Compliance and Assessment Guide for Schedule I and II of the Fish Inspection Regulations (Registered Establishments)
Chapter 4

This page is part of the Guidance Document Repository (GDR).

Looking for related documents?
Search for related documents in the Guidance Document Repository

4.1 Sanitation Program

Regulations

Schedule II Section 1

Every establishment shall implement and comply with its sanitation program.

"sanitation program" means a written program, describing sanitation practices, developed for a registered establishment or for the establishment, conveyance or equipment of a holder of a fish export licence. The purpose of a sanitation program is to ensure that the employees of the establishment or the users of the conveyance or equipment use proper sanitation and hygiene practices, and that the establishment, grounds, equipment or conveyances are maintained in a clean and sanitary condition and free from serious contamination and insect and animal pests.

"serious contamination" means any condition or deficiency that results, or is likely to result, in an unacceptable risk to the consumer or in tainted, decomposed or unwholesome fish.

Intent

All fish processing establishments must implement their documented sanitation program. Food products must not be allowed to become contaminated as a result of poor or inadequate sanitation

Compliance Guide

A registered establishment must have and implement a written sanitation program, documenting the cleaning and disinfecting procedures employed, as part of its QMP.

Details of what is required in a sanitation program can be found in the Interpretive Guidelines in Chapter 3, Subject 4 of the Facilities Inspection Manual, under Prerequisite Plan.

In addition to this guidance and, with the exception of dedicated live fish tank rooms and dedicated raw material holding rooms, all other all processing areas and all equipment and utensils found there in, must meet the following minimum proper sanitation procedures:

  1. Pre-rinse to remove gross debris
  2. Application of cleaner and/or degreaser
  3. Rinse to remove cleaner/degreaser
  4. Inspection of surfaces to ensure that they are properly cleaned (if not repeat 2,3)
  5. Application of sanitizer/disinfectant
  6. Final rinse (if necessary)

Cleaning and sanitizing chemicals shall be used in accordance with the manufacturers instructions.

In order to maintain the establishment, grounds and equipment in a clean and sanitary condition, the written sanitation program must include procedures that will be implemented at the end of each days production for the cleaning and sanitation of process areas, equipment and utensils.  Procedures must be provided, where necessary, for the disassembly of equipment for cleaning/sanitizing purposes.  Coolers or holding rooms containing fish may be cleaned on a reduced frequency providing that they are maintained in a clean and sanitary condition.  Support areas and cold storages shall be regularly swept and kept uncluttered.  Dedicated live fish tank rooms and dedicated raw material holding rooms shall be maintained in a clean and sanitary condition. 

In the case where the process is continuous in nature, these sanitation requirements may be modified if a properly validated (including microbiological validation), written HACCP plan is developed which will ensure that an equivalent sanitation program is used in the establishment.

Failure to meet these minimum requirements should be recorded as objective evidence in the compliance verification of the Prerequisite Program and not assessed as a deficiency in a Schedule II inspection.

If garbage bags are used they must be used in conjunction with a receptacle designed for that purpose.  Garbage must be removed from process areas at least daily.

Assessment Guide Table - Schedule II

Example situations
Table Summary

This table contains the Construction, design, plants and surroundings, including the Worksheet Line Item, Minor and Serious Critical Assessment Guide.

Worksheet Line Item Minor Serious Critical
employees use proper sanitation and hygiene practices Garbage bags not used in receptacle designed for that purpose

employees wiping/picking nose at process line (7)

hoses used in a manner such that over spray or ricochet could contaminate product (non RTE) (7)

cleaning cloths permitted for single application only – reuse not permitted

gross improper hygiene practices (1,2,3,4)

hoses used in a manner such that over spray or ricochet could contaminate product (2)

no serious contamination do not use do not use
establishment, grounds, equipment and conveyances free from insect and animal pests garbage not removed from process areas daily or more frequently as required (8)

evidence of animal pests (i.e., not insects) inside plant (7)

excessive flies in process areas (7)

evidence of non insect pests (droppings, urine, etc.) in or on product, on product contact surfaces or in packaging (3,4)

4.2 Cleaning and Disinfecting

Regulations

Schedule II Section 2

(1) Equipment and material used to clean and disinfect an establishment and processing equipment shall be provided in adequate quantities and be conveniently located in the establishment.

(2) Any product used for the lubrication of fish processing equipment or machinery and any product used for cleaning and disinfection shall be clearly labelled as to its use, stored in an appropriate location and only used by a person trained to use or apply it in a manner that prevents contamination of fish or contact surfaces.

Schedule II Section 11

(2) Unnecessary material or equipment shall not be stored in a processing area.

Intent

Cleaning and disinfecting equipment and supplies must be available to ensure that the sanitation program can be carried out as written. Chemical products for use in cleaning and disinfecting must not be allowed to contaminate food products.

