FSIS                                    

FSIS                                                                                               

New Notices And Directives Explained

The Food Safety and Inspection Service (FSIS) issued FSIS Notice 09-06, Certifying Beef Products Under Export Verification (EV) Programs, FSIS Directive 9040.1, Revision 3, Re-inspection of Product Intended for Export, and FSIS Directive 9000.1, Revision 1, Export Certification, on March 1, 2006.  All three publications include processes that will make the export of product more time-consuming and resource-intensive, with checks and double-checks to ensure that export requirements are met and products destined for export are, in fact, approved for export.  The following are the highlights of these publications explained by the American Meat Institute.

Notice 09-06, Certifying Beef Products Under Export Verification (EV) Programs

The notice defines the process for an establishment to be audited by the Agricultural Marketing Service (AMS) for EV program approval and the roles of the Technical Service Center (TSC), AMS, the FSIS District Office, and FSIS inspection program personnel.  The notice points out that all of the following must occur in order for product to be exported under an EV program:

• FSIS Form 9060-6, Application for Export Certificate must be completed and approved,
• The establishment must be on the AMS EV list as approved for exporting to the importing country,
• The product must be derived from cattle slaughtered after the date the establishment received AMS approval,
• Each product listed on the application must be eligible for export to the country under the EV program,
• FSIS must be able to conduct re-inspection of the product as set out in Directives 9000.1, Revision 1 and 9040.1, Revision 3,
• The establishment must have a letter from AMS confirming that the EV program requirements have been met and the products are eligible for export (a copy of this letter also will go electronically to the TSC),
• The establishment must provide the AMS letter, as well as any other certificates required by the importing country, including letterhead certificates and supporting documents, to the FSIS certifying official, and
• FSIS must sign the application and issue FSIS Form 9060-5, Meat and Poultry Products Export Certification of Wholesomeness, and any other certificates required by the importing country, including letterhead certificates and supporting documents.

As a requirement for EV approval from AMS, an establishment will maintain a copy of all EV program audit reports, and will need to discuss the audit reports with FSIS inspection personnel during a weekly meeting or before the first EV export.  A list of products intended for export will be in the establishment’s Quality System Assessment (QSA) Quality System Manual.  The notice provides direction to inspection personnel in the event that they have concerns that an AMS-approved EV establishment is not executing its EV program.  The full notice can be found at http://www.fsis.usda.gov/regulations_&_policies/Notice_09-06/index.asp .

FSIS Directive 9040.1, Revision 3, Re-inspection of Product Intended for Export

This directive defines the procedures for re-inspection of product that is destined for export to verify the product’s safety, wholesomeness, identity (including labeling), and eligibility for export.  These procedures apply whether the product is at the establishment, or off-site at a non-official establishment, such as an Identification (ID) warehouse or a cold storage facility.  The directive was revised to provide for the examination of boxes or containers in situations where inspection program personnel have a reason to question whether the product as labeled meets the importing country’s requirements.

If inspection program personnel find signs of poor product handling and storage while conducting the organoleptic examination of the shipping cartons at either official or non-official establishments, they are to randomly select up to 5% of the boxes or containers for re-inspection for soundness and wholesomeness.  If the product is frozen, the official establishment or ID facility must temper or thaw all individual packages in the randomly selected boxes or cartons to allow the inspection personnel to conduct re-inspection.  When found to be sound and wholesome, inspection program personnel may allow the product to be re-packaged (at the packer’s option) for export.  When found to be unsound or unwholesome, a non-compliance record will be issued at official establishments, or product will be detained at non-official establishments.  The complete directive may be found at http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/9040.1Rev3.pdf .

