Detection of Inconsistencies in Goods
a) Reasons for Most Common Health Rejections and Procedures to Be Followed Depending on the Inconsistencies Found.
If more than 10% of dirty eggs are found by sampling, the inspection is increased by 50% more than the sample boxes inspected; if the pattern repeats or increases, reject the lot.
In the case of imports and depending on the zoosanitary risk, the Secretariat may determine the quarantine guardianship procedure at the expense of the importer and in case of a supervening risk, nullify the issued certification and order the importer the return, conditioning or destruction of regulated goods depending on the animal health risk.
Physical Errors
Incorrect Labeling
Certification Errors
Product Critical Defects or Physical Anomalies
Customs Broker’s Errors
When there is a rejection of the merchandise, the OISA staff will do the following:
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Take the photographic evidence that motivated the rejection to be sent to central offices in the corresponding report.
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The merchandise must remain in the custody of SENASICA, so it may remain in a specific area of the PVIZI or in a strapped box. Said strap must be established in the observations of the opinion issued.
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Notify the user that he must proceed in accordance with Art. 72 of the LFSA Regulations; otherwise, the OISA may act in the terms indicated in Art. 73 and 74 of the RLFSA itself. (see the section on regulations).
b) Inconsistencies and Physical Anomalies of Goods
Criteria to classify eggs inconsistencies or defects in hatching egg:
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White rots, mixed rots, green whites, eggs with diffused blood in the albumin or in the yolk, stuck yolks, embryos developed in or beyond the blood ring, mildew on eggs, sour eggs, any other eggs rotten or dirty, including the following:
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Large blood spots or meat spots in an egg require to classify it as a loss.
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Aside from any other dirty or rotten eggs, including the following:
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Any eggs with a missing portion of the shell and shell membranes, and with the egg contents attached or in contact with the outside of the shell.
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Any egg with dirt or foreign matter attached to the shell and with cracks on the shell and the shell membranes.
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Fecal matter.
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Hazardous foreign materials (glass or plastic).
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Non-hazardous foreign material (insects or soil).
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Feathers, hair, lint or skin.
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Other defects (which individually or as a whole, would seriously affect the appearance or utility of the product; it shall be considered critical)
Description of defects for dirty and clean eggs.
DIRTY EGGS
CLEAN EGGS
-Examples of Egg Inconsistencies or Defects (Pictures)
c) Quarantine Measures
Reasons to apply a quarantine measure.
When SENASICA rejects the goods (deeming that the request to get the importation certificate does not meet the requirements), it shall issue a letter indicating the corresponding quarantine measures. These may be:
i. Return
Action arrange by SENASICA in it´s article 45 provision II of the Animal Health Law, aimed at a load or goods to be treated in order to adequate or prepare with the sanitary measures with the intention to avoid returned to the Country of Origin or country of departure, or to a third Country accepting it, when animal health measures are not met.
ii. Conditioning
Sanitary measures ordered by SENASICA in Article 45 Fraction II of the Federal Animal Health Act (LFSA) (Refer to the Standards Section) to apply Chemical, physical or other treatments to eliminate, remove, diseases and avoid the introduction to national territory.
iii. Destruction
Sanitary measures ordered by SENASICA, by which goods intended to be imported into Mexico are disabled due to the fact that they do not meet the applicable regulations and/or pose a sanitary risk for the Country. Expenses incurred in derived from this action shall be paid by the user.
The rejection or negative resolution regarding the shipment formality shall be issued in the following instances:
i. Presence of quarantine-relevant.
ii. Characteristics such as: bad state, color, smell and texture different from the product intended
for importation.
iii. Whenever the product does not match with what is declared on the international sanitary
certificate.
iv. If there are labeling errors and/or data inconsistencies between the label and the documents, the
entire shipment will be deconsolidated to detect all labeling inconsistencies.
v. If the General Animal Health Office (DGSA) issues specific risk mitigation measures, OISA’s staff
will verify such measures are applied.
d) Procedure to Return Rejected Goods to the US
The corresponding OISA shall issue a rejection opinion through the VDMCE specifying the reasons for rejection of goods. The Customs Broker and/or importer shall write a letter –preferably on lettered paper and with the original signature. It shall be sent to the Customs personnel in question informing about the goods rejection, and attaching background support and documents for the corresponding shipment for the Customs personnel to be informed, and to schedule, together with the Customs Broker, the day and time for the return of the goods. Once the vehicle has the goods, it shall leave the bonded warehouse/ verification point where it is, and go back to the US. Thus, the Customs and OISA’s personnel shall verify that the transportation with the goods returns to the country of origin through the correct fiscal route.
