Inspection of Specified Risk Material (SRM) controls in non-federally registered cattle abattoirs
On this page
- 1. Definitions
- 2. Background
- 3. Inspection of Specified Risk Material (SRM) controls in non-federally registered cattle abattoirs
- Mobile abattoir:
- cattle is slaughtered and processed at the farm (mobile trailer unit equipped to chill and process carcasses) and can be docked to other stationary structures.
The mobile abattoir is generally housed in a trailer custom designed with features for remote area conditions and provides slaughter, inspection and refrigerated transportation services for red meats such as beef, bison, pork, elk, sheep and goats. The front of the unit houses a mechanical room and a cooler with refrigeration capacity for up to 8 bison, beef cattle or elk, 15 hogs, or 20 smaller animals such as sheep or goats. The back half of the unit contains overhead winches for lifting the animal into the dressing bed as well as the equipment needed for skinning and evisceration. The mobile abattoir can also provide refrigerated transportation to a meat processor for cold storage, ageing, butchering and wrapping services.
- Mobile butcher:
- cattle is slaughtered and eviscerated at the farm and the carcass is brought back to a facility for further processing (cut and wrap).
- Mechanically Separated Meat (MSM) and Finely Textured Meat (FTM):
- are edible products obtained by using mechanical pressure to separate muscle tissue from the attached bones. The equipment operates on the differing resistance of bone and soft tissue to pass through small openings, such as sieves or screens. Depending on the composition of the final product, the resulting edible product is referred to as finely textured meat or mechanically separated meat.
Under existing legislation, Specified Risk Materials (SRM) must be hygienically removed from all cattle slaughtered for human consumption in order to prevent tissues that may contain Bovine Spongiform Encephalopathy (BSE) infectivity from entering the human food chain. Once removed the SRM must be segregated, stained and placed into a dedicated, leak proof container with a label indicating that the contents are SRM. Requirements for SRM disposal vary depending on whether or not SRM is being moved from the premises for destruction or containment purposes.
This section applies to operators of abattoirs other than registered establishments, as defined in subsection 2(1) of the Meat Inspection Act, including operators of mobile abattoirs and who in addition to receiving live cattle may accept to receive:
- over thirty month (OTM) cattle carcasses with or without viscera and/or under thirty month (UTM) carcasses with viscera in accordance with a permit to treat SRM
- eviscerated UTM cattle carcasses
It is imperative to understand the legislative framework under which the non-federally registered abattoir is authorized to operate and upon which the non-federal inspection system is based.
This document describes minimum SRM controls that the operator of a cattle slaughter establishment must develop and implement in producing dressed carcasses, cuts and deboned products. The operator must demonstrate ongoing and effective controls over SRM removal, handling, segregation, staining, shipping/ transportation, record keeping and, when applicable, compliance with the Canadian Food Inspection Agency (CFIA) permitting process.
The standards of the SRM controls are designed to meet the following objectives:
- to ensure the hygienic removal of SRM from edible meat during slaughter and cutting/boning operations
- to prevent SRM cross contamination of inedible material destined for the production of animal feed
Responsibility for verifying the effectiveness of SRM controls in non-federally registered cattle abattoirs is shared between the CFIA and the provincial competent authorities within the same province (Provincial Department of Agriculture, Provincial Department of Public Health). The scope of this shared responsibility may or may not be reflected in contractual agreement between CFIA and the provincial competent authority. In the event that the CFIA is responsible for inspection activities, the inspection frequency will be determined by the establishment's risk profile. In provinces where the provincial competent authority carries out these inspections, the CFIA shall conduct annual audits of the provincial inspection system by targeting a number of establishments determined jointly with the provincial competent authority.
