OTTAWA, Ontario – Various Corrective Action Requests (CARs) have been issued by the Canadian Food Inspection Agency (CFIA) to XL Foods Inc. as a result of the agency’s in-depth review of the company’s Brooks, Alberta-based plant following the initiation of an expanding beef products recall of various beef products from that plant due to E. coli O157: H7 fears.
Based on CFIA’s in-depth, review team observations, one CAR was issued requiring the company to address issues related to its management of E. coli O157:H7. During an in-depth review or audit situation, all findings are issued CARs immediately, the agency relayed. Regarding the company’s management of E. coli risks, the team determined although the company had an appropriate plan to control food-safety risks, which had been verified by the CFIA, its hazard analysis and critical control points (HACCP) plan was not being fully implemented or regularly updated.
Specific observations included a lack of detailed documents outlining required steps when product was positive for E. coli O157:H7 or when there were a high number of positives in a 24-hour period; inconsistent trend analysis on positive samples and no process to include test results from client establishments; insufficient record keeping related to on-going monitoring and validation of processes, procedures, and equipment maintenance (e.g., 12 of 100 water nozzles clogged in the primary carcass wash area); and deficiencies in sampling techniques and procedures, such as inconsistent sampling and no established monitoring program.
Other CARs, which pointed to general maintenance and sanitation issues that may be found in a high-volume plant — particularly if the plant is older, were also issued. These issues would not typically be expected to contribute to E. coli 0157:H7 contamination, the agency said.
Findings related to maintenance and sanitation include refrigeration units had not been cleaned as frequently as is required in the company’s written sanitation plan; ice build-up was observed on freezer doors; water was dripping from piping; a drain near the rendering room was emitting a foul odor; there was condensation above exposed containers of product in the sampling and weighing areas; sanitizer was dripping from overhead structures onto product below; the company had no effective monitoring procedures to ensure that equipment design meets requirements; the evisceration table thermometer was not functioning properly; some employees were not wearing beard nets; and employees sorting beef trim touched contaminated product without following appropriate washing and sanitizing procedures.
CFIA said the plant staff was immediately notified of these findings as they were observed.
Another CAR was issued when product from XL Foods Inc. sampled by the US Food Safety and Inspection Service (FSIS) at the Canada-US border tested positive for E. coli O157:H7.
In answering the question of why weren’t the problems found during the in-depth review identified during routine inspection, the agency relayed that, in general, routine, day-to-day inspections focus on key hazard control points where food risks are the greatest. Less-critical aspects of production and facility maintenance are assessed, but less frequently. Therefore, some of the maintenance/sanitation issues found may not have been present on the day they were assessed.
In this case, the in-depth review or audit assessed all aspects of the plant operations and CARs were issued based on all observations as is the normal process, the agency added. Many of the findings of the in-depth review would normally have been addressed by personal, daily interactions with management. However, during an in-depth review or audit situation, all findings are issued CARs immediately.
There was no one single factor that would lead to E. coli O157:H7 contamination, the in-depth review determined —- the combination of several deficiencies could have played a role. Individually, each finding would not typically signal an immediate concern during the course of normal inspection activities, the CFIA explained.
The XL Foods Inc. plant has been subjected to eight foreign audits over the past four years in order to maintain the ability to export products. During these audits, issues were identified and each time the company acted on all findings, the CFIA concluded.