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FSIS audit reveals deficiencies in Brazilian meat inspection system

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USDA's newly released audit of the Brazilian meat inspection system shows so many deficiencies that some advocates are calling for an in-depth review of the country’s inspection system and even to revoke Brazil’s equivalency status. 

The audit was conducted from May 16 through June 2, 2017, just a few months after a major corruption scandal involving Brazilian meat inspectors prompted some countries to temporarily suspend imports of meat from Brazil and caused the United States on March 18 to begin 100% point-of-entry re-inspection of all Brazilian beef imported into the U.S.

The audit report, which USDA’s Food Safety and Inspection Service (FSIS) released on Wednesday (Nov. 15), identifies a slew of deficiencies, stating that Brazilian authorities failed to establish procedures to prevent conflict of interest between inspectors and meat plants, that sanitation requirements in plants were not enforced adequately to prevent product contamination and that post-mortem inspection procedures were “inadequate” to ensure that only “wholesome carcasses, free of contamination and defects receive the mark of inspection.” The audit also identified a “trend of abnormal container violations” at U. S. point of entry.

The United States banned all Brazilian imports of fresh beef just 20 days after completing the audit.

The findings of the audit were part of the reason why the United States decided to implement a ban on fresh beef from Brazil, Carmen Rottenberg, the acting deputy under secretary at FSIS, told IEG Policy on Thursday.

While the high percentage of point-of-entry violations was the primary reason for the ban, the findings of the audit, which confirmed the problems the United States had already been seeing at the border, also played a role for the U.S. decision to suspend imports, Rottenberg explained.

“We are looking at documentation, we’re looking at audits, we are looking at point-of-entry. We don’t make decisions in a vacuum for any of those things,” she said. “We are looking at, as a system, are they meeting the U.S. equivalency standards and if they are not, they are not going to be able to continue shipping here. In this particular instance, we looked at them in concert and made a decision that there were significant issues that needed to be addressed by Brazil.”   

But the findings have raised red flags for food safety advocates like Rep. Rosa DeLauro (D-Conn.), who on Thursday (Nov. 16) called upon the USDA to conduct an in-depth investigation of the Brazilian food inspection system.

“FSIS’s most recent audit reaffirms what we have known for years that there are underlying structural problems with Brazil’s meat inspection system,” DeLauro said. “Specifically, this latest report shows Brazil’s meat inspection system is failing to the meet basic requirements needed to ensure sanitary conditions and to prevent product contamination. The report also concludes that proper procedures have not been put in place to avoid conflicts of interest between inspectors – whose duty it is to uphold food safety standards – and the meatpacking companies that were caught bribing workers earlier this year.”

In determining if Brazil's meat inspection system remains equivalent to that of the United States, the FSIS recently released an audit that identified concerns with five of the six individual equivalence components that inspectors examined, raising questions about government oversight, statutory authority, food safety and other consumer protection regulations, sanitation, the Hazard Analysis and Critical Control Points (HACCP) system, and government chemical residue testing programs.

The audit lists no concerns over the Brazilian microbiological testing program, which was the sixth and final component of the FSIS examination. 

According to the report, government oversight was the area with most problems. Inspectors found that the Brazil’s Central Competent Authority (CCA) had no policies and procedures to prevent potential conflict of interests between local food inspectors and the establishments where they work, and that CCA failed to verify if inspectors perform their duties in a manner that is consistent with the issued instructions.

Among other concerns in that area, the audit noted that CCA failed to develop standard procedures for assessing the competence and performance of in-plant inspectors assigned to United States-certified plants. For instance, while instructions for the certification of products for the United States were sent to inspectors, FSIS requirements for holding livestock carcasses selected for residue sampling until the official test results were reported as acceptable did not reach the meat plants and their in-house inspectors, the audit found.

The audit report concluded that “CCA has developed administrative processes, but their implementation is not adequate to meet the equivalence requirements for this component. The CCA has failed to address weaknesses in its oversight, including addressing potential conflicts of interests, training, and performance assessment of individual inspection officials.”

It raised questions about post-mortem carcass inspections, which require inspectors to look for superficial and localized contamination and pathological lesions, that include abscesses and masses. The correct procedures require more severely affected carcasses to be railed out to a designated station, where they can be inspected, disposed of, and potentially identified as “not exportable.”

FSIS auditors, however, found that procedures in Brazil do not include a carcass inspection station where inspectors could verify that each carcass is “wholesome and free of defects and contamination prior to the final carcass wash. Furthermore, the audit discovered that inspected carcasses were still in need of trimming to remove spinal cords, hair, bruises, dressing defects and stick wounds – an approach that does not meet FSIS requirements, the audit states.

