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Department of Agriculture, Food and the Marine
Trader Notice MH 11/2013
To: All Food Business Operators approved to export Meat to the Russian Federation
Customs Union
Subject: Sampling and Testing of Meat, Offal, Meat preparations and Meat products destined
for trade with the Russian Federation/Customs Union (RF/CU)
Background
The Customs Union (CU) between Belarus, Kazakhstan, and Russia came into existence on
January 1, 2010. All meat and meat products destined for the Russian Federation/Customs
Union (RF/CU) must comply with Customs Union Decision No. 299 which outlines the
technical requirements to be met by meat intended for export to this market.
Scope
This Trader Notice describes the sampling requirements that are necessary to provide part of
the basis for certification for all meat destined for RF/CU markets.
CU Decision No. 299
The basis of all sampling and testing of CU destined meat and meat products is contained in
CU Decision 299:
CU Decision 299
This is a large complex document containing test parameters for a wide range of foods of
animal and vegetable origin. However the main meat parameters are contained in Table 1
(pages 14-41), subdivided as follows:
1.1 Meat in sides, quarters, and cuts – fresh and frozen
1.2 Offal – fresh and frozen
1.3 Raw fat, salted fat
1.4 Sausages and Ready Meals
1.5 Meat products including blood sausages (black puddings)
1.6 Canned Meats
1.7 Canned Offal
1.8 Thermally dried meats
1.9 Poultry Meat
1.10 Poultry Offal
1.11 Sausages made from poultry
1.12 Meat products of poultry offal, e.g. liver pâté
1.13 Canned Poultry
1.14 Thermally Dried Poultry
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It is imperative that FBOs make themselves familiar with the sections of CU Decision 299
that are relevant to the meat or meat products they intend to export to the RF/CU
Role of the Food Business Operator
To provide a basis for certification for all meat in relation to the parameters set out in CU
Decision 299 (as amended) the following additional procedures must be put in place by plant
management.
The FBO’s RF/CU SOP must include a Sampling Programme which covers the
 microbiological criteria.
 antibiotic residue criteria.
 pesticide, dioxin and heavy metal criteria
The radio nucleotide contaminant criteria will be covered by the sampling and testing
carried out by the RPII until further notice.
Slaughter plants producing meat and offal in the same premises must have separate sampling
programmes for each product type.
Please be aware that sampling is not consignment related. A summary sampling frequency
table - attached as Annex 1- provides a list of the main parameters and the frequency of
sampling for each parameter. It is important to note that the parameters and the maximum
permissible levels vary for meats from different species, different types (meat/offal) and
different processes (meat preps/meat products).
The FBO must inform themselves of the requirements for the meat or offal that they are
testing.
Examples of variations include:
1. Different TVC and Coliform levels for different meat cuts.
2. Different tests for poultry products.
3. No requirement for TVCs or coliform tests on offals.
4. Different heavy metal permitted levels for offals.
5. Additional heavy metals nitrate and nitrosamine tests for canned products.
There is no requirement to detain sampled carcases/meat pending results.
The RF/CU Micro Sampling Plan must be separate and clearly distinguishable from the
FBO’s general micro testing programme.
From 2014 onwards, the antibiotic, pesticides and dioxin residues sampling will be added on
to the FBO’s Self Monitoring Plan and must be included for approval by Veterinary
Medicines Section (VMS)** by March of every year. Direction re self monitoring will be
sent out in November.
**Reporting Residues to Veterinary Medicines Section (VMS)
1. In 2013 FBOs are obliged to report residue findings in excess of EU MRLs or Action
Limits to VMS at:
The Veterinary Medicines Section,
Department of Agriculture, Food and the Marine
Food Safety Building
Backweston Campus
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Young’s Cross, Celbridge. Co Kildare
Further action to be taken will depend on the residue as per table above.
2. In 2014 and subsequent years, FBOs will be required to submit their RF/CU Residue
Sampling Plans for antibiotic, pesticides, dioxins to VMS for inclusion in their Self
Monitoring Plans.
Action to be taken in the event of residue levels exceeding EU MRLs or action limits will
be included in the Self Monitoring Direction issued by VMS in November of every year.
