Q1: Can cattle be "back-verified" for enrollment in to the NHTC Program?
A: No, in order for FSIS to provide export certification for this product, there must be assurances that there are effective controls in all phases of production, from birth to slaughter, and subsequent processing and final packaging activities. If cattle have not been verified prior to leaving the farm of origin, they cannot be considered eligible for the NHTC Program.
Q2: Can an "umbrella" program be used to approve multiple locations (ranches and feedyards) for the NHTC Program?
A: Yes, under the new QAD 1013 Procedure, an umbrella program may be used to approve multiple locations. Section 4.2 and 4.3 must be met.
Q3: What is an "umbrella" NHTC Program?
A: It is a program that is controlled by one company but involves other suppliers of cattle. An "umbrella" NHTC Program addresses all requirements for the entire supply chain within the scope of the program. Companies listed as Cattle Management Groups on the Official Listing of Approved Sources of Non-Hormone Treated Cattle are considered to have an “umbrella” NHTC Program and are responsible for developing and maintaining the program and for ensuring that the requirements are met throughout the entire supply chain.
Q4: Who may have an approved NHTC Program?
A: Any supplier of cattle or beef, including packers, fabricators, cold storage facilities, forwarding warehouses, feedlots, producers, cooperatives, auction markets, or buyers.
Q5: Can a company meet the specified product requirements through a USDA Process Verified Program?
A: Yes, a company may meet the specified product requirements through a USDA Process Verified Program.
Q6: Must a company meet the requirements outlined in Section 4 of GVD 1013 Procedure, if the specified product requirements are met through a USDA Process Verified Program?
A: Yes, the company must meet the requirement outlined in Section 4 of QAD 1013 Procedure if applying a USDA Process Verified Program.
Q7: When must the program compliant ear tag (PCT) be applied?
A: The ear tag must be applied as soon as possible after birth but no later than prior to the animals leaving the place of birth. However, if conforming animals are commingled with non-conforming animals at the place of birth, there must be a method to ensure identification and traceability.
Q8: What is conforming product under the NHTC Program?
A: Cattle that are in the program and can be verified with documentation as meeting the requirements of the NHTC Program.
Q9: What is non-conforming product under the NHTC Program?
A: Cattle that do not meet, or can not be verified as meeting, the requirements of the NHTC Program.
Q10: What options are available to supply cattle for inclusion in a NHTC Program?
A: A supplier of cattle has 2 options to qualify his/her cattle for the NHTC Program:
1. Have his/her own approved NHTC Program, which allows the supplier to send cattle to any approved NHTC Program; or
2. Participate in an "umbrella" NHTC Program, which allows the supplier to market cattle directly to the company under which he/she is approved or directly to any approved NHTC Program.
Q11: Do cattle have to be approved under a NHTC Program to qualify for export?
A: Yes, cattle must be approved under an NHTC Program to qualify for export.
Q12: Are suppliers of cattle under an "umbrella" NHTC Program audited by USDA, AMS?
A: No. However, the USDA may review suppliers of cattle while auditing the company's “umbrella” NHTC Program to ensure Program requirements are met.
Q13: What are the documentation requirements for a supplier within an "umbrella" NHTC Program?
A: Each supplier must maintain a quality manual that addresses the requirements of QAD 1002 Procedure and QAD 1013 Procedure, as applicable for that location or type of supplier. This quality manual may be a standard manual developed by the company with site specific procedures and records.
Q14: Are the cattle tested for use of HGPs?
A: All establishments approved for export of meat and/or offal to the EU are required to participate in the EU Additional Residue Testing Program, which is administered by FSIS. In accordance with Directive 96/23/EC, a targeted number of samples are collected and analyzed for the presence of residues. These monitoring samples are tested at industry expense by independent laboratories participating in Agricultural Marketing Service’s European Meat Export Laboratory Program. The results, which are reported to both plant management and FSIS, provide verification of the effectiveness of the program to prevent use of hormones in cattle intended for the EU.
Q15: What happens if HGPs are identified during the testing?
A: In the event that a confirmed violative positive result is reported by the laboratory, FSIS will notify AMS. AMS will immediately suspend all approvals for applicants in the product chain of custody pending a complete investigation. Suspension will remain in effect until objective evidence is provided that the system has been completely purged of all affected products and an on-site audit verifies that effective corrective action has been taken. Each phase or ownership stage will independently have to demonstrate that their system requirements are adequate and are meeting the standard prior to reinstatement of the NHTC Program, in accordance with AMS guidelines.
Q16. What periodic testing mean?
A: USDA interprets periodic testing as at least 2 times per year.