The audit was by DG SANTE from 2 to 12 May after results from Brazilian police of an investigation into illegal activities in the meat sector.
Previous audits covering the same commodities took place in 2013, 2014, 2015 and 2016.
Shortcomings previously identified
DG SANTE said it was of ‘particular concern’ that most shortcomings were the subject of recommendations in previous audits.
“The Brazilian competent authorities had provided written guarantees that the issues concerned by the previous recommendations had been addressed. However, the findings of this audit demonstrate that those previous guarantees were not fully reliable,” added the agency.
Objectives were to evaluate the official controls over production of beef, horse and poultry meat and products destined for the European Union, certification procedures, measures by authorities in response to rapid alert notifications and the police investigations in the meat sector with a focus on EU approved export sites.
Countries boosted scrutiny of Brazilian meat imports in response to a police investigation which uncovered a bribe payment scheme involving business and government inspectors who helped issue health certificates for food unsuitable to eat.
Police raided factories as part of Operation Carne Fraca in March this year. The action was the result of a two-year investigation of the meat sector.
Following the police investigation, 33 competent authority officials from different roles were dismissed/suspended and replaced. The majority were in the State of Paraná (29) and the head of SIPOA of Goiás.
At the time of the audit 87 people, including industry personnel, were subject to investigation.
The EU suspended imports from four of the 21 meatpackers in three states from which it received product and reinforced controls at EU border inspection posts to do 100% physical and 20% microbiological (lab) checks.
Non-compliances were identified in 10% of the more than 600 official samples of products made in the 21 establishments that were investigated.
MAPA hits back on lack of long term actions claim
The audit team said long term actions involving the whole meat sector and staff have not been considered.
They found the CCA did not launch additional investigations into linked sites (e.g. belonging to the same FBO or through official staff subject to investigation working also in other locations).
The Ministry of Agriculture, Livestock and food Supply (Ministério da Agricultura, Pecuária e abastecimento/MAPA) rejected this finding.
The agency said it is adopting actions including reorganization of personnel with the permanent hiring of 300 official veterinarians, implementation of a compliance program and proposal of technical and administrative ‘verticalization’ of the Federal Inspection Service (SIF) to make the system more robust against political interference.
“[There] was an administrative decision not to establish a formal audit schedule for the current year, concentrating efforts to investigate complaints received by internal or external channels to MAPA.
“Specifically for the EU, audits have been scheduled at all approved establishments located in the state of Paraná and in SIPOA-PR. [All] Brazilian poultry slaughterhouses approved to export to the EU will be audited.
“We emphasize once again that the main objective of the police investigation was the fight against corruption, and for this purpose, in an investigation that lasted more than two years, there were tools that MAPA does not legally have, such as: breach of confidentiality and wiretapping, among others.”
Highlights of DG SANTE audit findings
DG SANTE noted differences between Brazilian and EU requirements regarding microbiological criteria applied for Salmonella on poultry meat.
The sampling plan comprises five samples of meat cuts (e.g. poultry fillets) and of meat preparations (e.g. salted fillets), randomly collected during the day.
EU regulation requires collection of five samples of the same batch to define its acceptability.
MAPA informed the audit teams that regulation on industrial and sanitary inspection of products of animal origin entered into force on 3 April this year.
FBOs are obliged to make staff available to assist in official inspection, in accordance with specific rules by the MAPA. Such rules have not been drafted yet and FBO staff currently operates in post-mortem inspection under an official supervision.
Brazilian rules give authorities the necessary powers, independence and authority for enforcement of legislation but enforcement actions were not always appropriate or sufficient to ensure correction of detected deficiencies.
“The CCA has put in place audit and supervision systems aimed at verifying the effectiveness of the official controls in establishments approved for EU exports.
“However, these systems are not always properly implemented and therefore are not effective in detecting and acting on significant non-compliances in the performance of the CAs at State/local level.”
No official veterinarian supervision
In some beef and horse slaughterhouses, it was also found that FBOs' staff were carrying out official tasks without supervision by the official veterinarian (OV).
In some poultry slaughterhouses OVs have not been assigned and in three others they were not permanently present on site during slaughter.
“In one of these three slaughterhouses, the SIF team comprised one OV who was replaced, during the absence periods, by a private veterinarian of the slaughterhouse company. The audit team was informed that this veterinarian, employed and paid by the company, formed part of the SIF team on a permanent basis.
“The system in place does not guarantee that establishments exporting poultry meat to the EU are under the supervision of an OV or that ante mortem and post mortem inspection is performed in accordance with EU rules, nevertheless the CA was signing certificates confirming the EU requirements have been completed which were factually incorrect.”
This slaughterhouse was one of the biggest exporters worldwide of poultry meat to the EU in 2016.
A system to prevent use of food additives unauthorized in the EU was implemented by the SIF.
“However, in one of the establishments visited the audit team noted that for the production of salted chicken fillets (meat preparations) destined for EU, a low quantity of unauthorised food additives, phosphates (0.28% of the total mix of meat in the tumbler), was used.”
‘For 15 consecutive samples for TVC the result was 0’
The audit found there is no official instruction on how to verify the reliability and plausibility of results presented by the FBOs.
“As a consequence, in one beef slaughterhouse, it was observed that the OV had not reacted when, for 15 consecutive samples for Total Viable Counts (TVC), the result was 0, which is an implausible sequence of results.”
Brazil has a history of RASFF notifications mainly in poultry meat preparations with presence of Salmonella spp. Past reaction and follow-up was slow and did not lead to a significant reduction in alerts.
In two of three poultry sites visited, with a high number of recent RASSF notifications, no further interventions to mitigate risk of Salmonella contamination of final products in the process line (e.g. reducing speed of the slaughter/process line, emptying/cleaning of the cooling immersion tanks between work shifts, increasing the number of samples analysed) were considered necessary.
DG SANTE team found the CA cannot provide guaranties that rejected consignments will not be re-dispatched to the EU.
“Moreover, the system does not guarantee that products, that are part of the same batch rejected, will not be exported to the EU. The CAs acknowledged the problem and initial corrective actions are being taken/planned to address the situation, but it is too early to assess the effectiveness of this response.”