Re-inspection of Meat at the Canada-US Border

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Re-inspection of Meat at
the Canada-US Border
James M. Laws, P.Ag.
Executive Director
Canadian Meat Council
September 2014
Canadian Meat Council
• National industry trade association
representing federally-inspected meat
processors of beef, pork, poultry, horse
and lamb since 1919.
• www.cmc-cvc.com
Canada’s Meat Industry
• Total revenue from goods manufactured $24.1 billion (number one in food industry)
• Total value of meat exports - $4.5 billion
• Over 1,100 establishments
• Over 65,000 employees
• Largest food industry and the 11th largest
manufacturing industry behind motor vehicles,
petroleum products and sawmill products
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Pork Statistics 2013
• Canadian federally inspected hog slaughter – 20.3
million head
• Canada’s pork production – 1.93 million tonnes
• Canada’s pork exports – 1.2 million tonnes
• Export value total– $3.2 billion
• Export value to the USA $1.14 billion
• Canada’s pork imports- 185,000 tonnes
• Import value- $985 million, $920 million from USA
• Top Canadian pork export markets – USA, Japan,
Russia, China, Australia, Mexico
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Beef Statistics 2013
• Canadian federally inspected beef slaughter – 3.2
million head
• Canada’s beef production – 1.17 million tonnes
• Canada’s beef exports – 279 thousand tonnes
• Export value – $1.33 billion
• Export value to USA $ 902 million
• Canada’s beef imports- 213,000 tonnes
• Import value- $1.395 billion; $1.185 billion from USA
• Top Canadian beef export markets – USA, Mexico,
Hong Kong, Japan
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Number of Trucks
• Each and every day of the year, 365 days per
year, on average:
• 78 truckloads of Canadian meat (20 tonnes per
truck) cross the border into the United States
of America. That’s 28,150 truckloads per year.
• 49 truckloads of American meat (20 tonnes
per truck) cross the border into Canada. That’s
17,800 truckloads per year.
Prime Minister Harper and
President Obama Feb 4, 2011
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Beyond the Border: A Shared Vision for
Perimeter Security and Economic Competiveness
• On February 4, 2011, the Prime Minister of Canada
and the President of the United States issued
Beyond the Border: A Shared Vision for Perimeter
Security and Economic Competitiveness.
• The Declaration established a new long-term
partnership built upon a perimeter approach to
security and economic competitiveness. This
means working together, not just at the border,
but “beyond the border” to enhance our security
and accelerate the legitimate flow of people,
goods, and services. Leaders called for the
development of a joint Action Plan to realize this
goal, which is embodied in this document.
Why is the Canadian Meat Council Speaking
Here Today?
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Why is the Canadian Meat Council Speaking
Here Today?
10
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• Meat from the United States that is exported to Canada
is already inspected by USDA in accordance with
Canadian Food Inspection Agency requirements and the
meat is marked with “US Inspected and Passed by
Department of Agriculture” legend.
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• Canadian meat exported to the U.S. is similarly inspected
by the CFIA to the food safety and animal health
standards of the U.S. and marked with the Meat
Inspection Legend.
Canadian Federally Inspected Plants
 A Canadian Food Inspection
Agency veterinarian and
inspection staff are present at all
times during slaughter.
 A Canadian Food Inspection
Agency inspection staff is
present in processing plants.
 Industry employs full time
quality control managers.
 Every animal is inspected.
US Border Inspection
• All trucks containing Canadian meat crossing the
US border are first screened by US Border
Officials. After that , they MUST report to one
of only 10 US Inspection Centres along the
Canada-US border prior to final destination.
Canadian Border Inspection
• All trucks containing US meat crossing the
Canadian border are first screened by Canadian
Border Officials. At that time they are told if
their truck is the one of the 10% subject to
further inspection. This is NOT done at the
border but at one of the 125 CFIA Registered
Establishments in-land approved to do this.
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• The border inspections of Canadian and American meat
are merely “re-inspections” of USDA and CFIA inspected
meat. Re-inspecting meat in its final package in a box in
a truck is not nearly as worthwhile as inspecting meat
while it is being processed in the facility- or at a USDA or
CFIA regulated further processing plant.
