CHAPTER 4

REPORT ON THE IMPORTATION OF COOKED CHICKEN MEAT INTO AUSTRALIA

CHAPTER 4

APPLICATION OF THE PROTOCOL

Introduction

Performance of commercial ovens

Post processing contamination

Certification and verification

Health requirements

Committee's view

Introduction

4.1 This chapter deals with the practical issues associated with AQIS's proposed protocol for the importation of cooked chicken meat. Issues considered by the Committee include:

Performance of commercial ovens

4.2 Industry representatives expressed doubts about whether AQIS had adequately considered whether the time and temperature cooking protocols for chicken meat developed in laboratory conditions could be accurately applied in commercial cooking ovens.

4.3 Mr Luckhurst gave an example of where he considered the processing protocol could break down because of temperature variations in commercial cooking ovens. He advised the Committee of a memorandum from the group general manager for product development at Ingams, Mr Mike Novoselac, who said that variations in temperature of up to 8C degrees temperature differential could occur in "state of the art" commercial ovens when temperature readings were conducted at the same spot at different times.

4.4 Mr Luckhurst indicated that Mr Novoselac, who has many years of experience in the United States operating commercial cooking processes, held severe reservations about the efficacy of the cooking process as a method of preventing disease entry.(1)

4.5 Mr Graeme Bailey, Joint Managing Director, Chickadee Foods, confirmed that variations in temperature in commercial cooking ovens is common and also expressed doubts about the reliability of the cooking process in a commercial environment:

4.6 Dr Margaret MacKenzie, contended that AQIS had little understanding of whether the heating protocol would work in a commercial environment:

4.7 She argued that even with stringent processing protocols, there will be instances of undercooked product entering Australia. She maintained that this was a commercial reality due to the variables involved in cooking, for example:

4.8 Dr MacKenzie concluded that:

AQIS response

4.9 AQIS advised the Committee that the draft importation protocol contains safeguards designed to monitor how adequately chicken meat is cooked. A major component of these safeguards is a requirement that processors fit automatic time and temperature recording devices known as thermographs to all ovens producing cooked chicken for export to Australia.

4.10 AQIS will not require processors to send the thermograph record to Australia. However, AQIS will require that the relevant records be kept for at least a twoyear period and be made available to any AQIS request for inspection.(5)

4.11 Dr Sarah Kahn noted that variations in the performance of commercial ovens are well known but did not present insurmountable problems:

4.12 Dr Kahn concluded that the industry had undertaken to provide advice concerning appropriate means of calibrating recording devices but had not yet done so. She said that AQIS would consider the industry advice and if appropriate, "use that as a guideline or as a reference of some sort when we advise foreign plants of the standards we must meet."(7)

Post processing contamination

4.13 Contamination of cooked food products after processing potentially threatens the integrity of the quarantine protocol and provides a possible means for exotic avian disease outbreaks. Contamination is also a very serious human health issue in cooked products as consumers generally eat such products without any further cooking. If bacteria such as salmonella or listeria are present, the health consequences for affected persons may be very severe, as the recent peanut butter and mettwurst contamination cases demonstrate.

4.14 Contamination of packaging is a related issue. Contaminated packaging may constitute a human health risk if the contaminated surface comes into contact with the cooked product. Contamination of the outside packaging, while less likely to threaten human health, may still constitute a quarantine risk. It is well established that both IBD and ND are durable viruses and could potentially be transported on packaging.

4.15 Dr Margaret MacKenzie and other industry representatives suggested that AQIS had seriously underestimated the risks associated with contamination of the product after cooking and contamination of packaging. Industry representatives claimed that post-processing contamination of the product or its packaging could lead to human health risks or the introduction of poultry diseases. Dr MacKenzie stated:

4.16 Mr Luckhurst agreed that commercial manufacturing of chicken products was "demonstrably fraught with control management and recontamination problems and that is unverifiable after the event ". He submitted that Australia would be accepting the product without any further monitoring for the presence of poultry disease viruses once it arrives in Australia.(9)

4.17 Mr John Clarke, President, Chickenmeat Group, Victorian Farmers Federation, told the Committee that he believed there was a very real risk of importing virulent Newcastle disease as a result of the cooked chicken meat imports. He identified three possible methods which the disease could enter:

4.18 Mr Clarke concluded:

4.19 The Australian Veterinary Association has also expressed concern about the possibility that ND may be introduced on contaminated packaging. The AVA noted that AQIS does not consider that contaminated packaging represents a serious threat. However, the AVA speculated that Australian poultry processors may become importers themselves to retain their competitive position. Under such a scenario, the AVA considered imported and local products would be stored together and contaminated material might be inadvertently transported to Australian commercial poultry farms on vehicles or other materials.(11)

4.20 Mr Luckhurst concluded that the industry remains unconvinced that even Australian "best practice" standards are adequate to prevent re-contamination with ND or IDB virus. He argued that AQIS were acting on assumptions rather than objective data.