“FSIS requires that each carcass receive inspection to ensure that only wholesome carcasses free of contamination and defects receive the mark of inspection,” the audit states. “FSIS has reported to the CCA multiple POE [point-of-entry] violations that involve the presence of pathological lesions (i.e., abscesses) in raw beef products exported to the United States from certified establishments.”

“The observed audit findings under this component and the reported POE violations illustrate that PMI [post-mortem inspection] of Brazilian beef is not adequate to ensure that only wholesome, unadulterated carcasses, free of contamination and defects receive the mark of inspection to meet United States requirements,” the audit states.

FSIS auditors raised concerns over sanitation practices, noting that “in five of the nine audited establishments, poor maintenance of the facilities had created surfaces difficult to clean and sanitize.” Auditors noted that direct contamination was occurring in two of the four raw meat product exporting audited establishments. At one plant, for instance, beef carcass hindquarters were contaminated with “rail dust, a strip of hair on hide, and a thick smear of a green/brown substance were entering the deboning room.” At another plant, employees permitted reconditioning of raw pork that accidentally fell to the floor in the deboning department, because there were no written operational procedures to ensure that reconditioning of product is done properly, inspectors observed.

Inspectors also noted that one plant had failed to prevent carcasses moving on the chain rail from dragging across the flooring face plate of an inspection stand – a deficiency that had been identified for correction by CCA in 2014, the audit states.

FSIS auditors held an exit meeting at the end of the audit with Brazilian CCA officials who “committed to address the preliminary findings as presented.” CCA officials also submitted a written response to all outstanding concerns identified in the draft final audit report.

Brazil defends practices

Brazilian officials defended their practices, especially for post-mortem inspections.

“The average speed of slaughter in Brazil is much slower than in the U.S.,” the CCA noted in its response.

The CCA said that trimming of contamination does not impair health inspection and noted that Brazil has even taken steps to strengthen inspection procedures in a new regulation adopted on July 23, 2017.

The CCA also disagreed with the FSIS conclusion that inspectors in Brazil do not adequately enforce sanitation requirements, suggesting the issues FSIS inspectors observed were isolated cases and have been “corrected according to the establishments' individual action plans.”

Brazilian officials defended their inspection practices since the ban on Brazilian imports was instituted. Brazil’s Deputy Agriculture Minister Eumar Novacki said in June that the problems laid out by USDA had to do with cattle’s adverse reactions to foot-and-mouth disease vaccines and posed no risk to public health. Brazilian officials said they revised the Brazilian Health Regulations (RIISPOA) updated standards for employees and companies with the aim of "mitigating a lot of corruption risks," as well as the ministry's Ethics-Focused Compliance Program, which should be completed by January 2018.

Since instituting the ban on fresh Brazilian beef, the United States indicated that Brazil needs to conduct a complete review of its food safety inspection program and U.S. officials have been cautious about setting a specific timeline for lifting the ban, even after Rottenberg and some USDA representatives traveled to Brazil in the beginning of September to assess slaughterhouses.

In an email to IEG Policy on Thursday (Nov.16), the agency said it “considers the safety of our nation’s food supply and protecting the health of American consumers as its primary responsibilities.” 

“FSIS has committed to further technical discussions with the Brazilian government and will further assess equivalence of Brazil’s meat inspection system once the Agency receives Brazil’s proposed corrective actions to address the reported findings in the audit,” a spokesperson wrote.

“In the meantime, Brazil is still eligible to export processed beef and pork products to the United States,” a spokesperson wrote. 

But some food safety advocates feel the agency could do more.

In a statement on Thursday, Food and Water Watch (F&WW) questioned why the agency has not yet revoked Brazil’s equivalency status, which recognizes that the country has a food safety system equivalent to that of the United States.

“Why are we still recognizing Brazil as having an equivalent food safety system when over the past decade USDA auditors find the same problems over and over again?” asked Wenonah Hauter, F&WW executive director.

“The USDA should stop playing Russian roulette with our health,” she added. “The time has come to stop all meat imports from Brazil and eliminate it as a country eligible to export its meat products to the U.S.”

The problem, according to Tony Corbo, a senior lobbyist with the group, is that Brazil has been a repeat offender when it comes to meat inspections. Many of the deficiencies that were identified in the latest audit, were also found in an audit between March 10 and April 14, 2005, F&WW noted.

“Brazil has been an ongoing problem going back to 2003,” Corbo said. “The problem is that they always relapse. So, what is it going to take for USDA to say, 'Enough is enough!’”

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