FSIS Directive 9000.1, Revision 1, Export Certification

FSIS issued this directive to clarify FSIS policy regarding the export certification process.  The directive defines the steps FSIS takes to review a shipment for export, as well as procedures to follow in the event that refusal to sign the export certificate is necessary.  When the export certification services are performed in an official establishment, the issuance of export certificates that are required by 9 CFR Part 322 and 381.104 through 381.111 are not reimbursable services.  Only the execution of certificates that are in addition to FSIS regulatory requirements, e.g., additional certifications that are required by the importing country, and the transferring of products for export as described in 9 CFR 322.3, are considered reimbursable services.  When export certification services are performed at non-official establishments, the services are reimbursable and charged as set out in FSIS Directive 5110.1.

The Export Library contains the requirements that have been officially communicated to FSIS by the country to which the product is to be exported.  FSIS Directive 9000.1, Revision 1 also reviews the procedures used by inspection program personnel to verify that an application for export certification is complete, including review of paperwork, sensory evaluation of the product, storage and handling procedures for the product, labeling of the product and any required foreign language sticker.  The inspection program personnel may allow “pre-stamping” of boxes and the use of a computer-generated export stamp (sticker) with certain provisions described in the directive.

FSIS Directive 9000.1, Revision 1 also describes the export certificate paperwork required (application form 9060-6, certificate 9060-5), including continuation sheets prepared by the exporter when multiple items in the shipment exceed the space available on the face of the certificate.  The certifying official will sign the original certificate in the signature block in other than black ink, all continuation sheets, and other certifications, including letterhead certifications.  The certifying official should not stamp the certificate with the export stamp unless required by a receiving country as specified in the Export Library.

The directive defines the use of Replacement Certificates as well.  These are a re-certification of the product’s condition at the time of the original export certificate (and thus should be so dated) and does not represent the lot’s current condition.  The directive lists examples of when Replacement Certificates are appropriate.  The complete directive can be found at http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/9000.1Rev1.pdf .

Members with additional concerns can contact USMEF Export Services (Paul Clayton, Ann Spaeth or Kevin Smith at 303-623-6328) or AMI’s Skip Seward (sseward@meatami.com) or Mark Dopp (mdopp@meatami.com).

FSIS                                                                                               

New Notices And Directives Explained

The Food Safety and Inspection Service (FSIS) issued FSIS Notice 09-06, Certifying Beef Products Under Export Verification (EV) Programs, FSIS Directive 9040.1, Revision 3, Re-inspection of Product Intended for Export, and FSIS Directive 9000.1, Revision 1, Export Certification, on March 1, 2006.  All three publications include processes that will make the export of product more time-consuming and resource-intensive, with checks and double-checks to ensure that export requirements are met and products destined for export are, in fact, approved for export.  The following are the highlights of these publications explained by the American Meat Institute.

Notice 09-06, Certifying Beef Products Under Export Verification (EV) Programs

The notice defines the process for an establishment to be audited by the Agricultural Marketing Service (AMS) for EV program approval and the roles of the Technical Service Center (TSC), AMS, the FSIS District Office, and FSIS inspection program personnel.  The notice points out that all of the following must occur in order for product to be exported under an EV program:

• FSIS Form 9060-6, Application for Export Certificate must be completed and approved,
• The establishment must be on the AMS EV list as approved for exporting to the importing country,
• The product must be derived from cattle slaughtered after the date the establishment received AMS approval,
• Each product listed on the application must be eligible for export to the country under the EV program,
• FSIS must be able to conduct re-inspection of the product as set out in Directives 9000.1, Revision 1 and 9040.1, Revision 3,
• The establishment must have a letter from AMS confirming that the EV program requirements have been met and the products are eligible for export (a copy of this letter also will go electronically to the TSC),
• The establishment must provide the AMS letter, as well as any other certificates required by the importing country, including letterhead certificates and supporting documents, to the FSIS certifying official, and
• FSIS must sign the application and issue FSIS Form 9060-5, Meat and Poultry Products Export Certification of Wholesomeness, and any other certificates required by the importing country, including letterhead certificates and supporting documents.