Together with the above, the exporter of goods to the US and/or its Customs Broker shall notify CBP at the border through which the goods will return, with a signed free-text letter answering to the following questions:
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What is the product condition and its immediate packaging?
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How long has the product been out of the Country?
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Where has the product been since it was exported out of the US?
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Under what conditions has the product been maintained?
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What has been the chain of ownership of the product?
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Has the product been abandoned any time?
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Is product labeling in accordance with the US regulations?
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Product was rejected by a foreign Government, if so, what are the reasons for rejection? A copy of the (rejection) report may be required from the foreign inspection (SENASICA).
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Is the product in its original packaging?
The authorities will review the information and evaluate if goods can reenter the United States of America.
If reentry is allowed, the exporter shall contact a Customs Broker to conduct the necessary formalities before the authorities.
This link provides details from APHIS on the basic steps to follow to return inspected products: https://www.fsis.usda.gov/inspection/import-export/export-guidance
e) Salmonella and Avian Influenza
Salmonella
FDA has implemented regulations to help prevent egg contamination in the farm or during transportation and storage. It requires that all shell egg boxes that have not been treated to destroy Salmonella have the following safe-handling statement:
Shell eggs that have been pasteurized to destroy Salmonella do not need to have the Safe-Handling Instructions, but signs will usually say that they have been treated.
Avian Influenza
Avian Influenza, caused by Avian Influenza Type “A” Virus, may affect several poultry species (chickens, turkeys, quails, guinea hens, etc.), as well as companion birds and wild birds. Some strains may cause high mortality rates. The virus has been isolated in some mammal species, including humans, rats, mice, weasels, ferrets, pigs, cats, tigers and dogs.
There are several virus strains of Avian Influenza that are classified in two categories: Low-Pathogenic Avian Influenza which usually creates few clinical signs or none in birds; and Highly-Pathogenic Avian Influenza which produces serious clinical signs and/or high mortality in birds.
Strict measures taken both in the US and Mexico for surveillance and control of Avian Influenza are aimed at preventing foods with any possible health risk from reaching consumers. Therefore, affected or suspicious farm birds are euthanized; and rigorous control and follow-up measures are adopted in their environment, making sure that animals and their products do not contribute to spreading the disease.
f) Traceability
In accordance to the definitions of traceability by the Codex Alimentarius and the Federal Animal Health Law, respectively, traceability is:
“Series of systematic technical and administrative activities that allow to keep track of processes related to birth, rearing, feeding, reproduction, harvesting and processing of an animal, animal products, and chemical, pharmaceutical, biological and food products for animal use or animal consumption until their final consumption –identifying in every step, its spatial location and, as applicable, animal health and contamination risks that may be present in each one of the activities.”
The person responsible for goods at origin must establish an identification and registration system that clearly links the merchandise by place and date / time of processing with specific USDA contracts and destinations.
Therefore, traceability is the possibility to find and trace back, throughout all production, transformation and distribution steps of a food or substance aimed at being incorporated in food. Traceability gives credibility and efficacy to the control system for animal safety throughout the food chain.
A good traceability system, plays an important role in protection of consumers’ interest, and gives great benefits for companies, such as:
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It allows to demonstrate the cause of a problem.
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It facilitates the actions taken, aimed at preventing the recurrence of a problem.
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It fosters commercial food safety of products and generates trust in consumers.
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It increases safety and economic benefits for different stakeholders of the supply chain of goods.
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It is a tool to get a high-level of protection of life and health of individuals.
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It contributes with quality assurance and product certification.
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It allows for more efficiency in managing food safety incidents, crises or alerts. This prevents or softens the effects of possible alarms in the population, which so much harm has inflicted on consumers, the industrial sector, as well as the authorities involved.