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• Performing random inspections of trucks for
“contraband” or other illegal cargo is to be
expected- for all trucks – not just meat trucks.
• Stopping each and every meat truck at the
border is not necessary- especially when the
shipment comes from a supplier who is C-TPAT
certified.
• “We just got our SQF final audit (went very well)
and our custom commercial invoices are already
going electronically to FSIS. “
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• Redirecting Canadian meat trucks to U.S.
“inspection centres” also wastes time and fuel
and causes extra wear and tear on vehicles
through more mileage.
• “Every driver loses 2-4 hours of driving time
having to report to the I-house. If it is busy they
wait for the inspector to get free. Losing that
road time means that, once the driver hits his 1112 hours behind the wheel, paid rest time applies
for at least 10 more hours. Cost per hour is
roughly $100.00. “
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• “PHIS is the USDA
computer system
that we as exporters
will populate before
they get to the
border. That means
the USDA and FSIS
will have total control
and have almost a
flight plan from CFIA
Est. 1234 to USDA
est. 5678…….even
before it reaches the
border“
SUPPLY CHAIN DISRUPTION
AND LOSS OF SHELF LIFE
If products are sampled at the Inspection
House a supplier could lose 3-10 days of a
typical 30 day shelf life.
Fresh meats that get delayed can be refused by
the customer e.g. some customers in the
Southern USA has very tight quality control
criteria and will refuse products that don't
meet their very tight production specs for deli
products. “US companies require Delivery
Appointments….to manage the freshness…”
Cold-Chain at USDA Import Inspection
Centres is Broken
• All trucks containing Canadian meat crossing the US border
MUST then report to a US Inspection Centre prior to final
destination.
• The truck backs up to a warehouse loading dock.
• The trailer is opened up for inspection at an non-refrigerated
loading dock thus breaking the cold-chain.
Cold-Chain at USDA Import Inspection
Centres is Broken
• Many I Houses are older- buildings without proper food safety
programs such as HACCP and food safety warehouse programs
like the CFIA and USDA export establishments have.
• Temperature shifts while inspections are completed could be
10 degrees or more.
• Some wonder about I House control of rodents and pests…
Re-inspection of meat at the Canada-U.S.
border should be eliminated
• Both Canada and the U.S. currently approve the
establishments that are eligible to export to the
other country. Periodic audits of these approved
establishments are performed, and export eligibility
can be revoked at any time should the establishment
not satisfy the other country’s standards.
• 125 Federally registered establishments in Canada
are approved facilities for inspection of imported
meat products from the United States of America.
Of those 125 establishments 50 are meat processing
establishments and 75 are cold storage facilities.
Canada’s System of Meat
Testing is Equivalent to US
Canada’s System of Meat
Testing is Equivalent to US
Canada’s Listeria mono Control
in Meat is Equivalent to US
Canada’s Meat Inspection Act
Canada’s Meat Inspection
Regulations
Canada’s Meat Inspection
Regulations
Canada’s Meat Inspection
Regulations
• Federal Meat Inspection Act
Under the Federal Meat Inspection Act (FMIA), FSIS provides
inspection for all meat products sold in interstate commerce,
and reinspects imported products to ensure that they meet
U.S. food safety standards.
• In the statute, the relevant section is 21 U.S.C. 620
• Federal Meat Inspection Act
• Title 21 - Food and Drugs
• Chapter 12 - Meat Inspection
• SUBCHAPTER I - INSPECTION REQUIREMENTS;
ADULTERATION AND MISBRANDING
§620. Imports.
• No carcasses, parts of carcasses, meat or meat food products of
cattle, sheep, swine, goats, horses, mules, or other equines which
are capable of use as human food, shall be imported into the United
States if such articles are adulterated or misbranded and unless they
comply with all the inspection, building, construction standards, and
all other provisions of this chapter and regulations issued
thereunder applicable to such articles in commerce within the
United States. No such carcasses, parts of carcasses, meat or meat
food products shall be imported into the United States unless the
livestock from which they were produced was slaughtered and
handled in connection with slaughter in accordance with the Act of
August 27, 1958 (72 Stat. 862; 7 U.S.C. 1901-1906). All such
imported articles shall, upon entry into the United States, be
deemed and treated as domestic articles subject to the other
provisions of this chapter and the Federal Food, Drug, and Cosmetic
Act (21 U.S.C. 301 et seq.): Provided, That they shall be marked and
labeled as required by such regulations for imported articles:
Provided further, That nothing in this section shall apply to any
individual who purchases meat or meat products outside the United
States for his own consumption except that the total amount of such
meat or meat products shall not exceed fifty pounds.
