final report of an audit carried out in namibia from 19 february to 01 ...

Ref. Ares(2013)2555173 - 02/07/2013
EUROPEAN COMMISSION
HEALTH AND CONSUMERS DIRECTORATE-GENERAL
Directorate F - Food and Veterinary Office
DG(SANCO) 2013-6774 - MR FINAL
FINAL REPORT OF AN AUDIT
CARRIED OUT IN
NAMIBIA
FROM 19 FEBRUARY TO 01 MARCH 2013
IN ORDER TO EVALUATE THE OPERATION OF CONTROLS OVER THE PRODUCTION OF
FRESH BOVINE AND OVINE MEAT, FARMED AND WILD GAME MEAT DESTINED FOR
EXPORT TO THE EUROPEAN UNION, AS WELL AS CERTIFICATION PROCEDURES

Executive Summary
The report describes the outcome of an audit carried out by the Food and Veterinary Office (FVO)
in Namibia from 19 February to 1 March 2013. The objectives of the audit were to evaluate the
official public health controls in place for the export of fresh bovine, ovine and farmed and wild
game meat for human consumption destined for export to the European Union (EU), as well as
certification procedures and the measures taken by the Namibian authorities to address the
deficiencies, the conclusions and recommendations of previous FVO audit reports, in particular
report DG(SANCO)/2011-6120 (hereafter previous report 2011-6120). The action plan received
from the Namibian authorities provided satisfactory guarantees in response to all six but one
recommendation of the previous report 2011-6120. This audit was combined with audit
DG(SANCO)/2013-6782, which reviewed the animal health controls.
The Directorate of Veterinary Service (the DVS) has made huge efforts to adapt the animal
identification and registration system in order to guarantee the 90 day residence period in the EU
approved zone and the 40 day residence period at the last holding before animals are sent for
slaughter. Consequently, guarantees could now be provided to meet the certification residency
requirements for bovine and ovine meat. A number of discrepancies between the registration of
animals in the Namibian Livestock Identification Traceability System (NamLITS) compared with
the actual number of animals present at livestock holdings, or those who died or were slaughtered
as well as some inefficiencies in official controls on the registration of cattle and movement
controls weaken the reliability of the system.
The DVS did not ensure that records of veterinary medicine treatments are kept at all holdings.
The production of fresh bovine, ovine and wild game meat is, in general, in compliance with the
public health attestations laid down in the corresponding model certificates for export to the EU.
The DVS remains weak in their evaluation of systems based on Hazard Analysis Critical Control
Point (HACCP) principles and microbiological criteria for foodstuffs as well as the follow-up of
non-compliant microbiological test results. The situation in one establishment, in particular, is
worrying, as the test results for carcass sampling are regularly positive for Salmonella without
adequate corrective actions being taken by the food business operator (FBO) or the DVS. The
DVS did not take corrective measures for this establishment even though it had recently concluded
that the FBO did not have control over its food safety system.
A number of recommendations have been made to the Competent Authority (CA) with a view to
addressing the deficiencies identified during this audit.
I

Table of Contents
1 INTRODUCTION........................................................................................................................1
2 OBJECTIVES............................................................................................................................1
3 LEGAL BASIS..........................................................................................................................2
4 BACKGROUND..........................................................................................................................2
4.1 EXPORT STATISTICS........................................................................................................................2
5 FINDINGS AND CONCLUSIONS...................................................................................................3
5.1 LEGISLATION AND COMPETENT AUTHORITIES.....................................................................................3
5.1.1 LEGAL BASIS..........................................................................................................................3
5.1.2 FINDINGS.............................................................................................................................3
5.1.3 CONCLUSIONS........................................................................................................................5
5.2 HOLDING REGISTRATION, ANIMAL IDENTIFICATION...............................................................................5
5.2.1 LEGAL REQUIREMENTS............................................................................................................5
5.2.2 FINDINGS.............................................................................................................................6
5.2.3 CONCLUSIONS........................................................................................................................8
5.3 LABORATORY SERVICES...................................................................................................................8
5.3.1 LEGAL REQUIREMENTS............................................................................................................8
5.3.2 FINDINGS.............................................................................................................................8
5.3.3 CONCLUSIONS........................................................................................................................8
5.4 LISTING OF ESTABLISHMENTS...........................................................................................................9
5.4.1 LEGAL REQUIREMENTS.............................................................................................................9
5.4.2 FINDINGS.............................................................................................................................9
5.4.3 CONCLUSIONS........................................................................................................................9
5.5 OFFICIAL CONTROLS AT ESTABLISHMENT LEVEL...................................................................................9
5.5.1 LEGAL REQUIREMENTS.............................................................................................................9
5.5.2 FINDINGS...........................................................................................................................10
5.5.3 CONCLUSIONS......................................................................................................................13
5.6 OFFICIAL CERTIFICATION...............................................................................................................13
5.6.1 LEGAL REQUIREMENTS...........................................................................................................13
5.6.2 CONCLUSIONS......................................................................................................................14
6 OVERALL CONCLUSION..........................................................................................................14
7 CLOSING MEETING................................................................................................................14
8 RECOMMENDATIONS...............................................................................................................14
ANNEX 1 - LEGAL REFERENCES.................................................................................................16
II

ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT
Abbreviation
CA(s)
CCA(s)
DG(SANCO)
DVS
EC
EU
FBO(s)
FVO
HACCP
NamLITS
RFID
Explanation
Competent Authority(ies)
Central Competent Authority(ies)
Health & Consumers Directorate General
The Directorate of Veterinary Service
European Community(ies)
European Union
Food Business Operator(s)
Food and Veterinary Office
Hazard Analysis of Critical Control Points
The Namibian Livestock Identification Traceability System
Radio-Frequency Identification
III

1
INTRODUCTION
The audit took place in Namibia from 19 February to 1 March 2013 as part of the planned audit
programme of the FVO. The audit team comprised 2 inspectors from the FVO. This audit was
combined with audit DG(SANCO)2013-6782, which reviewed the animal health controls.
