UNITED STATES-JBS-SWIFT.
FOOD SAFETY SYSTEMS;
COMMITTEE: HOUSE AGRICULTURE
TESTIMONY-BY: CHANDLER KEYS, III, HEAD OF GOVERNMENT AND INDUSTRY RELATIONS
AFFILIATION: JBS, LLC.
Statement of Chandler Keys, III Head of Government and Industry Relations, JBS, LLC.
Committee on House Agriculture
April 02, 2009
Chairman Peterson, Ranking Member Lucas, and Members of the House Agriculture Committee, I am Chandler Keys, Head of Government Affairs and Industry Relations for JBS USA in Washington DC. As past Vice President of the National Cattlemen’s Beef Association and in my more recent role as a government relations executive for Swift & Company and its successor, JBS, I have had the pleasure of working alongside many of you over the years. I look forward to working with this Committee again in the future as we strive to collaboratively address issues impacting the livestock sector and enhancing the safety of the U.S. food supply.
JBS is currently the world’s largest beef processor - with beef operations in Brazil, Argentina, Australia, Italy and the United States. Currently, our U.S. operations are one of the top three U.S. processors in both beef and pork. We also process lamb in both Australia and the United States. Our U.S. operations are headquartered in Greeley, Colorado, in the congressional district of the Committee’s own, Representative Betsy Markey.
Food safety is the number one priority at JBS. From the moment livestock enter our facilities to the time meat is boxed for shipment to further processors and retailers, we are focused on mitigating risk and ensuring that we provide a safe product. We stand ready to assist Congress and the Administration as you look to enhance meat inspection and food safety through strong science- based and risk-based principles.
Importing Frozen Beef Trimmings from Australia into the U.S.
At the request of the Chairman, I will focus my testimony on our Australian operations and how this division of the company works with Australian and U.S. regulatory officials to ship "fresh and frozen" beef trimmings into the United States. I hope the Committee will find this information instructive to its deliberations on how we can enhance the safety of products regulated by the US Department of Agriculture.
JBS is very familiar with the USDA regulatory regime and its hallmarks of continuous inspection at slaughtering facilities, domestic plant certification, and Hazard Analysis and Critical Control Point (HACCP) requirements. We are also well-versed in the system of equivalency and the requirement that our foreign plants must meet the same food safety and regulatory standards as their U.S. counterparts in order to ship product into the U.S. We have a strong professional relationship with both Australian and American inspectors and regulatory bodies, and the import/export process is handled by consummate professionals who work every day to ensure that the process runs smoothly, efficiently, and effectively without sacrificing the tenets of food safety for the swift movement of product.
Overview
As an importer, JBS’ Australia division is required to submit all imported meat products from Australia for inspection by Federal agencies, including US Customs and Border Protection, which looks for items requiring a duty and contraband, and the USDA, which acts to stop dangerous insects and diseases from entering the country. USDA’s Food Safety and Inspection Service (FSIS) further inspects imported meat products upon arrival into the U.S., determining their fitness for consumption and verifying that no unacceptable or illegal residues are present. This inspection at the port of entry is often considered a "re-inspection" since all JBS Australian meat processing plants are already under in- plant USDA inspection guidelines under the auspices of the Australian Quarantine and Inspection Service (AQIS).
The majority of imported meat from Australia is shipped in containerized sea freight to ports of entry across the United States. JBS operations are consolidated into the major ports across the country; however the majority of our business goes through the ports of Philadelphia, PA, Long Beach, CA and Houston, TX. These three ports are the busiest and most adequately equipped for the importing of fresh and frozen meat products.
Regulatory Requirements
To explain the process of importing beef into the U.S., we must first understand the regulatory requirements - both Australian and U.S. - that an establishment must follow in order to ship to the U.S.
Australian Quarantine and Inspection Service (AQIS)
The Australian Quarantine and Inspection Service, a regulatory body equivalent to the US Department of Agriculture, requires, through Australian Export Control (meat and meat products) Orders, that the occupier of an establishment engaged in the preparation of meat and meat products for export has an "Approved Arrangement."
The purpose of the approved arrangement is to clearly describe those processes and practices which underpin AQIS certification of meat and meat products for export.
The approved arrangement describes how companies like JBS Australia will meet legislative requirements, including compliance with:
-- Good hygienic practices (GHP) to ensure that food is wholesome;
-- The application of HACCP systems for food safety;
-- Product integrity through the application of product identification, segregation and traceability practices ensuring the product is accurately described and maintains relevant importing country identification;
-- Importing country requirements necessary to maintain market eligibility; and
-- Animal welfare requirements.
In addition, Australian producing establishments must be registered by AQIS and "listed" as eligible to export to the U.S. and its territories. All meat, meat products and edible offal must be slaughtered, processed and stored in U.S. listed establishments at all times.
United States Department of Agriculture
In order for Australian product to be eligible for export, U.S. listed establishments must also comply with U.S. requirements. These requirements constitute the hallmark of USDA’s regulation of foreign plants: equivalency.
The Federal Meat Inspection Act requires foreign countries that export meat and poultry into the United States to establish and maintain inspection systems that are equivalent to those of the United States and conform with HACCP systems. Exporting countries like Australia must undergo a rigorous review process before they can become eligible to export meat and poultry to the United States. Even after a country is granted eligibility, FSIS continually reviews its inspection program to ensure it remains equivalent to the U.S. system.
The equivalency standard is a dynamic one. Foreign establishments are subject to the same additional regulatory measures applied to U.S. plants by FSIS. For example, when additional requirements were imposed on U.S. plants to mitigate the risks of Bovine Spongiform Encephalopathy (BSE); our JBS Australia plants had to meet those same standards in order to maintain eligibility to ship to the U.S.
On an annual basis, a representative from FSIS will visit Australia to perform a country review to ensure the Australian systems in place are achieving the requirements or deliver an equivalent outcome as agreed upon by the two countries. JBS Australia regularly has plants involved in these FSIS reviews.
In addition, AQIS performs verification activities to ensure JBS Australia establishments are compliant with U.S. country requirements at all times. These activities are performed through daily, weekly and monthly on-plant inspections by the On-Plant AQIS Veterinary Officer and the AQIS Area Technical Manager.
Understanding Equivalency
JBS Australia establishments have systems in place that comply with the AQI