3. Inspection of SRM controls in non-federally registered cattle abattoirs
1. The inspectors who will be responsible for conducting the inspection of the particular cattle abattoir will start by gathering the following information. This step is achieved through interview and review of documents such as, but not limited to:
- operator's preventative control plan for SRM
- any applicable quality assurance programs
- previous inspector's reports and Corrective Action Plans
- provincial guidelines and requirements relevant to the SRM removal, handling and disposal
- licensing (authority and process)
- establishment categorization criteria
- communication channels between CFIA and the provincial authority on enforcement and compliance issues
- CFIA's SRM permits
2. The purpose of the interview and documentation review is:
- to verify the layout of the establishment including descriptions of the following:
- where age of cattle is determined
- where, the spinal cord of OTM carcasses is removed
- where the SRM will be contained upon removal from a carcass
- where the SRM will be stored (if temporarily stored for pick-up)
- where the harvested meat will be stored
- where the equipment will be stored
- where the SRM will be disposed of in case of on-site disposal
- to understand how age of cattle is determined; how the meat for human consumption will be harvested and how SRM control is monitored until disposal
- to verify if plant personnel have received training in SRM control procedures including knowledge of the following:
- how age of cattle is determined
- what preventative measures are in place for blood collection
- how the edible meat will be hygienically harvested from the carcasses
- how to handle or remove SRM (for example ability to properly locate small intestine, skull and dorsal root ganglia (DRG) in OTM cattle)
- how SRM removal from each carcass will be monitored (for example spinal cord removal and DRG in OTM cattle)
- what hygienic methods are applied to prevent contamination of edible meat with SRM
- what equipment will be used for the removal of the SRM from the carcasses
- whether the equipment will be dedicated or non-dedicated (cleaned and sanitized after each use)
- SRM staining procedures
- if applicable, how the SRM will be moved for on-site disposal
- who will transport the SRM in case of off-site disposal
- how cleaning procedures prevent SRM from contaminating non-SRM tissues
- contingency plans when trained staff are unavailable
- records that will be kept
3. If any of the applicable elements listed above is not provided during the documentation review and interview, the inspector should inform the owner or operator of the establishment about the areas that are incomplete, request appropriate correction and record them.
4. The pre-inspection information gathered should guide the inspection tasks referred in the section on-site inspection. For example, if no OTM cattle were slaughtered on the day of inspection but UTM cattle were slaughtered with other species, check for cross-contamination in the inedible area of the slaughterhouse (note that casings are recovered for human consumption). The inspector should try to gather information from the operator before the on-site inspection and compare with what was recorded in previous inspection reports or Corrective Action Requests (CARs). For multi-species establishments the inspector should try to arrange for an inspection on a day where OTM or UTM cattle are slaughtered. The inspector should make linkages between questions asked during the pre-inspection and during the on-site inspection.
3.2 On-site inspection
1.1 Use of air injecting penetrating percussion devices or pithing rods for stunning of OTM cattle
During routine slaughter, the use of a penetrating percussion device which injects air into the cranial cavity or the use of pithing rods is not permitted. In the case of ante-mortem condemnation and euthanasia in the lairage (namely non-ambulatory and compromised animals discarded as inedible), the use of such methods may be tolerated provided that the operator has in place a control program ensuring that OTM carcasses are entirely handled as SRM and must not be salvaged for feed or pet food production. Such a control program may include, for example, a marking procedure additional to the usual denaturation policy and/or letter of guarantee from the abattoir operator that must satisfy the receiving rendering/salvaging establishment. The outcome is to demonstrate that the meat operator can clearly segregate any OTM carcasses that have been exposed to such methods from those that have not, as well as ensuring that renderer or salvager receiving such OTM carcasses are fully aware that no protein from these carcasses can be salvaged as pet food or enter the prohibited material stream. Once exposed to such methods, all tissues except hide derived from any OTM carcass are considered SRM.
1.2 SRM cross-contamination of UTM heads as a result of incidental OTM stunning
The incidental stunning of OTM cattle poses a potential risk of SRM cross-contamination of UTM cattle skulls and any Meat and Bone Meal (MBM) produced from them. The domestic use of ruminant MBM is authorized provided that the raw material from which it is produced is not contaminated with SRM. Operators of cattle slaughter establishments are required to implement approved effective measures to prevent SRM cross-contamination of UTM cattle skulls destined for the production of SRM removed Meat and Bone Meal (MBM). Currently, the two (2) UTM carcass heads immediately following the stunning of an incidental OTM must be designated as SRM in order to prevent the SRM contamination of any salvaged by-products for example, MBM. Any establishment wishing to utilize an alternate written procedural proposal to prevent the risk of SRM cross-contamination following incidental stunning of OTM cattle, must submit a detailed written procedural protocol to CFIA or competent authority inspectors. Review and assessments will be done through a collaborative team of CFIA (lead) and where applicable any other competent authorities.
1.3 Blood collection
When OTM cattle are stunned by captive bolt, there is a strong likelihood that blood may be contaminated with SRM (neural tissue). In establishments under ante and post mortem inspection the operator must develop, implement and maintain an effective control system to prevent SRM-contamination of bovine blood that may be used in feeds and food for animals:
- blood collected by open method from age verified UTM will be considered exempted material if it does not contain blood from an OTM cattle (zero tolerance)
- humane stunning using a non-penetrative method (for example, non penetrative captive bolt, electrical kill stunning, ritual slaughter, etc.)