Certificates issued by APHIS (Veterinary Services) area offices should provide information about the health certificate, including lot numbers, species, origin, and general description of the commodity.
Mexico’s SENASICA requires certain traceability and production information for animal products presented for importation into Mexico (Article 89 and other provisions of the Federal Animal Health Law). Generally, the lot number should be listed on the official animal health certificate in the Product Identification block. Separately, a supplemental declaration from the manufacturing company can be used to provide the additional pertinent information required for the animal product being certified. Typical examples of required information are production date, packing or shipment date, and an expiry date. The manufacturer’s or exporter’s supplemental declaration must be cross referenced to the certificate, and must show the lot numbers as well as the name of the official, their position within the company (acceptable examples: owner, president, quality control manager) and signature. The original and a copy of the supplemental declaration are required at the time of presentation of the product.
If you want to know more about the traceability of merchandise of avian origin you can click on the following link: https://www.aphis.usda.gov/aphis/ourfocus/animalhealth/export/iregs-for-animal-product-exports/sa_international_regulations/sa_by_country/sa_m/ct_product_mexico
The following aspects can be taken into account to have an effective traceability system in hatching eggs:
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Pavilion.
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Sector.
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Records (machines, processes, cleaning, veterinary, temperature, food, drugs, logistics, etc.).
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State / County.
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Type of transportation.
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Lot.
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Weight.
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Size.
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Country of origin.
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Destination country.
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The NPIP number of the farm or hatchery.
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Health certificate.
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Labeling.
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And any seal or brand that the authority has expressed in the packaging of the merchandise.
The monitoring of the movement of a product is linked to commercial information and internal processes and self-controls.
g) Indication and Warnings on Goods
Hatching eggs shipped for importation into Mexico shall comply with the following:
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Boxes or packages shall be arranged and sealed so that during transportation they do not move, flip over, break or get crushed.
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Maintain adequate temperature and ventilation.
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Be sure to send the necessary documentation with the shipment.
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Stack the boxes according to the height specified for transport.
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Keep the good in a clean and ventilated area away from extreme heat or cold.
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Make sure that what is physically sent matches the documentation submitted.
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Palletize and arrange goods appropriately for safety, as well as to have an easy and agile deconsolidation and physical inspection by the authority.
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The Mexican health authority may inspect 100% of goods to be imported. Thus, it is key that each box is duly placed, clean, closed, in order and with fully visible and readable labeling information.
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Labels shall be made of a resistant and durable material with sufficient glue to withstand movement and handling of boxes, as well as to withstand the temperature and humidity in the container.
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To thoroughly check the box or container in order to verify it was completely cleaned and sanitized before the shipping of goods, as well as identify and note any possible damages.
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A digital signature will be used as a substitute for the handwritten signature of the official veterinarian in the endorsement of certificates for fertile eggs and chickens up to three days old. Digital signatures of the accredited veterinarian and the USDA veterinarian will be used.The format will be issued through the Veterinary Export Health Certification System (VEHCS) with a digital signature.
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All certificates and labels must be typed, handwritten documents will not be accepted.
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To verify that the lock or stamp declared on the origin sanitary certificate physically matches the one placed on the transportation; do not break or open until reviewed by the Mexican Customs.
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On the labels, declare dates using the following format: day/month/year.
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Before shipping of the goods, it is important to send to the Customs Broker all required documentation, as well as the photographic support of the load, labels and origin sanitary certificate to make sure all is correct.
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To avoid marking and/or crossing out information with a marker on the boxes, since it may be considered as altered information.
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When an origin sanitary certificate replacement is requested, all duplicates shall be turned in.
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To avoid affix or adhere stamps and information different from that corresponding to the goods.
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Mexican customs require that all country of origin invoices and certificates show full addresses, including city / state and zip code information.
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It is recommended to have a temperature monitor or to record temperature to prove before authorities in case of discrepancies.
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Health certificates shall be registered or processed using a text processor or in a computer. The health certificate number shall also come from a text processor or computer. Hand-written documents shall be rejected. Mexico shall not accept hand-written corrections, erasures, text out of line, corrections or crossing-outs.
