Chapter 17 - Ante and Post-mortem Procedures, Dispositions, Monitoring and Controls - Meat Species, Ostriches, Rheas and Emus
17.12 Retained Water in Carcasses and Carcass Parts
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Raw single-ingredient meat product includes dressed carcasses and all their parts (e.g. trimmings, tails, livers, hearths, kidneys, feet, etc.), ground meat and mechanically separated meat, either fresh or frozen.
In the United States of America, raw single-ingredient meat products, including carcasses, carcass parts, offal, etc. are not be permitted by FSIS to retain water resulting from post-evisceration processing unless the establishment preparing those products, demonstrates with data collected in accordance with a written protocol, that any water retained in the products is an inevitable consequence of the process used to meet applicable food safety requirements. In addition, the establishment is required to disclose on the label the maximum percentage of retained water in the raw single-ingredient meat product (see Chapter 11 for export requirements to the US).
17.12.1 Retained Water from Post-Evisceration Process: General Principles
In Canada, processes (e.g. chilling, pathogen reduction interventions) where offal retains water are tolerated on the condition that the operator develops and implements a written, validated retained water control program as per the FSIS policy. However, carcasses and cuts cannot retain water as the result of post-evisceration processing in excess of naturally occurring moisture.
Except for carcass spray chilling processes (see section 17.12.6), once an operator collects valid data indicating less than 0.5% water is retained by the washed and chilled carcasses as shipped or when packaged as portions, no further moisture retention monitoring procedure is required other than a single annual test to verify that less than 0.5% water is retained by the washed and chilled carcasses. Test data and a copy of the corresponding carcass washing and chilling procedures under which data was collected shall be maintained on file and be copied to the Veterinarian in Charge.
A separate evaluation of each species of livestock carcasses including ostriches, rheas, and emus shall cover young (e.g. calves) as well as for mature livestock (e.g. one for heifers, steers, cows, and bulls) is necessary to determine if a particular process promotes water retention.
A no-retained-water statement may be included on the label when product has not been exposed to a post-evisceration process that adds water. Further information on labelling is contained in Chapter 7 of this manual.
The CFIA does not require establishments to use any specific method to make a retained water determination. The method chosen in calculating water absorption and retention, however, should be reproducible and verifiable. For example, an operator may use physical water pick-up tests, weighing the meat product before the direct contact with water and again just prior to final packaging and labelling. Likewise, an operator may make a retained water determination based on laboratory analysis for naturally occurring and total water content of carcasses before and after the application of water for food safety purposes. Further details on laboratory testing is contained at the end of Annex Y-1, US section, Chapter 11, of this manual.
17.12.2 Exemptions for Some Processes Where Water Is Used
The following are examples of post evisceration processes involving the use of water exempted from the retained water policy:
- flushing digestive tracts (stomachs, small intestines, large intestines, rectum, etc.) to remove content;
- scalding of stomachs, tongues, and lips, intestines, and rumen parts; and
- washing the heads.
However, if the scalded, flushed or washed products are then chilled by contact with water and/or ice, then the chilling procedures (only) would require a written and validated retained water monitoring program.
The final carcass wash and antimicrobial wash with organic acids solutions are not exempted and shall be evaluated as to the possibility of an inadvertent moisture pick up.
Note: On a case-by-case basis, the Veterinarian in Charge, in consultation with his or her Regional Veterinary Officer and the Area Red Meat Program Specialist will evaluate other post evisceration processes involving the use of water to determine whether the resulting products require a retained water monitoring program.
Washing offal (e.g.: hearts, livers, etc.) under a shower to remove excess blood is unlikely to promote water retention when followed by chilling on hooks and as such, data collection is not necessary but a warm packing process without dripping after a shower could need to be validated.
17.12.3 Validation of a Process
Common steps like final carcass wash, antimicrobial treatment with solutions of bactericides and cooling of offal in water have a potential to promote the pick up and retention of moisture. Red meat plants shall validate their particular process even if only to demonstrate that moisture pick up does not happen.
Data shall be collected according to a written protocol that contains the elements listed in the checklist "Proposed Moisture Retention Protocol" (Attachment 1, Annex Y, US Section of MOP Chapter 11). Once data is collected, the operator shall examine the data and assess if water is being retained or not.
For offal, if some retained water is the inevitable result of the harvesting or cooling system, a moisture retention monitoring program shall be implemented to ensure moisture retention is maintained to the lowest level.
For red meat carcasses or cuts, if water is retained as a result of the process where it is applied, the process shall be corrected so that no moisture pick up resulting in moisture retention occurs. Validation of the corrected process shall follow once it is implemented.
17.12.4 Monitoring Water Retention in Offal
The CFIA considers that it is possible for all red meat (including ratites) offal cooling processes to achieve a performance where a maximum of 8% of water is retained by the offal.
Once the validation determines the level of retained moisture to be at or above 0.5%, the sample size, sampling frequency and accept/reject criteria for the applicable retained water control program(s) shall be at least equivalent to that specified for poultry giblets, detached necks and salvaged portions described in of Chapter 19 - Poultry Inspection Programs.
The operator using a post-evisceration process that results in water retention in a raw single-ingredient meat product shall maintain on file their written data-collection protocol as well as their monitoring records.
