampling was regularly carried out by the FBO in the presence of Rosselkhoznadzor. Samples were sent to a laboratory and analysed taking into account the requirements (including microbiological and physicochemical parameters) of Council Directive 98/83/EC. No samples of water or products taken within the framework of own-checks had tested positive in either of the establishments visited. Conclusions Although some improvement was noted by the audit team since the previous FVO audit covering the same topic, deficiencies related to sanitary conditions, maintenance, hygiene practices, implementation of HACCP plans and to animal welfare at the time of slaughter (stunning) were still present in the establishments proposed for EU exports. Therefore, the recommendations Nos 1, 5 and 8 from the previous report cannot be considered as fully addressed (see also Chapter 5.3.1 of 8
this report). A comprehensive own-check sampling programme is implemented by the FBOs in line with EU requirements. Recommendation 6 from the previous report can be considered as adequately addressed. 5.3.4 Official sampling Legal requirements The statements contained in section II.1 of the poultry meat certificate included in Commission Regulation (EC) No 798/2008, in particular points (c), (e) and (f), imply that the CA should take samples for laboratory analysis. Findings In accordance with the sampling programme of the SVS, poultry meat and edible offal are tested for mesophyllic aerobic and facultative anaerobic microorganisms count (KMAFAM) and for pathogens including Salmonella and Listeria monocytogenes. In accordance with the National Sampling Programme for microbiological analyses, Rosselkhoznadzor s regional office takes samples of poultry meat carcasses. Under the sampling procedures, the establishment concerned is not notified in advanced of the date of the sampling. Samples are analysed for KMAFAM, Salmonella and Listeria monocytogenes in an official laboratory. No samples of poultry meat taken by the CAs have tested positive in any of the establishments visited. Conclusions The CAs implement adequate sampling programmes for microbiological analyses of poultry meat. 5.4 LABORATORIES Legal requirements Article 46 of Regulation (EC) No 882/2004 indicates how Commission controls in third countries will have particular regard to the resources available to the CAs, including diagnostic facilities. The Codex Alimentarius Guidelines require adequate quality controls and the use of validated analytical methods. Findings The audit team visited two official laboratories (the Central laboratory in Moscow and an interregional laboratory of Rosselkhoznadzor). Both laboratories are accredited to ISO 17025 by the Russian Federation Accreditation body. In addition, the inter-regional laboratory informed the audit team about its plans to be accredited by one EU Member State s accreditation body. The national (GOST 52814-2007) method used for Salmonella detection is the same (translated into Russian) as the reference method (ISO 6579) defined in EU legislation. Both laboratories regularly participate in proficiency testing organised by different Russian institutions (including the accreditation body) and on some occasions by UK laboratories with mainly satisfactory results. However, when reviewing proficiency test results in the inter-regional laboratory, the audit team noted that in 2009, the laboratory had unsatisfactory results in an international proficiency test (aerobic plate count) carried out using a poultry meat matrix. The laboratory linked this failure to 9
inadequate sample storage conditions during custom clearance procedures. However, no documented follow-up of this non-compliant result was carried out by the laboratory. The audit team noted that the Central laboratory regularly organises proficiency tests for the interregional laboratories, whose participation is mandatory. Results of proficiency tests were available for the audit team in both laboratories visited. The audit team noted adequate facilities and knowledgeable staff in both laboratories. Laboratory staff regularly participated in training organised by Rosselkhoznadzor and by EU Member States laboratories. In addition two experts participated in the recent training on EU requirements. In the case of a positive result a laboratory is obliged to inform the CA in the twelve hours after the positive result becomes available. Nevertheless, all poultry meat samples tested in the laboratories visited had been compliant with microbiological criteria. The audit team was informed by the Central laboratory that only in the case of suspicion do they perform a test for the presence of antimicrobial substances. Conclusions The CA has designated laboratories to carry out analyses of samples taken during official control in poultry meat sector. Laboratories involved in official control related to EU exports are accredited, have adequate facilities and regularly participate in proficiency tests with overall satisfactory results. 6 OVERALL CONCLUSIONS Although two out of seven applicable recommendations from the previous FVO audit covering poultry meat have been satisfactorily addressed by the Competent Authority and the rest of them are in the process of being addressed, the current system for official controls of poultry meat intended for export to the EU is still not able to fully deliver the guarantees required in the relevant export certificate. Improvement is still needed in the areas of procedures granting approval for establishments for EU exports, training, animal welfare, systems based on HACCP principles and post-mortem inspection. 7 CLOSING MEETING During the closing meeting held in Moscow on 14 June 2011, the audit team presented the findings and preliminary conclusions of the audit to the CA. During this meeting, the CAs acknowledged all the findings and preliminary conclusions presented by the audit team and provided a commitment to correct the deficiencies found. 8 RECOMMENDATIONS The CA should provide Commission services with an action plan, including a timetable for its completion, in order to address the following recommendations for poultry meat intended to be exported to the EU. 10