The FVO audit team was accompanied by representatives from the Central Competent Authority
(CCA), the DVS.
The opening meeting was held on 19 February 2013 with the DVS in Windhoek. At this meeting the
audit team confirmed the objectives of, and itinerary for the audit, and additional information
required for the satisfactory completion of the audit was requested.
2 OBJECTIVES
The objectives of the audit were to evaluate the official public health controls in place for the export
of fresh meat as well as the measures taken by the Namibian authorities to address the deficiencies,
the conclusions and recommendations of previous FVO audit reports, in particular report
DG(SANCO)/2011-6120.
The scope of the audit covered the official controls and certification of fresh bovine, ovine meat,
farmed and wild game meat intended for export to the EU.
The audit team in particular:
• reviewed the systems for certification of animals and meat in relation to the requirements of
Council Directive 96/93/EC;
• reviewed the system for the control and recording of animal movements, including those
controls necessary for certification in accordance with the requirements of Commission
Regulation (EU) No 206/2010;
• assessed the controls in place over the production of fresh meat, in particular bovine, ovine,
farmed and wild game meat, including those controls necessary for certification in
accordance with the requirements of Commission Regulation (EU) No 206/2010.
In particular, controls over bovine and ovine meat and farmed and wild game meat in the
framework of Regulations (EC) No 178/2002, No 852/2004, No 853/2004, No 854/2004 and No
882/2004 as well as Council Directive 97/78/EC were subject to this evaluation. In pursuit of these
objectives, the audit itinerary included the following:
COMPETENT AUTHORITIES
Competent
Authorities
Central
Regional
Local
Comments
Opening and closing meetings, meeting at district
veterinary offices and interviews with local official
staff at establishments visited
FOOD PRODUCTION / PROCESSING / DISTRIBUTION – ACTIVITIES
Slaughterhouses 4
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COMPETENT AUTHORITIES
Comments
Cutting premises 5 One independent cutting plant
Game handling establishments 2
Cold stores 1 One independent cold store
Laboratories 1
Assembly centres 2 Auctions
Livestock holdings 4 One feedlot, one sheep and two cattle holdings
Field abattoir 1
3 LEGAL BASIS
The audit was carried out under the general provisions of EU legislation and, in particular Article 46
of Regulation (EC) No 882/2004 of the European Parliament and of the Council on official controls
performed to ensure the verification of compliance with feed and food law, animal health and
animal welfare rules.
N.B. Full legal references are provided in Annex 1. Legal acts quoted in this report refer, where
applicable, to the latest amended version.
4 BACKGROUND
The previous audit concerning safety of food of animal origin in Namibia was carried out from 31
January to 8 February 2011. The results are described in the report 2011-6120. This report is
accessible on the Health and Consumers Directorate General DG(SANCO) website:
http://ec.europa.eu/food/fvo/ir_search_en.cfm
The action plan received from the Namibian authorities provided satisfactory guarantees in response
to all six but one recommendations of the previous report 2011-6120. Recommendation one of the
previous report 2011-6120 was related to the 90 day residence requirements in the EU approved
area NA-1 and the 40 day residence period in the last holding before sending for slaughter. At the
opening meeting of this audit, the DVS provided an up-date on the guarantees for all six
recommendations. Four recommendations were followed up during this audit.
4.1 EXPORT STATISTICS
The volumes (expressed in tonnes) of beef, ovine and wild game meat exported to the EU, Norway
and Switzerland in 2011 and 2012 as provided by the DVS is given in the tables below. There is no
trade between Namibia and the EU in the fresh farmed game meat, goat meat and minced meat
sectors.
