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Requirements to Requirements to Export Beef
Barry L. Carpenter
Deputy Administrator
Agricultural Marketing Service
Livestock and Seed Program

Overview of Responsibilities for Exporting Beef Products

• Expectation of the Importing Countries
• Role of Industry and USDA
• Process Control Systems
• Specified Product Requirements for Japan and other countries

Expectations of the Importing Country

• Industry and USDA will ensure:
  • All animal health protocols
  • All domestic food safety requirements
  • Additional country specific requirements
  • Complete and accurate documentation
• Industry expected to ship only complying products
• USDA is expected to verify compliance with all requirements

Role of Industry and USDA

• Ensure Product Conformance
  • Working together
  • Effectiveness of the process will determine product compliance
  • Inspection alone will not assure a complying product

Role of Industry

• Agree to meet all requirements of both the QSA and EV Programs
• Declare to USDA how compliance is achieved using documented quality management systems
• Continuous control of the product can ensure:
  • Product complies with the country specific requirements
  • Only conforming product is shipped to importing countries

Role of USDA (Figure)

Responsibilities of USDA Agencies

• APHIS
  • Animal Health requirements
• FSIS
  • Food safety and regulatory SRM removal
  • Export Certificates
• AMS
  • Bridge the gap between USDA regulatory requirements and importing country requirements

USDA/AMS
Provides services for Quality System Verification Programs

Quality System Assessment (QSA)
“Defines the Company’s PLAN”

• Who
• What
• Where
• How
• Addressing the requirements
  of ARC 1002 (QSA)

QSA Scope
The extent of controls in a QSA Program include everything in the entire production system
OR
Only subsets of the production system as described in the scope of the submitted program

Export Verification (EV) Program
“Defines the specified product requirements that must be controlled by the Company’s PLAN”

• Addressing the country specific requirements
  • Age
  • SRM Removal
  • Dedicated Equipment

QSA/EV Program Requirements

• Companies must submit a documented program that addresses the QSA/EV requirements
• This would include activities at all associated locations

EV Program addresses two broad areas:

• Requirements that exceed the U.S. regulatory requirements
• Mandated controls for segregation and product identification

QSA/EV Program Requirements - Major Elements

1. Quality Management Systems (QMS)
2. Management Responsibilities
3. Human Resources
4. Product Realization
5. Measurement, Analysis, and Improvement

1. Quality Management System

• Must have a quality system manual that defines your quality management system
• Procedures
• Documents
• Records

2. Management Responsibilities

• Must identify responsible management personnel
• Demonstrate knowledge of the QSA/EV program

3. Human Resources

• Competence
• Awareness of requirements
• Training
• Sufficient human resources

4. Product Realization

• Unique product identification
• Controlling and recording product identification
• Identifying the product status for monitoring purposes

5. Measurement, Analysis, and Improvement

• Monitoring and analyzing the process
• Measuring product conformance
• Ensuring conformity with the QMS
• Improving the effectiveness of the QMS

Specified Product Requirements – EV for Japan

• Beef items including offal and variety meats must be derived from bovine animals determined to be 20 months of age or younger
  • Age Verification – Traceable to records
  • A⁴⁰ Physiological Maturity
• Individual Animal Age Verification
• Group Age Verification
• Animals enrolled in an Approved USDA Age Verification Program
• A⁴⁰ - Physiological Maturity
• No Canadian Cattle
• Performed by Certified USDA Meat Graders
• Establishment must:
  • Be an FSIS approved establishment
  • Operate under HACCP
  • Conduct planned internal audits
  • Maintain an approved supplier list
• Excluded materials from all carcasses:
  • Bovine head
    • Including tonsils
  • Spinal cord
  • Distal ileum
  • Vertebral column
    • In accordance with FSIS requirements for removal of DRG from carcasses >= 30 MOA
• Shipping documentation must have the statement “Product Meets EV Program Requirements”
• Company must be listed on the AMS Web site
  • All information on export documentation must correspond with the Web site listing

Specified Product Requirements – Other Nations
(Table)

• EV Programs for other nations
  • 30 months of age or younger
• Hong Kong
  • Dedicated knife to sever the spinal cord for all animals
  • Dedicated splitting saw
  • Only boneless product

Specified Product Requirements

• Updates to the QSA/EV programs are posted on the AMS Web site
• www.ams.usda.gov/lsg/arc/bev.htm

Conclusion

• Everyone must do their part
• Ultimately Industry is responsible to ensure only conforming product is exported
• Only through strict adherence to our trade obligations will market confidence be achieved