Compliance Guide

Brushes, brooms, hoses and other equipment and materials needed for proper cleaning and disinfecting, in accordance with the establishment's sanitation program, must be available in adequate quantities at all times. Cleaning equipment must be constructed of approved materials; wooden-handled cleaning equipment is not acceptable.

There must be adequate facilities for the sanitary storage of hoses and other cleaning equipment.

All chemical products used in processing areas for the operation of equipment or for cleaning and disinfecting must be listed in the establishment's sanitation program, and their use must be identified.

For a listing of cleaning and disinfecting products that have been found by the CFIA to be acceptable for use in food processing establishments, refer to the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products.

Health Canada has approved the use of ozone for the sanitation of food contact surfaces.

Persons using chemical products should receive training, which can include on-the-job training, on the use of cleaning agents and disinfectants. These persons should be familiar with handling practices and the proper use of all the chemicals included on the processor's list.

Cleaning & Disinfecting
Assessment Guide Table - Schedule II

Example situations
Table Summary

This table contains the Construction, design, plants and surroundings, including the Worksheet Line Item, Minor and Serious Critical Assessment Guide.

Worksheet Line Item Minor Serious Critical
cleaning and disinfecting equipment and material provided in adequate quantity and conveniently located. insufficient equipment and material provided (8) no equipment and material provided (5) Not Generally Applicable

 

Products used for lubrication, cleaning or disinfection:

Table of example situations
Table Summary

This table contains the Construction, design, plants and surroundings, including the Worksheet Line Item, Minor and Serious Critical Assessment Guide.

Worksheet Line Item Minor Serious Critical
clearly labelled as to its use Assess in Section 2.5 Assess in Section 2.5 Assess in Section 2.5
stored in an appropriate location Assess in Section 2.5 Assess in Section 2.5 Assess in Section 2.5
used only by persons trained to use or apply in a manner that prevents contamination of fish or contact surfaces Assess in Section 2.5 Assess in Section 2.5 Assess in Section 2.5
unnecessary material or equipment not stored in process area Assess in Section 2.1 Assess in Section 2.1 Assess in Section 2.1

4.3 Pest Control

Regulations

Schedule II Section 4

Pesticides or any other animal control products shall be applied in a manner that prevents the contamination of fish, packaging, labelling materials and ingredients.

Schedule II Section 5

Animals are not permitted inside an establishment

Intent

Pests and other animals must not be allowed to become a potential source of microbial contamination or foreign matter for food products. Pest control products must not be allowed to become a potential source of chemical contamination for food products.

Compliance Guide

A registered establishment must set up and implement a pest control program as part of its QMP. Details of what is required in a pest control program can be found in the Interpretive Guidelines in Chapter 3, Subject 4 of the Facilities Inspection Manual, under Prerequisite Plan.

Protective devices such as rodent-proof drain outlets and tight-fitting doors must be provided. Fly stickers, insecticidal wall paints, insecticidal strips, automatic dispensers of aerosol insecticides and continuous vaporizers of insecticides must not be used in processing areas, and pesticides must not be stored in processing areas. The use of electrical devices to control flies and other insects is acceptable provided they are equipped with a catch basin and are properly located and maintained in order to eliminate the risk of contaminating food products. Care must be taken when using pest control products in processing areas to prevent dead insects from falling on operating processing equipment and food products.

Assessment Guide Table - Schedule II

Example situations
Table Summary

This table contains the Construction, design, plants and surroundings, including the Worksheet Line Item, Minor and Serious Critical Assessment Guide.

Worksheet Line Item Minor Serious Critical
pesticides and other animal control products applied in a manner that prevents contamination of fish, packaging, labelling materials, ingredients bug light not operational (8)

pesticides or other products applied or located in a fashion which could contaminate product, packaging, ingredients (7)

Electrical insect control devises or capture type bug lights over process line (7)

devices not regularly maintained and cleaned (7)

pesticides or other products applied or located such that product, packaging, ingredients are contaminated (3)
animals not permitted inside an establishment do not use

presence of animals or evidence of animals (i.e. foot prints, droppings etc.) inside processing and support areas (7)

excessive numbers of insects

Not Generally Applicable

4.4 Offal

Regulations

Schedule I Section 15

(1) Receptacles for the effective disposal of fish offal shall be provided, be clearly marked "For Offal Only" or with other similar wording or be colour coded, and be:

  1. equipped with tight-fitting covers, as applicable;
  2. constructed of non-absorbent and non-corrodible materials and kept in a sound condition for ease of cleaning and disinfection; and
  3. if stored outside the establishment, placed on a concrete pad sloped to a drain.

(2) Continuous offal handling systems that carry offal on conveyors or flumes to offal bins shall be constructed so that they pose no threat of contamination to the processing areas or to fish being processed and must:

  1. be equipped with tight-fitting covers;
  2. if located inside the processing areas, be constructed of non-absorbent and non-corrodible materials and kept in a sound condition for ease of cleaning and disinfection;
  3. if located outside the processing areas, be kept in a sound condition for ease of cleaning and disinfection and may be constructed of mild steel or other suitable non-absorbent metal; and
  4. if delivering offal to the interior of the offal bin, be located over or surrounded by a concrete pad of suitable size sloped to a drain.

