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% dirty egg is found by sampling, the inspection is increased by 50% more with respect to 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 custody procedure at the expense of the importer and in the event of a supervening risk, annul the issued certification and order the importer to return, condition or destruction of regulated merchandise depending on the animal health risk.
Physical Errors
Incorrect Labeling
Certification Errors
Product Critical Defects or Physical Anomalies
Customs Broker’s Errors
If there is a reason to reject goods, OISA’s staff will do the following:
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Take photographic evidence of the reason for the rejection to be sent to Central Offices in the corresponding report.
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Goods shall be under custody of SENASICA. Therefore, they may stay in a specific area of PVIZI or in a strapping-secured box. Said strapping shall be noted in the observations of the opinion issued.
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Notify the user that he shall proceed according to Article 72 of the regulations of the Federal Animal Health Act (LFSA); if not, the OISA may act in accordance with the provisions of Articles 73 and 74 of the same LFSA.
b) Inconsistencies and Physical Anomalies of Goods
The OISA personnel at the point of entry into the national territory will verify that the table egg sanitary complies to be imported.
Criteria to classify eggs inconsistencies or defects:
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Shell eggs with strong odors or eggs received in boxes with strong odors will go through ovoscopy and will be cracked separately to determine acceptability.
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When shell eggs are presented for cracking, they will have to be of superior edible quality, and the shell shall be healthy, of good quality, free from dirt and foreign materials attached.
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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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Whites with blood are eggs with diffused blood through the white. Such condition may be present in recently laid eggs, and it is considered a loss.
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Some processing facilities of egg products install black light in the cracking equipment to easily detect these non-edible eggs.
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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 external visible foreign matter aside from the blood spots and meat spots inside the egg.
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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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Liquid egg retrieved from shell egg containers and dripping egg trays.
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Open eggs dripping that appear in washing operations.
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Any eggs showing evidence that contents are or have been exudative before being transferred to the box.
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Rejected eggs from the incubator shall not be introduced in egg processing establishments.
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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 egg and clean egg.
DIRTY EGG
CLEAN EGG
- Examples of Egg Inconsistencies or Defects (Pictures)
c) Quarantine Measures
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 aimed at a load or goods to be 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 measure ordered by SENASICA in Article 45 Fraction II of the Federal Animal Health Law (LFSA) (Refer to the Standards Section) to apply a treatment for a merchandise regulated therein –to make then adequate or prepare them through the introduction of one or several sanitary measures in order to prevent the introduction and dissemination of pests and disease.
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:
1. Presence of quarantine-relevant.
2. Characteristics such as: bad state, color, smell and texture different from the product intended for importation.
3. Whenever the product does not match with what is declared on the international sanitary certificate.
4. 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.
5. 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.
The exporter shall contact AMS’s Sell Egg team as soon as it learns about the rejection providing the shipment details.
-AMS will review the details to determine if the product is eligible to proceed to access the country of destination with modifications for export documents.
-If the access issues cannot be solved in accordance with the importing Country, the buyer/seller shall analyze other options (returning to the US, destruction, reshipping to a different destination).
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:
1. What is the product condition and its immediate packaging?
2. How long has the product been out of the Country?
3. Where has the product been since it was exported out of the US?
4. Under what conditions has the product been maintained?
5. What has been the chain of ownership of the product?
6. Has the product been abandoned any time?
7. Is product labeling in accordance with the US regulations?
8. 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).
9. Is the product in its original packaging?
10. Was the product marketed in the foreign country?
11. Are there any food safety issues associated with the return of this product?
12. What do you plan to do with the product once you return it?
The authorities will review the information and evaluate if goods can reenter the US.
If reentry is allowed, the exporter shall contact a Customs Broker to conduct the necessary formalities before the authorities. Also, AMS (Jeff Shomaker) shall be contacted to follow his instructions regarding the entry process of goods (and likely reinspection).
AMS’s original export documentation should be sufficient, in most instances, together with the Customs Broker’s notice/request of the US to ensure reentry of goods.
In most cases, AMS’s personnel receive a notice when the product arrives at the point of entry on the US border to authorize the uninterrupted transportation to the destination establishment.
If you wish to know contact information of the personnel with USDA/AMS, you may click on the following link: https://www.ams.usda.gov/sites/default/files/media/QADJobFunctionDirectory.pdf
This link provides details from APHIS on the basic steps to take to return inspected products: https://www.aphis.usda.gov/aphis/ourfocus/animalhealth/animal-and-animal-product-import-information/returned-goods
e) Salmonella & 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 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.”
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.
Regarding the controls on the traceability to the batch of the farm of origin, all the eggs to be exported must be returned from flocks registered in the National Poultry Improvement Program (NPIP). The USDA inspector at the egg processing facility maintains a record of all serially numbered NPIP forms for each flock. The USDA monitors the segregation and labeling of the eggs they reach from all laying hen houses, affected by the location, prior to processing.
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.
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.
The USDA also monitors the coding of the package date, expiration date, processing plant facility number, and the application of the USDA export number seal on the labeling of the washed, sanitized, and packaged product. NPIP certificates, segregation procedures, and package labeling are used for traceability to source flocks. All egg shipments are accompanied by this documentation and this is verified by the USDA, prior to certification at the facility where the eggs are collected for the shipments.
Egg manufacturers and processors must have a system that allows all ingredients used to be tracked, from raw materials to the finished product. The requirements include:
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Keep records of the components used by all suppliers.
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Keep records of the companies to which you have supplied products.
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Link records to test results.
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Inform the authorities in case of emergency.
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Label or mark all semi-finished and finished products appropriately.
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Work within an integrated and preventive quality management system.
The following aspects can be taken into account to have an effective traceability system in table eggs:
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Labelled.
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Laying date.
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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 installation number of the processing plant.
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Health certificate.
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And any seal or brand that the authority has expressed in the products or their packaging.
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
Goods (poultry meat) 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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Make sure that what is physically sent matches the documentation submitted.
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Palettize 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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Make sure the temperature is appropriate depending on the state of the goods (dried, fresh or frozen).
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Make sure the temperature is appropriate depending on the state of the goods (dried, fresh or frozen). It is recommended that the signature of USDA’s official who signs the sanitary certificate of origin shall be using a different color than black.
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All certificates and letterheads 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 the packing, harvest and expiration dates using the following format: day/month/year.
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Labels shall not be adhered onto the plastic wrapped around the boxes.
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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 health 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 pertaining to the goods.
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Mexican Customs requires that invoices and certificates of Country of Origin show full addresses, including the city/state and the postal code.
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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 or labels shall be rejected. Mexico shall not accept hand-written corrections, erasures, text out of line, corrections or crossing-outs.
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All health certificates for live animals exported to Mexico SHALL NOT have abbreviations –except for: abbreviations by the issuer, the consignee and the accredited veterinarian, and endorser (of VMO field).
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The cold chain shall be maintained for table eggs during the entire process, i.e. until the final point of sale.
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Table eggs shall be packed in new cardboard boxes sealed with tape, or packaged in cardboard cartons. They shall be stacked over disinfected pallets and plastic-wrapped for stability. Each box or pallet with cardboard cartons shall be identified with USDA’s stamp.
Safe-Handling Instructions
To prevent bacterial diseases: keep eggs refrigerated; cook eggs until yolks are firm; and fully-cook egg-containing foods.