As a requirement for EV approval from AMS, an establishment will maintain a copy of all EV program audit reports, and will need to discuss the audit reports with FSIS inspection personnel during a weekly meeting or before the first EV export.  A list of products intended for export will be in the establishment’s Quality System Assessment (QSA) Quality System Manual.  The notice provides direction to inspection personnel in the event that they have concerns that an AMS-approved EV establishment is not executing its EV program.  The full notice can be found at http://www.fsis.usda.gov/regulations_&_policies/Notice_09-06/index.asp .

FSIS Directive 9040.1, Revision 3, Re-inspection of Product Intended for Export

This directive defines the procedures for re-inspection of product that is destined for export to verify the product’s safety, wholesomeness, identity (including labeling), and eligibility for export.  These procedures apply whether the product is at the establishment, or off-site at a non-official establishment, such as an Identification (ID) warehouse or a cold storage facility.  The directive was revised to provide for the examination of boxes or containers in situations where inspection program personnel have a reason to question whether the product as labeled meets the importing country’s requirements.

If inspection program personnel find signs of poor product handling and storage while conducting the organoleptic examination of the shipping cartons at either official or non-official establishments, they are to randomly select up to 5% of the boxes or containers for re-inspection for soundness and wholesomeness.  If the product is frozen, the official establishment or ID facility must temper or thaw all individual packages in the randomly selected boxes or cartons to allow the inspection personnel to conduct re-inspection.  When found to be sound and wholesome, inspection program personnel may allow the product to be re-packaged (at the packer’s option) for export.  When found to be unsound or unwholesome, a non-compliance record will be issued at official establishments, or product will be detained at non-official establishments.  The complete directive may be found at http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/9040.1Rev3.pdf .

FSIS Directive 9000.1, Revision 1, Export Certification

FSIS issued this directive to clarify FSIS policy regarding the export certification process.  The directive defines the steps FSIS takes to review a shipment for export, as well as procedures to follow in the event that refusal to sign the export certificate is necessary.  When the export certification services are performed in an official establishment, the issuance of export certificates that are required by 9 CFR Part 322 and 381.104 through 381.111 are not reimbursable services.  Only the execution of certificates that are in addition to FSIS regulatory requirements, e.g., additional certifications that are required by the importing country, and the transferring of products for export as described in 9 CFR 322.3, are considered reimbursable services.  When export certification services are performed at non-official establishments, the services are reimbursable and charged as set out in FSIS Directive 5110.1.

The Export Library contains the requirements that have been officially communicated to FSIS by the country to which the product is to be exported.  FSIS Directive 9000.1, Revision 1 also reviews the procedures used by inspection program personnel to verify that an application for export certification is complete, including review of paperwork, sensory evaluation of the product, storage and handling procedures for the product, labeling of the product and any required foreign language sticker.  The inspection program personnel may allow “pre-stamping” of boxes and the use of a computer-generated export stamp (sticker) with certain provisions described in the directive.

FSIS Directive 9000.1, Revision 1 also describes the export certificate paperwork required (application form 9060-6, certificate 9060-5), including continuation sheets prepared by the exporter when multiple items in the shipment exceed the space available on the face of the certificate.  The certifying official will sign the original certificate in the signature block in other than black ink, all continuation sheets, and other certifications, including letterhead certifications.  The certifying official should not stamp the certificate with the export stamp unless required by a receiving country as specified in the Export Library.

The directive defines the use of Replacement Certificates as well.  These are a re-certification of the product’s condition at the time of the original export certificate (and thus should be so dated) and does not represent the lot’s current condition.  The directive lists examples of when Replacement Certificates are appropriate.  The complete directive can be found at http://www.fsis.usda.gov/OPPDE/rdad/FSISDirectives/9000.1Rev1.pdf .

Members with additional concerns can contact USMEF Export Services (Paul Clayton, Ann Spaeth or Kevin Smith at 303-623-6328) or AMI’s Skip Seward (sseward@meatami.com) or Mark Dopp (mdopp@meatami.com).