(f) Inspection and other standards; applicability,
enforcement, etc.; certifications
• Notwithstanding any other provision of law, all carcasses, parts of carcasses,
meat, and meat food products of cattle, sheep, swine, goats, horses, mules, or
other equines, capable of use as human food, offered for importation into the
United States shall be subject to the inspection, sanitary, quality, species
verification, and residue standards applied to products produced in the United
States. Any such imported meat articles that do not meet such standards shall
not be permitted entry in to the United States. The Secretary shall enforce this
provision through (1) the imposition of random inspections for such species
verification and for residues, and (2) random sampling and testing of internal
organs and fat of the carcasses for residues at the point of slaughter by the
exporting country in accordance with methods approved by the Secretary. Each
foreign country from which such meat articles are offered for importation into
the United States shall obtain a certification issued by the Secretary stating that
the country maintains a program using reliable analytical methods to ensure
compliance with the United States standards for residues in such meat articles.
No such meat article shall be permitted entry into the United States from a
country for which the Secretary has not issued such certification. The Secretary
shall periodically review such certifications and shall revoke any certification if
the Secretary determines that the country involved is not maintaining a program
that uses reliable analytical methods to ensure compliance with United States
standards for residues in such meat articles. The consideration of any application
for a certification under this subsection and the review of any such certification,
by the Secretary, shall include the inspection of individual establishments to
ensure that the inspection program of the foreign country involved is meeting
such United States standards.
WHEREAS the Government of Canada has entered
into a Free Trade Agreement with the Government of
the United States of America in order :
• to strengthen the unique and enduring friendship
between the two countries and their peoples as befitting
great trading partners,
• to strengthen Canada’s national identity while at the
same time protecting vital national characteristics and
qualities,
• to promote productivity, employment, financial stability
and the improvement of living standards,
• to establish a climate of greater predictability for
Canadians to plan and invest with confidence and to
compete more effectively in the United States and global
markets, to build on Canada’s rights and obligations
under the General Agreement on Tariffs and Trade and
other multilateral and bilateral instruments of
cooperation,
US Inspection Centre Expenses
• In the summer of 2012 the Canadian Meat
Council surveyed its membership:
• “I am writing to request information from you
related to the fees that are charged to your
company by US Inspection Houses for shipments
of meat that are exported from Canada to the
United States of America.
• Excellent participation with 26 members
responding.
US Inspection Centre Expenses
• What is the fee that your company is charged per
truck at the US Inspection House just to verify the
documentation? (otherwise known as “skip lot”)
• Minimum $50
• Maximum $225
• Average: $105
• Based on 77 truckloads per day at a 90% skip lot
basis that’s 25,300 trucks x $105 per truck= $2.7
million on average just for skip lots per year.
• Source: Canadian Meat Council Members
US Inspection Centre Expenses
• What is the fee that your company is charged per
truck at the US Inspection House when a load is
pulled and held for testing purposes?
• Minimum $150
• Maximum $670
• Average: $370
• Based on 77 truckloads per day at a 10%
sampling basis that’s 2,800 trucks per year x 370
=$1 million on average just for test lots per year.
• Source: Canadian Meat Council Members
US Inspection Centre Expenses
• What is the total amount of fees that
your company pays to US Inspection
Houses each year?
• Total of all respondents:$3.56 million
• Source: Canadian Meat Council Members
Canadian Meat Council
Regular Members
Aliments
Trans Gras Inc.
Viandes
Sherrington
Conseil des Viandes du Canada
Membres réguliers
BOUVRY
EXPORTS
Canadian Meat Council
Associate / Retail / Food Service Members
Conseil des Viandes du Canada
Membres associés / du secteur du
commerce de détail / services alimentaires
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