184.108.40.206 Roles and Responsibilities in Monitoring Water Retention
The operator's role and responsibilities are:
- write and validate a proposed monitoring program to control the amount of water for each applicable single-ingredient meat product for which water is added and retained as a result of post-evisceration contact with water;
- label the product according to the requirements of chapter 7;
- submit each written and validated monitoring program to the Veterinarian or Inspector in Charge for CFIA acceptance;
- operate each retained water monitoring procedure according to the corresponding CFIA accepted retained water monitoring program and so as to ensure compliance with the Meat Inspection Regulations, 1990 and this manual;
- inform the Veterinarian or Inspector in Charge whenever changes will be made to operations covered by a CFIA accepted retained water monitoring program;
- obtain CFIA acceptance for any amendments to a CFIA accepted retained water monitoring program;
- maintain a copy of all CFIA accepted retained water monitoring programs on-site; and
- retain all associated records for 12 months on site.
The CFIA Veterinarian or Inspector in Charge's responsibilities:
- assess (in consultation with the Regional Veterinary Officer and the Area Red Meat Program Specialist) submitted new or amended proposed retained water monitoring programs and accept those which are deemed to be satisfactory;
- verify that operations conform to the CFIA accepted retained water programs, check company records and physically monitor the weighing process. Records are to be kept of the verification inspections performed and of the results and retained at least 12 months; and
- verify retained water is declared on the labelled products: e.g. parts of dressed carcasses, offal.
17.12.5 Monitoring Processes where Moisture is Retained
Once validation demonstrates less than 0.5% water is retained as a result of a process, the following applies, except for carcass spray chill monitoring where a special program applies (see next section).
The operating parameters of the process shall be continuously monitored and controlled as part of the HACCP system.
A single annual test to verify that less than 0.5% water is retained by the single ingredient red meat product or chilled carcasses shall be done according to the protocol developed for validation. Test data shall be maintained on file and be copied to the Veterinarian in Charge.
17.12.6 Carcass Spray Chill Monitoring
Carcasses of red meat are not allowed to retain added moisture. Because of the possibility of increasing the weight of the carcass over its hot dressed weight, the following requirement is being imposed on establishments using or contemplating the use of spray chilling for red meat.
The possibility of reduced shelf life in product chilled in this manner is considered to be a quality assurance problem unless a food safety risk is demonstrated.
Management are to put in place a documented control program for moisture pickup in carcasses involving the random selection and weighing of sample carcasses prior to leaving the coolers for shipping or further processing to assure that their weight does not exceed the green weight as recorded on the kill floor after trimming and before carcass washing.
220.127.116.11 Sample Size
The sample size in the following table is based on "Sampling Plans Indexed by Acceptance Quality Limit (AQL) for Lot-by-Lot Inspection", ISO/ 2859-1, (Identical to Canadian Government Specifications Board (CGSB) Standard on Inspection by Attributes 105-GP-1 or Military Standard 105-D (MIL-STD-105D) of the United States Department of Defence). However, the Acceptance Quality Limit (AQL) has not been determined from a baseline survey but has been found to be very low in practice resulting in an AQL of 0.40 being selected for this test. Therefore, throughout the table, the accept number is always zero (0) and the reject number is one (1).
Management are to divide the carcasses into lots of a designated size. The maximum lot size that can be defined is the production from one kill shift. The number of carcasses that make up the sample depends on the lot size according to the following table:
18.104.22.168 Selection of Sample and Weighing
The carcasses to make up the sample are selected at random, prior to the final wash and leaving the kill floor and are identified. Their weights are noted and totalled. In plants where computer tracking systems or their equivalent are installed the information generated by these systems may be used as an alternative for identifying and tracking carcass weights. After chilling, and before further processing or shipping the carcasses are re-weighed and the total combined weight of the sample carcasses is calculated. If the combined weight of the sample carcasses making up an individual lot after chilling is equal to or less than the combined hot green weights of the same sample carcasses taken prior to the final carcass wash when leaving the kill floor then the process is considered to be in control.
To account for scale variability a tolerance of no more than 0.5% over the hot green weight is permissible in the weight of the sample lot after spray chilling. If the combined chilled weights of the sample lot are greater than the combined hot green weights of the sample lot plus a tolerance of 0.5% then the process is considered to be out of control and corrective actions are to be implemented.
22.214.171.124 Interpretation of Results
Although a tolerance of 0.5% is permitted to allow for scale variability on an individual lot basis if any increases over hot, green weight after spray chilling occur routinely then the process will be judged to be out of compliance and corrective action required.
126.96.36.199 Corrective Actions
Corrective actions will include immediately notifying the Veterinarian in Charge or inspection staff of the establishment that the process is out of control. The establishment will begin an immediate investigation of the non-conformance and steps will be taken to correct the process by adjusting spray chill, etc., if required, and the Veterinarian in Charge shall be advised of the corrective action taken.
Product out of compliance shall be detained until brought back into compliance with applicable retained water requirements in the Meat Inspection Regulations, 1990 and this manual.
188.8.131.52 Switching Rules
Initially the normal sample size is to be used until 5 consecutive lots have been found in compliance. At this time the company may switch to the reduced sample size and sample only one out of 5 consecutive production shifts. If at any time a lot is found to be out of compliance, sampling using the normal sample size must be resumed until 5 consecutive lots are in compliance.
184.108.40.206 Record Keeping
The company must keep records indicating the date of slaughter, sample carcass identity, hot green weight and weight prior to further processing or shipping. Records of action taken when non-compliance is detected must also be kept. All records should be retained for at least 12 months.
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