4.21 Mr Luckhurst identified two areas of concern. These were:

4.22 He questioned whether AQIS had given adequate consideration to the possibility of airborne contamination and listed several areas that he considered as requiring attention including:

AQIS view

4.23 Dr Sarah Kahn verified that in the case of cooked meat products, contamination is a very important issue, as the product is likely to be consumed without any further cooking. She said however that she considered contamination was predominantly a human health issue:

4.24 AQIS will rely substantially on a preventative approach to post processing contamination to fulfil both food safety and quarantine objectives. Dr Kahn advised that all regulatory authorities, in Australia and overseas, emphasised strict controls on and segregation of cooked product from products in the earlier stages of processing. She noted that most countries are now introducing quality assurance programs such as Hazard Analysis Critical Control Point Processing (HACCP).

4.25 HACCP programs require processors to detect and control critical risk points where there is a possibility of accidentally exposing cooked product to sources of contamination. Dr Kahn explained that an additional benefit of HACCP is that it makes it easier for AQIS to audit and verify the controls that are in those plants. This is because under HACCP, processors must keep records and have a planned system of checks, inspections and response actions.

4.26 Dr Kahn told the Committee that AQIS proposed that the processing plants producing cooked chicken for export to Australia have internationally recognised quality assurance systems such as HACCP in place. This requirement is similar to other countries:

4.27 From a quarantine perspective however, these countries have less at stake than Australia as most have some history of Newcastle disease.

4.28 Dr Kahn advised that AQIS emphasised strict controls and strict prevention of postprocessing contamination, including contamination of packaging material. Mr Hickey explained that it is standard procedure to check how the plant controls packaging material in any review or inspection of a foreign food processing plant:

4.29 While AQIS places substantial emphasis on a preventative approach to post processing contamination, AQIS will also conduct a sampling program of products arriving in Australia.

4.30 AQIS conducts this sampling program on behalf of the Australia New Zealand Food Authority (ANZFA). The objectives of the sampling program are primarily related to food safety issues. However, Dr Kahn noted that it also assists with quarantine issues as the presence of organisms such as salmonella provides an indication that contamination has occurred and avian viruses like ND or IBD may also be present.:

4.31 However, Newcastle disease virus may be present in uncontaminated chicken meat. In previous evidence, the Committee notes that the virus may be present in the tissues of clinically healthy, vaccinated birds, although at lower levels than in birds exhibiting clinical evidence of active disease.

4.32 Mr Stephen Bailey, Principal Executive Officer, Imported Food Inspection Program, AQIS, advised the Committee that testing product on arrival in Australia has significant limitations because of the uncertainties associated with selecting samples for testing:

4.33 ANZFA considers that the limitations associated with sampling may be addressed by implementing a preventative approach to food safety. ANZFA indicated that it is for these reasons that cooked chicken meat produced for importation into Australia must be produced using a recognised quality assurance program such as HACCP. Dr Gordon Burch, Scientific Director, ANZFA, elaborated:

4.34 Mr Bailey concluded that accreditation by the authorities in the exporting countries provided considerably higher levels of confidence that the relevant standards were maintained:

Certification and verification

4.35 The import protocols proposed by AQIS for the importation of cooked chicken meat rely heavily on foreign government certification concerning standards to be observed in the production of product for importation into Australia.

4.36 The integrity of HACCP programs is ensured by a process of inspection and audit carried out by accredited agencies. Mr Bailey advised the Committee that the legislation enables AQIS to accredit a foreign government food inspection agency. He explained that the process of accreditation is rigorous:

4.37 Several witnesses and submissions questioned the reliability of certification processes in the countries seeking to export chicken meat into Australia, particularly Thailand.