2011 EU Norway Switzerland
Bovine meat 9 924 1 413 21
Ovine meat - 26.4 -
Wild game 44.9 - -
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2012 EU Norway Switzerland
Bovine meat 9 333 1 565 21
Ovine meat 41 81 -
Wild game 110 - -
5 FINDINGS AND CONCLUSIONS
5.1 LEGISLATION AND COMPETENT AUTHORITIES
5.1.1 Legal basis
Article 46.1 of Regulation (EC) No 882/2004 stipulates that official controls by Commission
experts in third countries shall verify compliance or equivalence of third country legislation and
systems with EU feed and food law, and EU animal health legislation. These controls shall have
particular regard to points (a) to (e) and (g) of the aforementioned Article.
5.1.2 Findings
5.1.2.1 Competent Authorities
5.1.2.1.1 Organisation of Competent Authorities
The DVS stated that the organisation of the CAs, their powers, independence and authority for
enforcement remains as described in the previous report 2011-6120.
Observations:
5.1.2.1.2 Supervision
• The Public Health Division of the CCA carried out yearly supervisory audits in the EU
approved establishments. These CCA audits were, as described in the previous report 2011-
6120 still focused on the FBO’s compliance with export requirements rather than verifying
the effectiveness of official controls to ensure that corrective actions are taken when needed
and that documented procedures are updated as appropriate.
5.1.2.1.3 Training of staff in performance of official controls
The FVO audit team did not receive information from the DVS on updates since the previous audit
2011-6120. It has been identified by the FVO audit team that the official veterinarians have
insufficient knowledge of the requirements on microbiological criteria for carcass sampling,
interpretation of test results and corrective actions to be taken in the case of unfavourable test
results and that not all official veterinarians supervising the EU approved establishments are
familiar with the traceability systems in place.
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5.1.2.1.4
Resources
Observations:
• The DVS informed the FVO audit team that the number of staff had further increased since
the previous audit 2011-6120. The occupancy rate is now more than 90% of the established
737 posts.
• Although the DVS had announced during the previous audit 2011-6120 the recruitment of
new staff in order to achieve freedom of Foot and Mouth Disease and Contageous Bovine
Pleuropneumonitis in the Northern Communal areas, the project did not start and no increase
in staff took place. The DVS still plans to start this project.
• The FVO audit team did not see any evidence of a shortage of staff at the DVS in the
carrying out of control activities, with the exception of one establishment visited. This has
also been reported in the previous report 2011-6120. The only appointed official veterinarian
in the multi-activities establishment was only occasionally present for post-mortem
inspections in the period June to October 2012.
• The DVS stated that the frequency of annual on-farm inspections in one district visited,
could not be met due to a lack of staff.
5.1.2.1.5 Organisation of control systems
In response to recommendation two of the previous report 2011-6120 “to ensure that the
guarantees for public health attestation set out in II.1.1. (HACCP principles), II.1.2 (specific
hygiene conditions) and II.1.6 (microbiological criteria for foodstuff) of the model certificates
“BOV”, “OVI” and “RUW” as laid down in Regulation (EU) No 206/2010 are met and adequate
supervision takes place”, the DVS has reviewed by means of Circular V21/2012, the risk based
audit system in order to establish the frequency of inspection visits for the official veterinarian to
ensure that establishments approved for the export of meat to the EU comply with the relevant EU
requirements. The frequency of inspection visits by the official veterinarian may range from two to
twelve month intervals and results from a rating level that is based on the CCA annual verification
audit.
Observations:
• Circular V21/2012 contains confusing information on the scope, the responsibilities for the
official veterinarian and also for the CCA. It refers to incorrect EU legislation and provides
incomplete guidance for controls on HACCP based principles and approval of
establishments.
• The check-list annexed to this Circular V21/2012 contains a number of questions for which
it is unavoidable to respond to without providing conflicting responses. As a consequence,
certain questions were answered with both a satisfactory and a non-satisfactory response.
• In one establishment visited, the set frequency of inspections by the CCA was not followed
by the official veterinarian. In addition, although not authorised to do, the frequency of
inspection visits was reduced by the official veterinarian based on the inspection results.
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• The CCA stated that audits on certification of EU eligible meat took place, but no such
evidence has been provided.
5.1.2.1.6 Documented control procedures
Documented procedures are in place and are described in the previous report 2011-6120.
In response to recommendations one and two of the previous report 2011-6120, the DVS informed
the FVO audit team that documented procedures had been reviewed; in particular those controls
related to the residency period of EU eligible animals, the HACCP based principles and the
inspection frequency for the official veterinarian.
Observations:
• The documented procedures for official controls related to HACCP based principles
contained both confusing and incorrect information. In addition the check-list does not
foresee controls on the relevant criteria for microbiological sampling of carcasses.
• The circular V16/2007 regarding controls on microbiological criteria for foodstuff was not
followed by the official veterinarians in the establishments visited, in particular, the
requirement for the official to verify FBOs' compliances with process hygiene criteria,
FBOs' written procedures on sampling, sample collection, receiving and recording of test
results and corrective actions in case of deviations.