(3) Vessels, barges or conveyances may be used to store or transport offal to designated gurry grounds or fish meal plants if they are operated in a clean and sanitary manner.

Schedule II Section 6

Fish Offal shall be:

  1. collected in handling systems, receptacles or conveyances that are not used for the holding or transport of fish intended for processing;
  2. disposed of or stored, before disposal, in a manner that will not attract insect and animal pests, allow the build-up of offensive odours or contaminate the area surrounding the establishment; and
  3. removed from the establishment or grounds under the control of the operator of the establishment as frequently as necessary to maintain the sanitation of the establishment, and as specified in the quality management program of the establishment.

Intent

Fish offal must not be allowed to become a potential source of contamination for food products. Offal must be collected, handled and disposed of in a manner that does not attract pests.

Compliance Guide

Bins or receptacles in which fish offal is stored must be clearly marked, watertight, constructed of metal or other approved material and, where necessary to prevent contamination of the establishment or any food products, must have tight-fitting covers. Containers used along processing lines do not require covers.

Containers, bins, receptacles and conveyances used for offal must not be used for holding or transporting fish intended for processing, or for any materials or utensils used in a food processing operation, unless they are cleaned and disinfected after holding offal as specified in the establishment's QMP. Offal bins stored outside must be placed on a sloped and drained concrete pad, and must not be allowed to attract pests or contaminate the establishment's surroundings.

Continuous systems for conveying offal to a fish meal processing area or other final removal point must be constructed of acceptable materials, maintained in a sound condition, and cleaned and disinfected as often as required. They must be designed and constructed so that offal or liquid waste will not contaminate food products or the processing area, and so that they can be effectively and thoroughly cleaned.

Some forms of offal, such as fish skins for glue manufacture and frames and waste for animal feed, require special handling. These types of waste materials may be held in receiving or holding rooms, provided that this does not affect the sanitary operation of the establishment.

Although not specifically required for facilities constructed prior to April 1999, it is strongly recommended that direct access to processing areas be prevented through the use of ante rooms or some other similar construction layout. Facilities having processing areas that have direct access to the outside must take extra precautions to ensure that these areas do not become contaminated as a result. Some deficiencies which would normally be categorized as minor pose a greater risk to the processing area when there is direct access to/from the outside and so when that is the case, these deficiencies will be categorized as Serious (see Schedule II Table for this section).

Offal
Assessment Guide Table - Schedule I

Table Summary

This table contains the Construction, design, plants and surroundings, including the Worksheet Line Item, Minor and Serious Critical Assessment Guide.

Example situations
Worksheet Line Item Minor Serious Critical
offal receptacles clearly marked or colour coded do not use receptacles not colour coded or marked to differentiate from fish receptacles (7) Not Generally Applicable
(a) equipped with tight fitting covers, if necessary offal stored outside with no tight fitting covers (9) Not Generally Applicable Not Generally Applicable
(b) made of approved material and maintained for ease of cleaning do not use

offal receptacles of unapproved material (i.e. wood) in process area (5)

broken/damaged offal receptacle in process area (5)

Not Generally Applicable
(c) if stored outside are on a concrete pad sloped to a drain do not use

no concrete pad (5)

no drain (5)

improper slope (5)

Not Generally Applicable
continuous offal handling systems properly constructed, located and maintained for ease of cleaning. if outside, constructed in a manner that does not permit cleaning (9) if inside, constructed in a manner that does not permit cleaning (5) Not Generally Applicable
vessels barges, conveyances clean and sanitary Not Generally Applicable Not Generally Applicable

 

Assessment Guide Table - Schedule II

Table Summary

This table contains the Construction, design, plants and surroundings, including the Worksheet Line Item, Minor and Serious Critical Assessment Guide.

Fish Offal shall be: - Example situations
Worksheet Line Item Minor Serious Critical
(a) collected in handling systems, receptacles, conveyances that are not used for the holding or transport of fish intended for processing do not use offal receptacle used for fish (7) Not Generally Applicable
(b) disposed of or stored before disposal in a manner that does not attract pests, build up offensive odors, or contaminate surrounding area offensive odours (9)

attracts pests (birds, rodents, insects, etc.) (7)

offensive odours if attracting pests (7)

contaminates grounds of facility (5)

Not Generally Applicable

(b) disposed of or stored before disposal in a manner that does not attract pests, build up offensive odors, or contaminate surrounding area

  • when no anteroom
do not use

offensive odours (7)

attracts pests (birds, rodents, insects, etc.) (7)

offensive odours if attracting pests (7)

contaminates grounds of facility (5)

Not Generally Applicable
(c) removed as frequently as necessary to maintain sanitation of establishment and as specified in their QMP do not use offal not removed from process areas of plant at least daily (7) Not Generally Applicable
Date modified: