Food Safety: Procedures for Inspecting Canadian Meat Imports

Published by the Government Accountability Office on 1997-04-02.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                    United States General Accounting Office

GAO                 Testimony
                    Before the Committee on Small Business,
                    U.S. Senate

For Release
on Delivery
Expected at
                    FOOD SAFETY
9:00 a.m. MST
April 2, 1997
                    Procedures for Inspecting
                    Canadian Meat Imports
                    Statement of Robert A. Robinson, Director,
                    Food and Agriculture Issues
                    Resources, Community, and Economic
                    Development Division

Mr. Chairman and Members of the Committee:

We are pleased to be here today to respond to your inquiries about the
U.S. system for inspecting Canadian meat imports. You asked us to
(1) describe FSIS’ system for selecting and inspecting imported meat
products, (2) determine the availability of equipment at import inspection
facilities along the Canadian border that would enable the full inspection
of meat shipped in trucks, and (3) assess the effectiveness of FSIS’ new
procedure to verify that carcass samples selected by Canadian inspectors
are representative of the entire shipment.

To respond to these questions, we visited 5 of the 21 FSIS-approved import
inspection facilities located along the U.S./Canada border and a Canadian
slaughterhouse, where we observed the inspection and sampling
processes. In addition, we met with FSIS officials and current and former
import inspectors to discuss the import inspection process. We also
reviewed the availability of equipment required to unload carcasses at
import inspection stations and FSIS’ data on the quality of Canadian

In summary, FSIS considers the eligible foreign countries’ inspection
system—not its own reinspection at the port of entry—to be the primary
control for ensuring that imported meat products meet U.S. standards. As
a check on the foreign countries’ inspection performance, FSIS requires
that every shipment of imported meat, including shipments from Canada,
receive some level of U.S. inspector review at the border. All Canadian
meat shipments receive a visual check for container damage and
inaccurate labeling or paperwork. Further, a sample of Canadian meat
shipments (about 11 percent of total Canadian meat shipments in calendar
year 1996) receive a more intensive examination.

The sampling approach used to perform this more intensive examination
varies by the type of product being shipped. For meat shipped in
containers, such as boxed ground beef or palletized bins of canned corn
beef, FSIS inspectors unload the entire shipment and select and examine a
random sample of the product. For meat carcasses, FSIS inspectors select
samples from the back of the trailer because the existing inspection
facilities lack the equipment needed to unload an entire shipment of meat
carcasses. To facilitate its sample inspection of meat carcasses, starting
February 16, 1997, FSIS began requiring that Canadian inspectors located at
Canadian slaughter plants select a random sample of carcasses and place
them at the back of the trailers in which they are to be shipped. The FSIS

Page 1                                                    GAO/T-RCED-97-121
             import inspector at the border will then examine the Canadian-selected
             samples. To verify that the Canadian sample selection is unbiased, FSIS
             inspectors also examine at U.S. destinations, about 15 carcass shipments
             per month that were not examined at the border. For these verifications,
             FSIS inspectors randomly select a sample of carcasses from the shipment,
             examine that sample and the Canadian selected sample and compare the
             results of the sample examinations. These data will be accumulated over
             time to verify that the Canadian samples are representative of entire
             shipments. While little experience has been gained since the new
             procedures took effect in February, an FSIS pilot test of the procedures
             found no evidence of bias in Canadian sampling.

             The Federal Meat Inspection Act requires that meat imports meet U.S.
Background   standards for wholesomeness and be produced under inspection systems
             that are equivalent to the U.S. system. Under the act, FSIS reviews the
             inspection systems of exporting countries for equivalency with the U.S.
             system and reinspects imported meat at the port of entry as a spot-check
             of the countries’ inspection performance. FSIS conducts two types of spot
             checks which are commonly referred to as “skip” assignments and
             “inspect” assignments. Skip assignments require a visual check for
             container damage and inaccurate labeling or paperwork. Inspect
             assignments require an FSIS import inspector to conduct the labeling,
             paperwork and container review associated with a skip assignment and to
             (1) randomly select and examine product samples and (2) sometimes
             randomly select and send product samples to an FSIS laboratory for testing.
             In a product examination, the inspector feels, smells, and visually
             examines exposed product samples to discover defects such as blood
             clots, bone fragments, extraneous materials, feces, hair, and lesions.

             Canada, generally speaking, is subject to the same requirements as other
             exporting countries, but is granted certain exceptions. One such exception
             is that for meat carcasses shipped from Canada, Canadian inspectors, not
             FSIS inspectors, typically select the carcass samples to be examined by FSIS.
             In accordance with one goal of the 1988 U.S./Canada Free Trade
             Agreement—facilitate commerce by reducing trade barriers—both
             countries sought agreement to minimize inspection procedures applicable
             to each other’s meat imports.

             Page 2                                                     GAO/T-RCED-97-121
                         For meat being imported from all countries, FSIS relies on its Automated
Automated System         Import Information System to automatically assign the type of
Determines Type of       reinspection that an FSIS import inspector will perform on an incoming
Inspection for Imports   shipment. The automated assignment system works in two ways. When
                         non-Canadian shipments arrive at a U.S. port of entry, a description of the
                         shipment is entered into the automated system and the type of
                         reinspection is automatically assigned. The proportion of skip assignments
                         and inspect assignments will vary with the product type, country of origin
                         and meat producer. In calendar year 1996, approximately 70 percent of
                         meat shipments from countries other than Canada were given a skip and
                         30 percent were given the more intensive inspect assignment.

                         For Canadian shipments, the process is modified. Rather than assigning
                         inspections on the basis of the product type, the automated system is
                         programmed to (1) randomly generate about 3,000 inspect assignments
                         annually, at a rate of about 250 per month, and (2) automatically generate
                         inspect assignments for those meat producers that are placed in
                         intensified inspection status because of recent compliance problems.1 For
                         calendar year 1996, approximately 89 percent of Canadian meat shipments
                         received skip assignments and 11 percent received inspect assignments
                         (7 percent triggered by random assignments and 4 percent triggered by
                         previous compliance problems). Skip assignments for Canadian shipments
                         also differ from those for other countries in that rather than unloading the
                         shipment, inspectors check only what is visible when the rear doors of the
                         trailer are opened.

                         As with imports from other countries, an inspect assignment for Canadian
                         meat shipments (for other than meat carcasses) requires that the entire
                         shipment be unloaded from the truck so that the inspector can randomly
                         select samples and perform specified product examinations. As discussed
                         below, however, entire Canadian shipments of meat carcasses are not
                         unloaded because of the limited equipment at the border inspection

                          If a shipment of imported meat is refused entry, the foreign meat producer is placed on “intensified”
                         inspection status. Non-Canadian meat producers, depending on the reason for refusal and the type of
                         product refused, will automatically receive an inspect assignment until the next 10 to 15 shipments of
                         that product pass inspection. For Canadian meat producers, 15 consecutive shipments of the refused
                         product—equaling at least 15 times the weight of the refused shipment—must pass inspection
                         regardless of product type or reason for refusal.

                         Page 3                                                                          GAO/T-RCED-97-121
                      Only 1 of the 21 FSIS-approved inspection facilities along the U.S./Canadian
Border Inspection     border has the necessary equipment to unload an entire shipment of meat
Facilities Lack       carcasses. As a result, unlike non-carcass shipments, Canadian meat
Equipment Needed to   carcass shipments are not entirely unloaded at any of the border
                      inspection facilities.
Unload Canadian
Carcass Shipments     Our analysis of FSIS data and our observations at the inspection facilities
                      we visited confirmed that only one inspection facility located on the
                      U.S./Canada border (facility number I-47 in Sweetgrass, Montana) had
                      sufficient overhead rail capacity to hang an entire truckload of meat
                      carcasses. Nine of the border inspection facilities had no rail capacity, and
                      the remaining 11 facilities had rail capacity ranging from 16 to 100 feet in
                      length. Because meat carcasses are generally shipped in trailers having a
                      total rail length of about 160 feet, the rail capacity at these facilities is not
                      adequate to handle a full shipment of carcasses.

                      FSIS-approved   import inspection stations have never been required to have
                      the overhead rail capacity needed to unload a full truckload of carcasses.
                      In January 1989 the United States and Canada, responding to the goals of
                      the U.S./Canada Free Trade Agreement, implemented new meat inspection
                      procedures for meat products traded between the two countries.
                      According to the FSIS Import Inspection Director, prior to 1989, Canadian
                      meat carcasses were inspected at their U.S. destination, rather than at the
                      border.2 In January 1989, FSIS moved its inspection activities for imported
                      Canadian meat to approved privately built and operated inspection
                      facilities located along the U.S./Canada border. However, the privately
                      owned facilities were only required to have enough overhead rail capacity
                      to unload the Canadian-selected carcass samples for FSIS inspectors’
                      examination. In July 1992 FSIS discontinued Canadian sample selection in
                      response to issues we raised during our 1992 report on Canadian meat
                      inspection.3 In that report we expressed concern about giving advance
                      notice of inspection to Canadian meat plants and having Canadian
                      inspectors select samples for U.S. inspection. Because the import facilities
                      lacked the equipment to unload full carcass shipments, FSIS import
                      inspectors started selecting their own samples from the carcasses
                      accessible at the rear of a truck.

                       Currently, two U.S. destination facilities are authorized to conduct import inspections. Canadian
                      importers may request inspection at these facilities, rather than at the port of entry.
                      Food Safety and Quality: USDA Improves Inspection Program for Canadian Meat, But Some Concerns
                      Remain (GAO/RCED-92-250, Aug. 26, 1992).

                      Page 4                                                                          GAO/T-RCED-97-121
                   After discontinuing Canadian sample selection and eliminating the
                   advance notice of inspection to Canadian meat plants, FSIS import
                   inspection officials told us that they had made a number of unsuccessful
                   attempts to provide for random sampling of carcass shipments at the
                   border. For example, around August 1993, FSIS proposed to Canadian
                   inspection and meat industry officials that carcasses be unloaded for
                   random selection and that inspection facilities be upgraded for this
                   purpose. The proposal was dropped because (1) industry and Canadian
                   government officials were concerned about shipment delays and potential
                   adverse impacts on meat hygiene, and (2) import inspection facility
                   owners objected to the increased costs associated with providing the
                   additional equipment and staff that would be needed to unload an entire
                   truckload of meat carcasses.

                   A second FSIS proposal, made in December 1993, to sample carcasses from
                   randomly selected sections of truck trailers was also abandoned when it
                   was determined that the trailers might become unbalanced, creating a
                   safety hazard. FSIS officials concluded that unloading entire carcass
                   shipments at the border inspection facilities was (1) unnecessary, given
                   the U.S.-equivalent Canadian inspection process before shipment and
                   (2) more risky, given the increased potential contamination and spoilage
                   associated with additional handling.

                   FSIS recently revised its procedures for Canadian carcasses imports to
New Verification   again allow for Canadian inspectors to select the samples that will be
Procedure Checks   examined by FSIS inspectors. The revised procedures also establish a
Canadian Carcass   system for FSIS to verify that the Canadian-selected carcass samples are
                   representative of the entire shipment. Effective February 16, 1997,
Sample Selection   Canadian meat producers exporting meat to the U.S. are required to place,
                   at the rear of every truckload, marked carcasses that were randomly
                   selected by a Canadian government inspector. These are the carcasses that
                   will be examined by the FSIS import inspector if an inspect assignment is
                   drawn from the automated system at a U.S. border inspection facility.

                   However, unlike the inspection procedures that were in place prior to
                   July 1992, Canadian plants are not provided advance notice of inspections
                   and FSIS has implemented a process to verify that the Canadian selected
                   samples are unbiased. To verify that Canadian samples are representative
                   of shipments, 15 shipments a month that receive skip assignments at the
                   border will be resealed and sent to their U.S. destination, where they will
                   be met by an FSIS import inspector. The inspector will unseal the truck,

                   Page 5                                                     GAO/T-RCED-97-121
           remove the Canadian selected sample, randomly select another sample
           from the remaining carcasses, and compare the inspection results from the
           two samples. The results of the verifications will be accumulated over time
           to statistically gauge the reliability of the Canadian sampling process. If
           the cumulative verification results exceed the pre-set limit of variation
           established by FSIS, there is evidence of possible bias in the Canadian
           sample selection process. Results will be compiled for individual Canadian
           slaughterhouses to ensure that the Canadian sample selection process is

           FSIS and Canadian inspection officials conducted a 60-shipment pilot test
           of the new verification procedure from July 10, 1995, to October 16, 1995.
           The test involved one of the largest Canadian meat producers and two U.S.
           destination plants. The results of the pilot test indicated that Canadian
           sampling was unbiased and that the verification procedure is an effective
           means for ensuring that Canadian-selected samples are representative.

           This concludes our prepared statement. We would be happy to respond to
           any questions you or members of the committee may have.

(150644)   Page 6                                                    GAO/T-RCED-97-121
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