• The DVS staff at livestock holdings must check 80% of the animals for animal
identification. However, the inspection instruction does not lay down the requirements to
cross-check between animals' identification and their registration in the NamLITS with the
number of animals registered and the reading of their individual identification.
• No documented procedures are established to verify the number of animals arriving at the
slaughterhouses and their individual (cattle) or group (sheep) identification as well as action
to be taken in case of non-compliances, for example in case the 90 day residence period is
not met.
• A special instruction has been established for official controls at the feedlot. The check-list
covered controls over feed and feeding practices, veterinary medicine treatment, disease
occurrence and prevention, cattle handling facilities, traceability and animal welfare.
5.1.3 Conclusions
The control system in Namibia has the potential to provide satisfactory assurances regarding
compliance with, or equivalence to, EU requirements.
5.2 HOLDING REGISTRATION, ANIMAL IDENTIFICATION
5.2.1 Legal Requirements
The veterinary certification requirements for the introduction into the EU of fresh meat are laid
down in Regulation (EU) No 206/2010. Point II.2 of the model certificates, in Part 2 of Annex II to
the Regulation, sets out the requirements for animal health conditions and for traceability of bovine
5

animals (with the effect that the CA must have in place a system for holding registration, animal
identification and movement control and recording).
5.2.2 Findings
5.2.2.1 Holding registration
The system of holding registration remains as described in the previous report 2011-6120.
5.2.2.2 Animal identification and registration system, movement controls
In response to recommendation one of the previous report 2011-6120 “to guarantee the 90 day
residency in the EU approved zone NA-1 and 40 day residency on the last holding before being sent
for slaughter”, the DVS informed the FVO audit team that all EU eligible cattle are individually
identified and registered in the NamLITS database. The deadline for implementation of the new
animal identification and registration system was 2 August 2011. Since this date cattle are
individually identified with double yellow ear tags by the age of six months or younger when calves
need to be moved. The individual identification number is composed of eight digits on one visual
tag and one Radio-Frequency Identification tag (RFID - primary tag). If the primary tag is lost, both
tags must be replaced with a new tag linked to the old number. If the secondary tag is lost, the tag
can be simply replaced with a printed tag or a blank tag using indelible marker pen. The secondary
tag must not be replaced if cattle are sent for slaughter or exported. There is no obligation for the
owner to record replacement tags in the herd register. The system to identify ownership by means of
stock branding remains in place.
The identification system for sheep remains as described in the previous report 2011-6120.
The movement permits, which are issued at the State Veterinary Offices contain a declaration to be
completed by the owner at the moment of loading. This declaration includes a statement on the
animals' 90/40 day residency period and an annex with all recorded individual identification
numbers.
The owner must notify the NamLITS within 14 days of registration of the cattle/sheep and within 7
days of arrival by providing the original movement permit. If a permit is not used, the owner has to
declare this to the NamLITS. The DVS updates the NamLITS, which is for 2 out of 19 district
offices delegated to an agency. If a movement permit is not notified within 7 days, the NamLITS
will automatically restrict the movements from both, the arrival and departure holding until
notification is received.
The NamLITS has been further developed since the previous audit 2011-6120 allowing the DVS to
verify the 90/40 day residency periods. This verification function is also made available to
slaughterhouse staff, auctioneers and owners for their own cattle.
Operators of slaughterhouses, auctioneers and some owners of bovine animals invested in readers
and the information about the arrival, slaughter data and departure is sent electronically to the
NamLITS.
The NamLITS is able to provide the movement history of individual bovine animals once identified
and registered.
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In response to recommendation five of the previous report 2011-6120 “to guarantee that records
are kept of treatments with all veterinary medicinal products, for all food producing species”, the
DVS guaranteed that records of treatments with all veterinary medicinal products are kept and to be
specifically checked during farm inspections.
Observations
• At one auction visited, the auctioneer stated that only EU eligible animals passed through
the auction. This was not the case when verified against the NamLITS (some animals were
not registered as being present for 90 days in the EU approved area).
• At this auction, out of 80 movement permits verified, seven were not completed by the
owner regarding the 40 day residence period and for two in addition information was also
missing on the 90 day residence period or residency since birth in the EU approved zone.
• At a second auction visited, there were discrepancies in the number of animals which left
and arrived at the auction. More animals had left than had arrived and the records of the
auction did not match the data available at the State Veterinary Office. The DVS did not
identify this non-compliance in the reconciliation of movements.
• At both auctions visited, animals without a primary tag were separated and were sent back to
the holding of origin.
• In the feedlot visited, the FVO audit team identified one animal with two primary and one
secondary tag. The identification number of the secondary and one primary tag matched, but
this number was allocated for an animal that was present at the farm of origin. The other
primary tag was registered for an animal present at the feedlot that had been moved from the
same farm.
