You
have been taking, they have been making mentions about the SRT, I consider it is a subject
that several of the TIFE establishments are already sensitized, perhaps because a request
through electronic mail in February more or less, so that the TIFE establishments
received the SRT electronically and sent it to us so that it could solve one of the observations
that made FSIS about that before the audit, it needed that all the SRTs of establishments
that are eligible to export to the United States had it.
It was done that first review, in reality it is a quite extensive questionnaire as
all of you could observe, so it was done a series of observations and it was resumed
again with you so that they fill it together with the official staff, whether it is assigned
to their plants as well as supervisors.
When Sena Zica received those questions, they were sent to FSIS, so all the information
that is contained in those questions in these moments are already with the US authorities
and as Paco told me, this is one of the new, a new tool that will occupy the US
to make the audit plan, maybe you can answer the question a little bit, what are the establishments
that they are going to visit, because FSIS is going to take into account all the information
that is contained in those questions.
Since the questionnaire is very extensive, I will allow the platic to go further in
which is the function of the SRT, which is its participation in some of the new evaluation
of the equivalence that is being made by the US and of course the offers, if at some
time there was a specific question about its establishments, we will be able to answer
them with pleasure, as from the beginning it was said that they could have the support
of both their doctors and also in central offices, in the end I offer them my e-mail
so that we can have the communication.
Well, then the topic of the platic is the SRT in the FSIS audit, I will refer to it
as SRT is easier for its cycles in English, I had already mentioned previously the implementation
of this new system, which is the Public Health Information System, PHIS, it is a new system
that comes to replace two systems that currently are working for the US, which is where
it receives all the information of the imports, as well as the performance or the inspection
that is done within the plants.
This new system, they have been developing it for some time and its goal is that the
29th of May of this year is already implemented in all the plants of the US, in an auditory
that was done in the US in the last year, the last year, at the end of last year, it
could be observed that all the doctors of the plants that were visited have already implemented
this program, they have already received the training and everything, then if the FSIS
continues with its plan, this 29th of May, it will already be implemented in all the plants.
This system is very complex, it applies to many things, not only the inspection issue,
but it will allow, it is a mathematical model that will allow, in a way, to give a qualification
to each of the inspection systems of each of the countries that are authorized to export
products to the United States and finally, the first appearance of the SRT in this question
is that it is one of the tools for which this PIHS will be implemented, there is a publication
in the website that was made in July 2011 and in this publication is described the process
of evaluation of the equivalence between the systems of veterinary inspection, already
during the transfer in the morning, the subject was taken about what is the system of equivalence
and inspection and how the evaluation is done, in this sense we are going to give the most
quick, in the evaluation process we can consider if it is properly said and call it as a triad
of equivalence, which is in three rubres, which is the documentary analysis, auditory
and inspection points.
The auditors have already taken several talks, everything how they are carried out and what
are the procedures.
In the inspection points, basically this is what will come to be, for example, in each
of the points that will come to be incidents, some species violation or some that exceeds
the permissible limit of some toxic residue, that will also allow you to see the tendencies
that there are of some establishments.
So we are going to take part of the documentary analysis, one of its objectives is to verify
the normal conditions under which the equivalence criteria was established, that is to say that
it continues to be fulfilled with everything that was done at the beginning, the protocol.
The second part would be the review of the procedure of official supervision, it has already taken
quite the talk about how the whole review is done, the official part of how the follow-up
is carried out, that all the criteria are fulfilled and again the analysis of the responses that
were given to the SRT.
We can talk then in this question that the goal of the SRT is going to be to provide
and update the information of six essential components in the equivalence system, which
are the legal authority in food care, the regulations of official supervision, PoEZ,
HAZAP, toxic residues and microbiological programs, as well as the SRT is also a platform
that will allow official authorities of the eligible countries to inform the FSIS which
are some updates that are in matter of health regulation or even that establishments have
changed some control for the reinforcement of food care, this means that the SRT
version of the information is that it cannot change, of course, if the establishments, according
to their analysis, to their HAZAP and to their programs, consider that they are going to implement
a new format or they are going to use an indicator or they are going to change their
masterpieces or their product is going to change in category, you must also get this
information so that food care also informs FSIS and this source of information is continuously
updating itself.