Industry concerns

4.38 Witnesses focussed on what they perceived to be shortcomings in aspects of Thai government regulatory activity. Witnesses suggested that if such shortcomings existed, this brought the reliability of the Thai certification process into question. They implied that hence, the reliability of documentation certifying that the products had been produced in accordance with the specifications of AQIS's import protocol may be doubtful.

4.39 Witnesses focussed on two areas of perceived shortcomings:

4.40 Industry witnesses also questioned the adequacy of AQIS's procedures for verifying that the certification process is reliable.

Thai inspection requirements

4.41 Dr Jeffory Fairbrother, Executive Director, Australian Chicken Meat Association and Australian Poultry Industries Association, drew the Committee's attention to Thai regulatory requirements for inspection of chickens during processing. He pointed out that a literal reading of the Thai regulations indicated a stringent inspection process, requiring inspectors to carry out the following procedures:

4.42 Dr Fairbrother indicated that Thai chicken plants process between 6,000 and 8,000 birds an hour, or 1.6 to 2 birds a second. He concluded:

Thai health surveillance system

4.43 Dr MacKenzie told the Committee that Thailand has an inadequate health surveillance system. She said that in response to AQIS's questionnaire on the health status of the Thai poultry flock, Thai authorities indicated that they had no information about whether salmonella enteriditis, a dangerous organism associated with poisoning outbreaks overseas, was present. Similarly, they had no information about the prevalence of salmonella pullorum.

4.44 Dr MacKenzie concluded that the Thai authorities lacked information about the disease status of poultry in their own country and had to rely on the poultry processing companies to supply this information for export.

4.45 The Australian Veterinary Association raised similar concerns to AQIS in a letter dated 27 July 1994. The Association stated that they were also concerned about the quality of disease surveillance in Thailand as Thai representatives had acknowledged they did not know the status of avian influenza, salmonella enteriditis or salmonella pullorum in Thai commercial chicken flocks. Mr Philip Greenwood, the Chief Executive Officer of the AVA concluded:

4.46 Dr Fairbrother advised the Committee that industry considered that the relevant Australian authority should inspect overseas processing plants, including the cooking plant, before AQIS permits importation to proceed. He explained that the industry regarded certification by the exporting countries' authority as insufficient, regardless of their previous performance, because it will be the first time such products will be imported.

Verification

4.47 Industry representatives expressed the view that AQIS's proposals for verifying that importation protocols had been properly observed by the exporting countries are inadequate. Dr MacKenzie summarised the industry's views:

AQIS views

4.48 Committee members questioned AQIS officers about how AQIS proposed to verify that the conditions specified for cooking meat were properly carried out, including observation of procedures to prevent contamination of either the product and or its packaging after processing.

4.49 Dr Kahn advised the Committee that verification of the protocol is a key issue. She explained that verification relies on a system of certification by the exporting health or veterinary authority. The certifying veterinarian, who is usually employed by the government of the country of export, signs a certification setting out the conditions that have been complied with.

4.50 Certification is based on Government to Government understandings. Dr Kahn assured the Committee that in accepting verification by foreign veterinary authorities, AQIS checks the reliability of such certifications:

4.51 Dr Kahn advised that AQIS corroborates the reliability of its assessments by conducting visits to the countries concerned:

4.52 AQIS emphasised that certification by foreign inspection authorities that processors had adhered to Australia's requirements is used for a wide range of products imported into Australia. Dr Kahn explained that other countries to which Australia exports products use the same certification system:

4.53 The Committee sought AQIS's views about the industry and Australian Veterinary Association concerns about the credibility of the certification process in Thailand and the apparent lack of knowledge about disease status on the part of Thai authorities.

4.54 Dr Kahn acknowledged that it is important that AQIS has confidence in the certification that the Thai veterinary authorities are going to provide if importation proceeds. However, she considered that it was a matter for the Thais to decide the nature of the health controls in their own country. Dr Kahn concluded that it is not possible to draw a broad assumption as to the validity of the health certification on the basis of whether the Thais control certain diseases.(27)

4.55 Dr Kahn also drew a distinction between the need for stringent veterinary certification in the case of uncooked meat as opposed to cooked meat. She told the Committee

4.56 AQIS has not yet conducted any visits to Thailand in respect of the proposal to import cooked chicken meat. Mr Hickey emphasised that any final approval to be given for permits for imports from Thailand is subject to an AQIS review of the Thai processing industry.(29)