• At one holding visited, the owner did not declare for several years all deaths to the
NamLITS although deaths are recorded in the holding register.
• At two slaughterhouses visited, animals without primary tags are accepted for slaughter by
the FBO without informing the official veterinarian. These animals are declassified by the
FBO as non-EU eligible.
• At slaughterhouses, the official veterinarian does not verify the total number of animals on
arrival and their identification.
• The FBOs at slaughterhouses downgrade systematically animals not compliant with the 90
and 40 day residency periods. The official veterinarian does not investigate non-compliant
animals, in particular those that are not registered as being present for 90 days in the EU
approved zone.
• For some animals examples were seen in the NamLITS of discrepancies between the
recorded slaughter date and the recorded time of death e.g. One animal was slaughtered on 7
December 2012 and time of death was recorded as 10 January 2013.
• Not all slaughterhouses and auctions visited had direct access to the NamLITS.
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• At one holding visited, the owner did not keep records of veterinary treatments other than
the mandatory vaccination. At the feedlot visited, records of treatments with veterinary
medicines were kept and were subject to official controls.
5.2.3 Conclusions
The DVS has made huge efforts to adapt the animal identification and registration system in order
to guarantee the 90 day residence period in the EU approved zone and the 40 day residence period
at the last holding before animals are sent for slaughter. Consequently, guarantees could now be
provided to meet the certification residency requirements for bovine and ovine meat.
A number of discrepancies between the registration of animals in the NamLITS compared with the
actual number of animals present at livestock holdings, or those who died or were slaughtered as
well as some inefficiencies in official controls on the registration of cattle and movement controls
weaken the reliability of the system.
The DVS did not ensure that records of veterinary medicine treatments are kept at all holdings.
5.3 LABORATORY SERVICES
5.3.1 Legal Requirements
The veterinary certification requirements for the introduction into the EU of fresh meat are laid
down in Regulation (EU) No 206/2010. Point II.1 of the model certificates, in Part 2 of Annex II to
the Regulation, sets out the public health requirements to be met. These include the requirement to
satisfy the relevant microbiological criteria set out in Regulation (EC) No 2073/2005 and the special
guarantees concerning Salmonella for consignments to Finland and Sweden.
5.3.2 Findings
The DVS informed the FVO audit team that the Central Veterinary Laboratory is awaiting the final
decision of the South African Developing Countries Accreditation Services. As described in the
previous report 2011-6120, the Food Hygiene Section is included in the scope of the accreditation
for a few detection methods only. This Section is responsible for testing meat samples and
environmental samples for microbiological criteria.
Observations:
Meat samples have been accepted for which the sample forms were not completed e.g. species. The
test results for one slaughterhouse reported in a few cases the results for bovine meat (where the
species was not defined on the sample form) whilst no cattle are being slaughtered in the
slaughterhouse concerned.
A few cases were noted by the FVO audit team for which samples were sent to the Central
Veterinary Laboratory, but the results of tests did not arrive at the DVS or at the FBO. The DVS did
not take any action in order to obtain results.
5.3.3 Conclusions
The Central Veterinary Laboratory is awaiting the final decision on its accreditation, which included
8

the section Food Hygiene for which the scope covers a few detection methods only. A few errors
were identified in the reporting of test results and the handling of samples,which could have easily
been avoided.
5.4 LISTING OF ESTABLISHMENTS
5.4.1 Legal requirements
Article 12 of Regulation (EC) No 854/2004 requires that products of animal origin may be imported
into the EU only if they have been dispatched from, and obtained or prepared in, establishments that
appear on lists drawn up, kept up-to-date and communicated to the Commission.
5.4.2 Findings
The FBOs of export approved establishments annually receive from the CCA a renewal of their
certificate confirming their compliance with the relevant export market requirements, its activities
and species being processed.
As reported in the previous report 2011-6120, the CCA could not provide evidence to the FVO audit
team, based on the follow-up of annual audit reports, that they had concluded that the
establishments were in compliance with the relevant EU requirements.
Observations:
• For one cold store visited, the CA stated that a number of rooms are excluded from EU
approval. No documented evidence is available. The exclusion of these rooms for EU
eligible meat is also not reflected in the FBOs' procedures. The department concerned was
not compliant.
• One recent audit report was seen, which concluded that the FBO of the slaughterhouse did
not have control over its food safety system without the CCA having undertaken corrective
measures with regard to the export of fresh meat to the EU. It concerned the establishment
where the test results for carcass sampling are regularly positive for Salmonella (see point
5.5.2.5 for details).
5.4.3 Conclusions
The list of establishments are kept up-to-date and procedures are in place to verify the
establishments' compliance with relevant EU legislation. The DVS did not take corrective measures
for one establishment for which it has recently concluded as not having control over its food safety
system.