N. Recommendation 1. The Central CA should take further measures to ensure that the principles of the veterinary certificates for the relevant commodities equivalent to those laid down in Directive 96/93/EC, in particular concerning the awareness of the EU requirements by any OV participating in the EU Export certification chain, are adhered to. 2. The Central CA should guarantee that only those establishments with standards equivalent to those of the EU, in particular with the relevant requirements laid down in Sections II and V of Annex III to Regulation (EC) 853/2004 and Annex II to Regulation (EC) No 852/2004 are included in the list of establishments authorized for exporting products to the EU, in line with Article 12 of Regulation (EC) No 854/2004 and the deficiencies mentioned in this report are corrected and avoided in the future. 3. The Central CA should provide guarantees concerning post-mortem inspection as required by the export health certificate for poultry meat in Regulation (EC) No 798/2008. Procedures for post-mortem inspection should be at least equivalent to those required in Chapter V of Section IV of Annex I to Regulation (EC) No 854/2004 and conditions to those required in paragraph 5 and 6 of Chapter IV Section II of Annex III to Regulation (EC) No 853/2004. 4. The Central CA should ensure that shortcomings in HACCP plans and their implementation as mentioned in this report are corrected and that requirements in line with those set out in Article 5 of Regulation (EC) No 852/2004 are fully met. 5. The Central CA should provide guarantees concerning the animal welfare attestation contained in the veterinary certificate for poultry meat in Regulation (EC) No 798/2008. In particular, that the stunning of birds is carried out in line with Article 6 of Chapter II, of Directive No 93/119/EC. The competent authority's response to the recommendations can be found at: http://ec.europa.eu/food/fvo/ap/ap_ru_2011-8849.pdf 11
ANNEX 1 - LEGAL REFERENCES Legal Reference Official Journal Title Dir. 93/119/EC OJ L 340, 31.12.1993, p. 21-34 Dir. 95/2/EC OJ L 61, 18.3.1995, p. 1-40 Dir. 98/83/EC OJ L 330, 5.12.1998, p. 32-54 Dir. 96/93/EC OJ L 13, 16.1.1997, p. 28-30 Reg. 852/2004 OJ L 139, 30.4.2004, p. 1, Corrected and re-published in OJ L 226, 25.6.2004, p. 3 Reg. 853/2004 OJ L 139, 30.4.2004, p. 55, Corrected and re-published in OJ L 226, 25.6.2004, p. 22 Reg. 854/2004 OJ L 139, 30.4.2004, p. 206, Corrected and re-published in OJ L 226, 25.6.2004, p. 83 Reg. 882/2004 OJ L 165, 30.4.2004, p. 1, Corrected and re-published in OJ L 191, 28.5.2004, p. 1 Reg. 2073/2005 OJ L 338, 22.12.2005, p. 1-26 Council Directive 93/119/EC of 22 December 1993 on the protection of animals at the time of slaughter or killing European Parliament and Council Directive No 95/2/EC of 20 February 1995 on food additives other than colours and sweeteners Council Directive 98/83/EC of 3 November 1998 on the quality of water intended for human consumption Council Directive 96/93/EC of 17 December 1996 on the certification of animals and animal products Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29 April 2004 on the hygiene of foodstuffs Regulation (EC) No 853/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food of animal origin Regulation (EC) No 854/2004 of the European Parliament and of the Council of 29 April 2004 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption Regulation (EC) No 882/2004 of the European Parliament and of the Council of 29 April 2004 on official controls performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules Commission Regulation (EC) No 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs 12
Legal Reference Official Journal Title Reg. 2074/2005 OJ L 338, 22.12.2005, p. 27-59 Reg. 1333/2008 OJ L 354, 31.12.2008, p. 16-33 Reg. 798/2008 OJ L 226, 23.8.2008, p. 1-94 Commission Regulation (EC) No 2074/2005 of 5 December 2005 laying down implementing measures for certain products under Regulation (EC) No 853/2004 of the European Parliament and of the Council and for the organisation of official controls under Regulation (EC) No 854/2004 of the European Parliament and of the Council and Regulation (EC) No 882/2004 of the European Parliament and of the Council, derogating from Regulation (EC) No 852/2004 of the European Parliament and of the Council and amending Regulations (EC) No 853/2004 and (EC) No 854/2004 Regulation (EC) No 1333/2008 of the European Parliament and of the Council of 16 December 2008 on food additives Commission Regulation (EC) No 798/2008 of 8 August 2008 laying down a list of third countries, territories, zones or compartments from which poultry and poultry products may be imported into and transit through the Community and the veterinary certification requirements 13