Sampling Methodology
CU Decision 299 does not give the precise methodology required for each test. However the
following can be deduced from this document:
1. Micro samples are to be taken by a destructive/excision method.
2. The number of micro samples per test appears to be a minimum of 1
3. The number of heavy metal samples per test appears to be a minimum of 1.
4. The number of antibiotic samples per test appears to be a minimum of 1.
5. The number of pesticide samples per test appears to be a minimum of 1.
6. The number of dioxin samples per test appears to be a minimum of 1.
Sampling and Testing Requirements
Samples and tests to be carried out will depend on the plant type. While approved slaughter
plants must have a sampling and testing programme for all the required parameters at the
required frequency before carcase meat can be certified to another plant, other types of
premises are required to sample for fewer parameters, as indicated in the table under.
Plant Type
RF/CU Approved Slaughter Plants
Stand Alone Boning Halls
Mince Meat/Meat Preparation
Establishments
Meat Products
Samples/Tests to be carried out
Relevant Micro Tests
Antibiotic Tests
Heavy Metals
Pesticides
Dioxins
Relevant Micro Tests
Relevant Micro Tests
Relevant Micro Tests
Specific Tin, Chromium and Nitrosamine
tests for canned foods
In the case of RF/CU eligible carcases a traceability link must be maintained to demonstrate
that the samples came from such eligible carcases. Samples from other plants must also retain
a link to RF/CU eligible meat.
Reporting of Results
Once testing has commenced for the listed parameters, the relevant results must be provided
to the VI as they become available e.g. heavy metals results must be within 6 months of
certification and micro results must be within 10 to 15 days, as appropriate, for certification .
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The results form must clearly identify the laboratory and its status for the specific test it
undertakes. The units reported must be the same as those used in CU Decision 299.
Where possible, the FBO must use an accredited laboratory that uses a test validated to detect
to the levels (in the units) specified in CU Decision 299 (as amended). Where the sample
laboratory is not accredited for the specific test (required by RF/CU) the laboratory must
confirm that it will undertake to have the test accredited in a timely manner.
In the event that test results are non-compliant the FBO must carry out all corrective
actions indicated by the VI-in-charge.
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Annex 1
Sample Frequency Table for Required Tests
Organism
Responsibility
Frequency
Mesophilic and facultative
aerobic and Anaerobic
FBO
Every 10-15 days
micro-organisms1 (TVC)
– where applicable*
Coliforms – where
applicable*
FBO
Every 10-15 days
Salmonella
FBO
Every 10-15 days
Listeria monocytogenes
FBO
Every 10-15 days
*Note 1:
o TVC and Coliform tests are not required for Raw Offal of all species.
o Coliform tests are not required for Raw Poultry meat and meat products
Note 2: Sterilized canned foods must meet the requirements of industrial sterility for
canned food as described in Annex 1 of Decision 299 (page 327)
Substance
Toxic Elements
Amount of
Tested
sample
by
Frequency
Heavy Metals*
Lead
Arsenic
Cadmium
Mercury
As required by
laboratory
As required by
laboratory
As required by
laboratory
As required by
laboratory
FBO
Every 6 months
FBO
Every 6 months
FBO
Every 6 months
FBO
Every 6 months
*Note: Additional tests for canned foods include:
a) Tin (St) and Chromium (Cr)
b) Nitrosamines
c) Nitrates (offal)
Permitted Levels are contained in Sections 1.6, 1.7 and 1.13 of CU Decision 299.
Antibiotics:
Laevomycetin
(chloramphenicol)
Tetracycline group
Bacitracin
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As required by
laboratory
As required by
laboratory
As required by
laboratory
FBO
Every 6 months
FBO
Every 6 months
FBO
Every 6 months
This count is annotated as “QMAFAnM” which means “Quantity of Mesophilic Aerobic and facultative Anaerobic
Microorganisms”. This is not a routine EU test but VPHIS is advised that a standard Aerobic Colony Count (TVC) will also
pick up all facultative anaerobes (not obligate anaerobes) which prefer growing aerobically.
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Pesticides
HCCH (α,β,γ –
isomers)
DDT and its
metabolites
As required by
laboratory
As required by
laboratory
FBO
Every 6 months
FBO
Every 6 months
FBO
Every 6 months
FBO
Every 6 months
Dioxins
Beef/lamb fat
Pork fat
Radionucleotides
Cesium 137
Strontium90
As required by
laboratory
As required by
laboratory
On the basis of Sampling and Testing carried out by the RPII