The SRT is also made a SRT for the part of the official veterinary inspection, that
is, the CENACICA already in central offices filled the questions corresponding to the
official part, the other are the questions that are made about the Stiff establishments
and the other part, then also what is the verification method that they do in the case
of official laboratories and authorized, now I'm going to see just what is more focused
on what is the SRT of the establishment, all the questions that come there are based on
the requirements that are given to export countries and that are pointed out in the
Federal Code of Regulations 327.2 for the case of meat and 3.81.196 for the case of
dairy products, in this case there were products. The SRT has a sheet that comes in the instructions
specific to fill each of the rubric of the questions, however here I am going to take
some points not all that consider more important that are in the question of the type of exportation
that the product is made in the plant, that is, an establishment can be a direct exporter,
an indirect exporter can carry out both actions or in its case be an establishment
that is authorized to sacrifice or process some kind of species, but that for the moment
for some other question is not active in its exportation, the other is that the establishment
is making the sacrifice or process of some species that is not eligible to export to
the United States and that its product is only for national consumption.
After the sheet of instructions, you see in the general questions that it comes from
what is the location of the establishment, where is the latitude and other geographical
questions, the rest is the next point is the activity, what is the establishment dedicated
to, for what is the establishment authorized, it is even asked the year in which it was
authorized to be eligible to export to the United States, the other part is the number
of employees, this will allow to give the category that if it is a small, medium, large establishment,
the hours of operation and pre-operative of the establishment, there are rubles where
they come if they have a turn, if they have one or two or up to three turns, the point
of the veterinary inspection official and non-official, in fact this was one of the,
I consider the most recurrent question of all SRT, I did not have another question
to answer via telephone or email, about the doubt that had the plants where they
placed the MBRATIF, if they placed it in the rubles of a doctor paid by the establishment
or a doctor paid by the official, according to the agreements that took place in the last
meeting, as it has already been said previously, the MBRATIF are with the functions of an official
doctor and therefore the only change that was made in central offices to the SRT was
to place the figure of the RATIF within the official inspectors and for the other part
everything is already involved, which are the microbiological aspects and here the aspects,
after this comes what is the HASA category, here your product of agreements should answer
according to the category in which the products that are being elaborated in your plant, in
the medical talk of Aurelio, these categories were already taken and talked about them, 03J
Sacrifices, 03B Crudomolido, 03 Crudomolido, the 03D process thermically with a commercial
treatment, 0E not treated thermically, stable at room temperature, 0F treated thermically
stable at room temperature and others that have already been seen, in fact it was also
made the offer that if the plant was not sure of the category in which it fell its
product, it could be supported in the official part in its doctor and in the state supervision
or in its moment in central offices so that they could be sure of in what category
enters your product.
This SRT there is also a part that involves what are the products or products, after
that follows the cell for what is the origin of raw material, here it is very important
that the establishments place and declare where the raw material comes from with which
the products that are going to be exported to the United States.
All this information has to be linked with everyone because if a establishment receives
raw material from another and does not declare it and then the other establishment in its
SRT says that it provides raw material to the establishment that did not declare, obviously
when crossing the information you will realize that there are establishments that are not
declaring that they are sending their product to other Stiff establishments.
To mention that if you receive raw material from the United States there was no need to
place it, the other important rubric are the exports, which would be the same dynamic
if you are sending a product not directly to the United States but if they are sending
it to another establishment that has authorization to export to the United States, they should
also declare it or even if you send that product to a country that is also eligible
to export to the United States, it must be declared.