5.5 OFFICIAL CONTROLS AT ESTABLISHMENT LEVEL
5.5.1 Legal requirements
Article 12 of Regulation (EC) No 854/2004 lays down that the CA of a third country of origin has to
guarantee that establishments placed on the list of establishments from which imports of specified
products of animal origin to the EU are permitted, together with any establishments handling raw
material of animal origin used in the manufacture of the products of animal origin concerned,
9

complies with relevant EU requirements, in particular those of Regulation (EC) No 853/2004, or
with requirements that were determined to be equivalent. It also lays down that an official
inspection service supervises the establishments and has real powers to stop the establishments from
exporting to the EU in the event that the establishments fail to meet the relevant requirements.
The animal and public health and veterinary certification requirements for the introduction into the
EU of products of animal origin intended for human consumption are laid down in the product
specific Regulations covered by the scope of the audit, i.e. Regulation (EU) No 206/2010.
5.5.2 Findings
5.5.2.1 Ante-mortem inspection
• The ante-mortem inspection results are reported and with the exception of one case, results
were satisfactory.
• In one case observed, the number of animals slaughtered exceeded the number of animals
inspected (7 out of 270 were not subject to ante-mortem inspection according to the records
verified).
• The consignments of live animals were not accompanied with food chain information or
documents containing equivalent guarantees.
5.5.2.2 Post-mortem inspection
• The post-mortem inspection was carried out by veterinary hygiene assistants (auxiliaries)
working under the supervision of the official veterinarian.
• In one cutting plant the FVO audit team observed that the renal fat was not removed from
four out of six carcasses and consequently the kidneys of the lambs were not subjected to
post-mortem inspection. Some of these carcasses contained also faecal contamination.
• In one slaughterhouse visited, post-mortem inspection results were not available for five of
the ten days of slaughtering.
• In another slaughterhouse visited, the feet were not sufficiently cleaned and both, feet and
mouth were not properly inspected for symptoms of Foot and Mouth Disease.
• The team observed harvesting of wild game (springbok) where the following observations
were made:
• The post-mortem inspection was carried out by a trained hunter. For one carcass
abnormalities were observed, which were not recorded and the head of the animal
did not accompany the meat to the game processing establishment.
• Legs and heads are allowed to be removed. Legs, heads, tongues and mucosa of the
game were not subject to post-mortem inspection. In this respect the instruction for
the hunters and the DVS is not in line with the relevant EU requirements.
5.5.2.3 General and specific hygiene
The main observations regarding structure, lay-out and maintenance are:
• one older part of a cold store visited was not compliant, parts of floors and walls were
damaged, condensation was present and some doors were not pest proof. The FBO did not
have available an upgrading plan for this part of the coldstore.
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• Two establishments were facing ammonia leaks. One cutting plant was recently repaired but
the smell of ammonia was still present. Precautionary measures were taken by the FBO.
• In a second establishment (slaughterhouse) the leakage was a recurrent problem. This
establishment was not well maintained; overhead structures were rusty, accumulation of dirt
and dust was noted. Condensation in the cold store rooms was present and an accumulation
of ice caused wet cartons.
• The field abattoir, specially developed by the hunter for the completion of evisceration and
post-mortem inspection of wild game was designed to a high standard. The abattoir included
non-hand operated hand wash facilities, sterilization facilities for knives and was foreseen
with sufficient light.
The main observations related to the operational hygiene:
• In two slaughterhouses visited, de-hiding of carcasses was not carried out in a hygienic way.
In one slaughterhouse, the anal area was wet after stunning and skin contacted the meat. In a
second slaughterhouse, the de-hiding of the animals was not operated in a hygienic way at
several places on the line.
• In two slaughterhouses, the killing of animals was not operated hygienically: one knife was
used for bleeding, but the oesophagus was also cut through, causing reflux of stomach
content and contamination of meat.
• At the field abattoir, the removal of the anus and the oesophagus of wild game was not done
hygienically.
5.5.2.4 HACCP-based systems
All establishments visited had implemented procedures based on HACCP principles. The following
observations were made by the FVO audit team, which were not reported by the DVS:
• The monitoring of the critical control point in one cutting plant was inadequate.
• The monitoring of results of microbiological criteria for environmental swabs of equipment
and staff was not efficient in four establishments visited, as well as the monitoring of carcass
contamination (visually and microbiological testing).
5.5.2.5 Microbiological testing
• In all slaughterhouses visited, microbiological testing and trend analysis for carcass
sampling was carried out.
• In all four slaughterhouses insufficient action was taken should test results for Salmonella
proved positive and corrective action was not enforced by the DVS. All but one
slaughterhouse applied reduced frequency of sampling for Salmonella, but the sampling
frequency was not increased after positive results were obtained. In one of the four
slaughterhouses the number of samples taken was lower than what should be taken in the
case of reduced frequency. In a second slaughterhouse where positive results for Salmonella
were also identified, the FBO did not sufficiently improve the slaughter hygiene despite
several observations on carcass contamination with hair and faeces being recorded.