4.57 In respect of Denmark and the United States, however, AQIS will be accepting certification of the relevant government authorities in those countries subject to AQIS being able to undertake checks from time to time on the adequacy of that system. Mr Hickey emphasised that is the same system that other countries apply to products exported from Australia.(30)

4.58 While depending heavily on certification by foreign authorities, AQIS does carry out random checks to verify that the certifications accompanying goods conform with reality. Mr Bailey explained:

4.59 The random sampling process is conducted by AQIS in accordance with ANZFA requirements. The ANZFA requires samples to be tested for the following agents:

4.60 This testing is conducted primarily for reasons of human health rather than for quarantine purposes. AQIS does not propose to test for the presence of viruses of quarantine concern such as ND and IBD. However, AQIS considers the tests would provide "relevant and valid information" to confirm the performance of processing plants and whether they had employed "good manufacturing practices". AQIS advised that the presence of any of the agents would provide a reliable indication that post processing contamination had occurred.(32)

Health requirements

4.61 Industry maintains that it is essential that the general locality from which birds are taken for processing should be free of ND and IBD. The industry contends that this safeguard is required to provide reserve protection in the event that any other link in the quarantine protocol fails.

4.62 The industry contends that AQIS's proposed requirement that the poultry be "clinically healthy" is insufficient as healthy birds that have been vaccinated may act as carriers for the virus.(33)

4.63 Dr MacKenzie informed the Committee that it is standard practice for other countries to require certification of freedom from disease. She told the Committee that when Australian exporters send cooked or uncooked chicken meat to countries such as Singapore, Japan and the United States, these countries required the Australian Government to sign a health certificate certifying that no cases of malignant poultry diseases have been diagnosed within a radius of up to 50 kilometres from the premises of origin of the birds during the preceding 90 days.

4.64 However, she said that AQIS had continually disagreed with industry about requiring such a health certificate from countries seeking to import product into Australia, despite clear evidence that the countries concerned had Newcastle and other diseases.(34)

4.65 Mr Luckhurst told the Committee that :

4.66 Mr Hickey addressed assertions made at the Maitland hearing by Dr MacKenzie that countries including Thailand required Australia to certify disease freedom. He confirmed that he believed that Thailand, Korea and Japan do require such certification, but this requirement could be satisfied by Australia relatively easily.

4.67 Mr Hickey maintained that a requirement to certify area freedom could not be justified on technical quarantine grounds. He noted that the importation proposal allows for cooked product only and the cooking process would effectively eliminate quarantine risks potentially associated with the presence of IBD or ND viruses in meat. Accordingly, AQIS considers that it is not necessary to impose additional poultry health certification in respect of cooked chicken meat.(36)

Committee's view

4.68 The Committee notes that AQIS acknowledges that the cooking process is very important to maintaining the importation protocols. It is therefore surprising that AQIS has apparently not commissioned or conducted any trials of commercial oven performance in order to determine methods of verifying thermograph calibration.

4.69 Dr MacKenzie's statement that "they have never been to have a look at a further processed plant to understand it" is disturbing. If correct, this statement indicates that AQIS may have failed to back up its theoretical knowledge with practical field trials. The Committee considers that field trials of protocols would provide valuable extra knowledge about the reliability of quarantine safeguards. They would also fulfil the useful function of assuring industry that such safeguards are well designed and reliable.

4.70 The Committee recommends that AQIS commission field trials in a commercial cooking environment to determine appropriate methods of verifying thermograph calibration and performance.

4.71 The Committee is satisfied that AQIS's approach to post processing contamination is appropriate. The preventative approach embodied in quality assurance systems such as HACCP is internationally recognised and should, if properly implemented in the countries exporting chicken meat to Australia, provide substantial protection against both avian disease incursion and pathogens of concern to human health.

4.72 The Committee notes that testing of product samples on arrival will provide a measure of added protection with respect to pathogens of concern to human health, for example, salmonella. However, the Committee considers that this sampling may provide only partial protection against avian diseases, particularly Newcastle disease.

4.73 While the presence of these pathogens indicates the possibility of contamination, it is by no means established that avian viruses will be absent if other pathogens are not detected.

