USDA FSIS Export Verification Program for Closed Faced Sandwiches Destined for Canada
SAFEGUARDS | Food NO. 192/15
On November 2, 2015, the United States Department of Agriculture (USDA) Food Safety Inspection Service (FSIS) proposed a voluntary program to verify Hazard Analysis and Critical Control Point (HACCP) compliance of the manufacturing of closed faced sandwiches with meat and/or poultry products that are destined for Canada.  This program will be implemented with the USDA Agricultural Marketing Service (AMS) and export verification program for Ready to Eat products. The companies in this plan will pay the USDA FSIS/AMS to provide this inspection service. Once this program is implemented, only those companies participating will be able to export closed faced sandwiches to Canada.
Closed faced sandwiches, which are created by placing meat, poultry with or without other food products between slices of bread or other bakery materials, such as buns, are under the jurisdiction of the United States Food and Drug Administration (US FDA). When these products are manufactured for export, the US FDA does not require them to be manufactured under a HACCP plan. However, Canada requires closed faced sandwiches to be produced under a verified HACCP plan.
As part of this program, the USDA will verify the production of these products under a HACCP plan and Sanitation Standard Operating Procedures (SSOPs), as per the requirements of 9 Code of Federal Regulations (CFR) 417 and 416.11-17. Additionally, the AMS will perform routine and intensified testing. For routine testing, the AMS will take six product samples at random and test them for Salmonella and Listeria monocytogenes. If the plant has both post-lethality exposed and non-post lethality exposed product, the AMS will take six product samples from the post-lethality exposed product and two from the non-post lethality exposed product. Sampled production will be held until the results are determined. If tested positive, the product will have to be destroyed as per US FDA requirements. At least once a year and when a positive sample is obtained, the AMS will also perform intensive testing involving environmental and product testing.
The deadline to submit comments on this proposal is February 2, 2016.
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