• In this slaughterhouse, the FBO took samples for Enterobacteriaceae and Aerobic total
count following both a destructive and non-destructive method. The results of both sampling
methods were not comparable. No action was initiated by the FBO when the trend analysis
for Enterobacteriaceae showed one extremely high result (log 60 was recorded whilst the
actual test results were expressed in 60 cfu/cm²).
11

• In one slaughterhouse results of samples taken on 9 out of 36 production dates had positive
results for Salmonella. The FBO’s action was sampling of final products and if results were
negative for Salmonella, the meat was considered EU eligible. The FBOs’ procedures did
not reflect the imposed actions as required in Article 7.4 of Regulation (EC) No 2073/2005.
5.5.2.6 Traceability and identification marking
• The FVO audit team did not identify deficiencies in the application of health marks and
identification marks.
• Traceability systems in the establishments visited were well developed enabling guarantees
to be provided for certification regarding the origin of the meat and maturation. Where
applicable, the traceability procedures include the procedures to be followed in case fresh
meat is exported via one cold store in the Republic of South Africa.
• In one slaughterhouse, there was a discrepancy in the records of the number of animals that
arrived, the number of animals subject to ante-mortem inspection, the number of animals
recorded in NamLITS as having arrived at the slaughterhouse and the number of animals
slaughtered.
• In one game processing establishment visited, the reconciliation of the number of all game
carcasses sent for processing compared with the arrival records did not match.
• At the cold store visited, copies of or the original health certificates are not kept. Instead the
DVS provides permits for storage, but the permits contain insufficient information to carry
out identity checks.
• The official veterinarians in the establishments visited were not fully familiar with the
traceability systems in place.
5.5.2.7 Maturation of meat
• Procedures were in place in all establishments visited in order to ensure maturation of meat.
In addition to the temperature controls, the FBOs also check the carcasses for pH.
• In one case there was discrepancy in the records regarding the period of maturation of meat.
The de-boning started less than 24 hours after the start of the maturation. The FBO stated
that this was a technical error in the systems’ programming and this error has been rectified
in the meantime. This error was not identified by the DVS.
5.5.2.8 Animal welfare at the time of slaughter or killing
• The DVS could not yet guarantee that animals are fed and provided with bedding after 12
hours of arrival in the lairages.
• In two bovine slaughterhouses, where verified, a new restrainer was installed meeting the
requirements of Regulation (EU) No 1099/2009. In one sheep slaughterhouse, sufficient
people were being used to restrain animals to ensure the effectiveness of stunning.
• Hunting was done efficiently and animals were bled whilst stunned.
5.5.2.9 Documentation of official controls
The DVS issues reports containing the findings and conclusions of official controls. The FBO is
requested to carry out corrective action in order to address deficiencies identified.
Observations:
12

• The official reports did not contain information on controls of microbiological criteria for
carcass sampling.
5.5.3 Conclusions
The production of fresh bovine, ovine and wild game meat is, in general, in compliance with the
public health attestations laid down in the corresponding model certificates for export to the EU.
The DVS remains weak in their evaluation of systems based on HACCP principles and
microbiological criteria for foodstuffs as well as the follow-up of non-compliant microbiological
test results. The situation in one establishment, in particular, is worrying, as the test results for
carcass sampling are regularly positive for Salmonella without adequate corrective actions being
taken by both the FBO and the DVS. The DVS did not ensure that all relevant requirements on
animal welfare are met in the slaughterhouses, in particular the feeding and bedding after 12 hours
of the arrival of the animals.
5.6 OFFICIAL CERTIFICATION
5.6.1 Legal requirements
Council Directive 96/93/EC lays down the general rules to be observed by third countries in issuing
certificates required for exports to the EU, according to the specific EU veterinary legislation.
The specific animal health, public health and veterinary certification requirements for the
introduction into the EU of products of animal origin intended for human consumption, are laid
down in the product specific Commission Regulations, i.e. Regulation (EU) No 206/2010.
Findings:
The DVS provided guarantees to recommendation five of the previous report 2011-6120 that the
signing official is in possession of the necessary supportive evidence for the statements of the
relevant export certificates laid down in Regulation (EU) No 206/2010.
Observations
• The DVS had made the necessary tools available for the signing official to ensure
verification of the 90/40 day residence period of cattle and sheep in the EU approved zone
and in the last holding before being sent for slaughter.
• Despite the circular V 14/2/2/1/2 of 27 January 2011 regarding “update on Council
Regulation (EC) No 810/2010 of September 2010”, where the DVS announced the update of
the model certificate allowing animals passing through assembly centres, old certificates
were still in circulation.