4.74 The Committee is, however, concerned that a lesser level of confidence in Thai certification is acceptable, as indicated by Dr Kahn's statement quoted at paragraph 4.55. The Committee is also concerned that AQIS has not visited the Thai processing plants in respect of the proposed importation despite indicating that AQIS has a lesser degree of knowledge about conditions in that country.

4.75 The Committee considers that AQIS should have conducted inspections of the processing companies in Thailand at a much earlier stage in order to determine whether certification procedures are reliable and processors can satisfy Australia's quarantine requirements. The Committee finds it difficult to understand how AQIS could properly complete its risk assessment without such visits.

4.76 The Committee notes that AQIS has indicated that officers will inspect Thai processing plants before approving importation of cooked chicken meat from that country. The Committee recommends that AQIS conduct inspections of processing plants in all countries seeking to import cooked chicken meat into Australia. The Committee further recommends that industry representatives accompany AQIS officers on these visits.

4.77 Industry has not been without fault. For its part, the industry has been slow to understand and accept the basis of certification procedures between trading countries and the difficulties that Australian exporters would undoubtedly face if such procedures were discontinued.

4.78 The Committee believes that AQIS is placing considerable if not almost total reliance on the integrity of the cooking process to maintain its quarantine objectives in respect of the cooked chicken meat proposal. The reasons the Committee has come to this view are that:

4.79 The Committee notes that AQIS properly emphasises the use of quality assurance procedures in production of cooked chicken meat. However, these are essential to maintain the integrity of the cooking process.

4.80 Given that it is possible that very large quantities of cooked chicken meat may enter the country if the importation proposal proceeds, it is possible that some breakdowns of the protocol will occur.

4.81 The Committee fully understands that any breakdown of the cooking and certification process will not necessarily result in disease outbreaks. However, the Committee believes AQIS's reputation will be irretrievably damaged if IBD or ND enter the country via a cooked chicken meat importation under its control.

4.82 There are currently no simple methods of detecting product that contains IBD or ND once it arrives in Australia. While some testing will be done for pathogens of human concern, these provide only partial indication that avian disease viruses are present. The Committee believes AQIS has glossed over this issue, as the testing that will take place will not reliably indicate that avian viruses are present.

4.83 The Committee therefore recommends that AQIS require area certification from avian disease. The Committee believes that AQIS should follow established international practice with regard to disease certification requirements.

Chapter 5

ENDNOTES

  1. Evidence, 13th September 1996, p. 123.
  2. Evidence, 13th September 1996, p. 203.
  3. Evidence, 13th September 1996, p. 131.
  4. MacKenzie, op. cit.
  5. Evidence, 28th August 1996, p. 20.
  6. Evidence, 30th September 1996, p. 271.
  7. Evidence, 30th September 1996, p. 271.
  8. Evidence, 13th September 1996, p. 131.
  9. Evidence, 13th September 1996, p. 124.
  10. Evidence, 13th September 1996, p. 189.
  11. D. Rayward, Submission No.12.
  12. Correspondence, Luckhurst, 23 October 1996.
  13. Evidence, 28 August 1996, p. 31.
  14. Evidence, 28th August 1996, p. 30.
  15. Evidence, 30th September 1996, p. 259.
  16. Evidence, 30 September 1996, p. 260.
  17. Evidence, 28th August 1996, p. 116.
  18. Evidence, 28th August 1996, pp 116-117.
  19. Evidence, 28th August 1996, p. 116.
  20. Evidence, 28th August 1996, p. 117.
  21. Evidence, 13th September 1996, p. 127.
  22. Rayward, op. cit.
  23. Evidence, 13th September 1996, p. 131.
  24. Evidence, 28th August 1996, pp 20-21.
  25. Evidence, 28th August 1996, p. 21.
  26. Evidence, 28th August 1996, p. 21.
  27. Evidence, 30th September 1996, p.245.
  28. Evidence, 30th September 1996, p. 255.
  29. Evidence, 30th September 1996 p. 254.
  30. Evidence, 30th September 1996, p 225.
  31. Evidence, 28th August 1996, p. 117.
  32. Evidence, 28th August 1996, pp 40 - 49.
  33. Evidence, 13th September 1996, p. 135.
  34. Evidence, 13th September 1996, p. 130.
  35. Evidence, 13 September 1996, p. 124.
  36. Evidence, 30th September 1996, p 222.