The last part of the SRT is quite extensive, which is about the control that is given to
Ecolio 157H7 for the case of establishments where it applies.
With all this brief explanation that is given of the SRT we can consider two important points
of its function, one that is an essential component in the PHS system, the other that
is a platform under which we will be able to have an update of all the information
that we are giving in matter of national regulation and also of the controls within
the plant and very important that the SRT on this occasion will be part of what is
the PHS audit plan, then they will analyze what will influence to be able to determine
by the authorities of the United States what are the establishments that need an audit,
point number one is the analysis of previous audit reports, later there will be a talk
about what observations have been given in previous audits and what will obviously
influence this new one in 2012, the other is the problem that could have existed in
the inspection points, that is, if there is any incident in any particular establishment
that continuously or regularly has had some violation, obviously it will give them more
probability that it could be visited by that plant and then all the crossing that will
give with the information that contains the SRT, basically it is all, I know that there
may be some questions and how much pleasure we solve them, thank you.
If we have questions, there is going to be Gabriela to pick them up, the objective that
we are seeing is to cross systems for the United States, they integrate this report
that they send us in Excel to their system and based on that goes to the retroalimentation,
this retroalimentation that will go to the origins, destinations of the goods, the production
of the establishments, the entry points, link everything that is ports and borders with
what are the establishments that are exporting, internally to their national establishments
links the raw material that they are receiving from here and the inspection activities of
their personnel, all this goes crossing systems and is reinforcing a lot in the PHIS for the
U.S. inspection system that we will have to advance in tasks to try to systematize
keeping the equivalence with them, they ask how much time the company would update the
information.
Good question of the update, if there is any change, it is the obligation of the establishment
inform it to CENACICA to inform it and send the SRT with where it was changed, where
the updates were made and already central offices will take care of making the notification
to FIS.
It is the same question, because what happens if at the date for some reason the information
that was presented, it is simply update our brief information that is in the SRT so
that we are presenting it and there are no differences at the time of the audit visit.
This system sends it to us, we request it and to whom, it is not a system really is
a table of Excel where as I was saying, we are requesting the documental information,
we can say a statement of the establishment that is sent to the U.S. and they, this table
of Excel will be sent to their internal systems so that when they come with the information
they have all the elements to review you on the floor what you declared in your SRT.
So, this system is sent to them, it was sent generally to the areas, to the legal representatives
and their quality areas would be the most indicated people to answer it.
As Teri said, a first proposal basically filled by the establishment, but it was asked
for a joint review with the official personnel to advance together in what is being declared.
We could not receive for a part, nothing more, this report validated by the quality area
without having a cross with the official part, it is very important because at the moment
of the review on the floor, if you declared something that is not agreed with what the
doctor is reviewing or validating, then we will have there a counterpoint in the auditory
on the floor that is going to be done.
So, the first report that was sent, we commented that it was in February and in March it was
sent again to have this cross with the supervisors, with the doctor on the floor.
This is the possibility for an establishment to integrate the system independently so that
there is no possibility for it to co-operate and create a situation of financial crisis
Fíjate que empezamos a ver ese esquema que está avanzando tanto por la parte oficial
de otros países. Tenemos conocimiento de que Australia está integrando ya en un sistema
información de las plantas, de la autoridad que se va directamente a cruzar con el PHS.
Yo creo que la negociación tendría que ir de la parte oficial preguntarle a FSIS si estarían
dispuestos a ellos ya a recibir en una plataforma la información de las empresas mexicanas y esto en este momento, como lo comentas, puede ser un esfuerzo aislado de una empresa de decir yo estoy cruzando, yo tengo ya el sistema, estoy recibiendo capacitación de gente de Australia precisamente para integrar ya mi esquema y empezar a cruzar información.
Podemos hacer las consultas con FSIS para empezar a cruzar si fuera necesario, pero tendremos también que avanzar como sistema completamente para ver qué mecanismos tenemos para cruzar información.
Gracias ateres, y