• Bovine meat from one container with origin Namibia was transferred into another container
in the Republic of South Africa. The official veterinarian was not informed by the FBO and
the established procedures for meat exported via the Republic of South Africa were not
followed. The DVS initiated a recall.
• In one slaughterhouse visited a replacement certificate has been issued by the certifying
officer without the DVS being in possession of the original certificate. The procedures for
issuing replacement certificates do not require the return and cancellation of the original
certificate.
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5.6.2
Conclusions
In response to the recommendation of the previous audit 2011-6120 regarding certification, the
DVS has ensured that the signing official is in possession of the necessary supportive evidence for
the statements of the relevant export certificates laid down in Regulation (EU) No 206/2010. A few
issues were raised during this audit regarding procedures for certification, in particular regarding the
issuing of replacement certificates.
6 OVERALL CONCLUSION
The action plan received from the Namibian authorities provided satisfactory guarantees in response
to all six but one recommendation of the previous audit report 2011-6120.
The DVS has made huge efforts to adapt the animal identification and registration system in order
to guarantee the 90 day residency period in the EU approved zone and the 40 day residence period
at the last holding before animals are sent for slaughter. Consequently, guarantees could now be
provided to meet the certification residency requirements for bovine and ovine meat. A number of
discrepancies between the registration of animals in the NamLITS compared with the actual number
of animals present at livestock holdings, or those who died or were slaughtered as well as some
inefficiencies in official controls on the registration of cattle and movement controls weaken the
reliability of the system.
The DVS did not ensure that records of veterinary medicine treatments are kept at all holdings.
The production of fresh bovine, ovine and wild game meat is, in general, in compliance with the
public health attestations laid down in the corresponding model certificates for export to the EU.
The DVS remains weak in their evaluation of systems based on HACCP principles and
microbiological criteria for foodstuffs as well as the follow-up of non-compliant microbiological
test results. The situation in one establishment, in particular, is worrying, as the test results for
carcass sampling are regularly positive for Salmonella without adequate corrective actions being
taken by the FBO or the DVS. The DVS did not take corrective measures for this establishment for
which it has recently concluded as not having control over its food safety system. The FVO audit
team requested the DVS to provide an action plan for this establishment.
7 CLOSING MEETING
A closing meeting was held on 1 March 2013 with the CCA, the DVS. At this meeting the audit
team presented the findings and preliminary conclusions of the audit and advised the CCA of the
relevant time limits for production of the report and their response.
The representatives of the CCA acknowledged the findings and conclusions presented by the audit
team.
8 RECOMMENDATIONS
An action plan, describing the action(s) taken or planned in response to the recommendations of this
report and setting out a timetable to correct the deficiencies found, should be presented to the
Commission within 25 working days of receipt of the report.
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N°.
Recommendation
1. To ensure that the guarantees for public health attestations set out in point II.1.1
regarding Hazard Analysis Critical Control Point principles of the model certificates
“BOV”, “OVI” and “RUW” as laid down in Regulation (EU) No 206/2010 are met.
2. To ensure that the guarantees for public health attestations set out in point II.1.6
regarding microbiological criteria for foodstuffs of the model certificates “BOV”,
“OVI” and “RUW” as laid down in Regulation (EU) No 206/2010 are met.
3. In order to be in a position to comply with the certification and animal traceability
requirements specified in the relevant sections of Regulation (EC) No 206/2010, to
further improve the quality of the data registered in the computerised database, the
Namibian Livestock Identification Traceability System and to ensure that data are
verified during official controls.
4. To further improve enforcement to ensure that records are kept of treatments with all
veterinary medicinal products, for all food producing species in order to reinforce
guarantees of equivalence to the standards specified in Annex I, Part A, point III(8) to
Regulation (EC) No 852/2004, as required by Articles 4(1) and 10 of that Regulation.
5. To further improve the the procedures for issuing certificates and,in particular,
replacement certificates, in order to meet the requirements laid down in Council
Directive 96/93/EC, particularly Article 4 thereof, relating to the integrity of
certification.
6. To ensure that adequate measures are taken for these establishments which fail to meet
relevant European Union requirements in line with the requirements laid down in
Article 12 of Regulation (EU) No 854/2004.
7. In order to enhance the reliability of the guarantees provided in certificates for export
to the European Union and to underpin the actions taken to address recommendations 1
to 6 above, to reinforce the systems for supervision and verification of official controls
and to ensure that all official staff have the necessary skills and knowledge necessary
for the effective performance of such controls. To this end, training should be
provided, in particular in relation to controls on HACCP based procedure (including
testing against microbiological criteria as laid down in Regulation (EC) No
2073/2005); animal identification & movement controls; and traceability of bovine,
ovine and wild game meat.
The competent authority's response to the recommendations can be found at:
http://ec.europa.eu/food/fvo/rep_details_en.cfm?rep_inspection_ref=2013-6774
15

ANNEX 1 - LEGAL REFERENCES
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17

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18