The Canadian Food Inspection Agency (CFIA) Position on Change Over to Specified Risk Material (SRM) Removed Meat and Bone Meal (MBM) Production in Rendering Plant Operations

Rationale

The current ruminant feed ban (implemented in 1997) prohibits the feeding of most protein materials derived from mammals to ruminant animals. At the time the ban was introduced, this was considered to be an appropriate level of risk management for a BSE-free country. However, with the 2003 finding of a domestic case of BSE and subsequent cases, Canada's BSE situation requires an enhanced management approach. The new enhanced ruminant feed ban regulations, which come into force on July 12, 2007, are intended to further mitigate risks posed by the potential cross-contamination of ruminant feeds with prohibited proteins by completely removing SRM from animal feed, pet food and fertilizer.

CFIA's position regarding the change over in rendering plants to achieve compliance with the new requirements recognizes that the removal of SRM-containing materials from the entire feed production system will further reduce the risks posed by cross-contamination. The combination of the existing restrictions and the new enhancements provide a double barrier against BSE exposure for ruminant given that SRM-removed ruminant MBM cannot be fed to ruminants as it continues to be a prohibited material for ruminant feeding.

In order for the rendering industry to meet the new requirements under the enhanced feed ban regulations and assure clients that their products do not contain MBM containing SRM, they will need to provide reasonable assurances that the SRM-containing MBM currently in the their system has been removed in a manner accepted by the CFIA. In the protocol outlined below, the objective is to demonstrate that storage and processing equipment as well as conveyances have been appropriately cleaned and flushed of ruminant MBM containing SRM.

The clean out protocol below outlines the CFIA's considerations regarding the manner in which this can be acceptably accomplished at commercial rendered product manufacturing plants. The use of other methodologies to achieve similar outcomes will be considered by the CFIA. The rendering industry should submit such proposals to the CFIA for endorsement prior to their being undertaken. The approved protocol may also be applied in premises where, after an acceptable clean out is completed, manufacturing of MBM not containing SRM can resume in the event SRM-containing raw material or MBM was accidentally or otherwise re-introduced into the MBM production and distribution system.

Verification

To maintain uniformity across all rendering production facilities, documentation of the clean out and validation procedures to be employed and records that they have been undertaken and completed will be required. The documentation should be dated and signed by the Operator identified on the CFIA Permit to Operate the facility, the Production Supervisor or person designated in the clean out procedures documentation.

Cleaning Protocol

To maintain uniformity across all ruminant MBM production facilities CFIA would anticipate operators would employ very similar measures as those proposed below. If not, prior review and approval of procedures that deviate from those below by CFIA would be required before the flush out is undertaken.

General Facility Cleaning
Cleaning will be required for all inedible raw material handling and MBM processing/storage areas at the facility, not including new facilities/equipment areas designed to handle SRM separately from other raw inedible materials going to rendering. This includes external surfaces of handling systems and equipment, plant floors, etc. Methods of wet cleaning of raw material areas and dry cleaning of finished product (MBM) areas are to be employed. Cleaning is to be conducted in separate areas of the facility in conjunction with clean out of various systems as listed below:

Raw Material Handling Systems
For systems used to convey and grind raw materials previously containing SRM but now dedicated to non-SRM inedible materials from slaughter/processing facilities and/or dead stock operations up to the entry of raw materials into the cooker, contact surfaces of these systems will be pressure washed with hot water. All residues will be removed from the contact surfaces of these systems. Any solids recovered from the treatment of wash and other waste water treatment processes are not to be re-introduced into the raw material handling system for reprocessing once this washing step has been completed.

Cooking Equipment up to Cracklings (unground MBM) Handling Equipment
For enclosed cooking vessels (batch and continuous cookers, evaporators) and meat and bone / fat separation systems post cooking (Including presses, centrifuges and all distribution equipment (augers, elevators, pipes etc.) leading to MBM storage, flushing with sufficient volume of non-SRM-containing material for effective clean out (see validation section below).

Cracklings Handling Equipment to MBM storage (silos, bins, tanks etc.)
For equipment, including hoppers that holds pressed cracklings prior to grinding, grinding and screening equipment and all conveyances for handling cracklings/MBM up to discharge into MBM storage, dismantle equipment and employ dry clean using methods such as vacuuming, sweeping, blow-out with compressed air. For equipment that cannot be dismantled, such as pneumatic pipes, it is to be emptied using air pressure and subsequently flushed with an amount/volume of a non-SRM containing flush material sufficient to represent at least a complete end-to-end fill the piece of equipment.

MBM Grinding, Storage and Load-Out Equipment
For grinders, storage vessels (silos, bins, tanks etc.) and load-out conveyance systems (drag augers, bucket elevators etc.) that are used to empty and load MBM out of storage, dry cleaning using methods such as vacuuming, sweeping and compressed air should be employed. Equipment that cannot be dismantled or opened to facilitate inspection and cleaning, such as sealed unloaders and/or augers, will be emptied as completely as possible using compressed air and subsequently flushed with non-SRM containing material sufficient to represent at least a complete end-to-end fill the piece of equipment. Flush material used during this clean out step is not to be re-introduced into the rendering system.

MBM Transportation Equipment (trailers, rail cars etc.)
For trailers, cars etc. dedicated to MBM transport that previously hauled SRM containing MBM, contact surfaces of the equipment is to be pressure-washed with hot water. All residues are to be removed from the contact surfaces. Special emphasis should be placed on ensuring slide gates have been adequately cleaned.

Validation

In order to validate the effectiveness of the flushing procedures as noted in the above protocol, the CFIA proposes that testing of SRM-removed MBM manufactured following the completion of the cleaning and flushing procedures be undertaken to demonstrate the effectiveness of the measures taken. The use of biological chemical or physical tracers within the context of a validation plan acceptable to the CFIA will be required. Acceptable validation plans will need to include test methods to detect the identified tracer in MBM to a limit of detection of at least 0.1%. The CFIA has evaluated and considers as acceptable tracers, the recovery of DNA from added rice flour and the detection of added titanium dioxide. Additional tracers will be considered by CFIA on the basis of industry proposals.

For additional information on methodology, please contact Sergio Tolusso, Feed Program, CFIA at 613-221-4377.