- closed blood collection method (for example, hollow knife or cannula)
- any other method approved by the CFIA or competent authority such as the application of edible grease, tampons or other equivalent devices, and grossly visible brain material is removed from the face plate by trimming, washing, scraping and/or vacuuming Where the nasal cavity has not been compromised, the CFIA will not require any measures from industry to prevent the blood from being contaminated with nasal drip. Compromise of the nasal cavity is considered likely in double stunned or misplaced stunned animals. In such situations the collection of blood is acceptable only if a specific mitigation measure is included in the Preventive Control Plan (PCP). In the absence of ante and post mortem inspection, blood collected from OTM cattle slaughter establishment must be treated as SRM.
1.4 Age determination
To ensure appropriate SRM removal and segregation operators slaughtering UTM and OTM cattle must establish and implement procedures for identifying and separating these two types of cattle from their arrival at the establishment throughout the slaughter process, and during chilling, and/or cutting/deboning operations. The operator can establish age of cattle by:
- Using reliable documentation: The CFIA recognizes the original copies of official birth date documents, issued by registered breed associations, as well as birth date information provided by the regulated database of the Canadian Cattle Identification Agency and Agri-Traçabilité Québec, as reliable documentation for determining the age of animals. CFIA also accepts age determination if it is supported by a document signed by a private veterinarian
- Bovitrace data base: Although not regulated by the CFIA under Part XV of the Health of Animals Regulations, Bovitrace data base considered a reliable source for age verification
- Examining the teeth: Cattle are considered to be aged 30 months or older when they have more than two permanent incisor teeth erupted (namely the first pair of permanent incisors and at least one tooth from the second pair of permanent incisors), a permanent tooth is considered erupted when any part of the tooth is protruding through the gum. This will include teeth that have erupted behind or in front of the existing deciduous incisor. Cattle will be considered UTM as long as the erupting third permanent incisor is not above the surface of the gum. Visual examination of the incisor teeth of each carcass must occur at or before the head is dislocated. The operator examines the incisor teeth of each carcass, and determines if the carcass is derived from an OTM animal. Similarly if an animal's birth date documentation has been deemed acceptable and the head is observed where the fifth permanent incisor tooth is above the gum line, the animal will be deemed an OTM and will be treated accordingly.
When reliable documentation is available, it shall be used as the primary means of determining the age of animals. If the operator of the abattoir elects to age the cattle received, records shall include information regarding the procedures used to determine the age of animals. If age is determined by documentation, the document shall be maintained with the records for a period of two (2) years from the date the animal was received.
Operators may be able to eliminate the need for age determination if they decide to treat all slaughtered cattle, or cattle slaughtered from a particular lot, as being derived from OTM animals. In such a case, SRM would be removed from all carcasses regardless of their age and there would be no need to examine incisor teeth for the purpose of age determination.
1.5 Maintaining OTM cattle carcass age after head removal
The identification of the carcasses of OTM cattle must be done as soon as possible after the carcass has been aged. The operator shall implement an effective method of identification and describe it in the PCP. The method must result in an effective communication with the employee responsible for splitting carcasses in order to ensure the use of appropriate splitting saw. Operators of slaughter establishments may be able to reduce or eliminate the need for certain requirements under this part providing the same outcome is achieved. For example, an operator may decide to treat all slaughtered cattle, or cattle slaughtered from a particular lot, as being derived from OTM animals. In such a case, SRM would be removed from all carcasses regardless of their age.
Finally, operators of all non-federally registered slaughter establishments are required to track the number of OTM cattle slaughtered in the establishment. The number of OTM cattle must be recorded before the carcasses have left the kill floor. The total number of OTM carcasses identified on the kill floor must reconcile with the number of carcasses found in the carcass cooler and the number of carcasses entering the cutting/deboning room or shipped from the establishment.
1.6 Cross-contamination through equipment / tools
In general, slaughtering and harvesting procedures must prevent contamination of edible meat with SRM. Meat harvested for human consumption must be hygienically removed and physically separated from the remaining parts of the cattle carcass as soon as possible during the harvest process. The risks and appropriate procedures will be site and scenario specific. Potential sources of contamination include all SRM tissues from within the head of OTM cattle killed with the aid of a penetrating stunning device, accidental cut through palatine tonsils, the spinal cord of OTM cattle exposed during carcass splitting or severing from the head, and the internal tissues of a severed distal ileum from cattle of all ages. The operator must use, except as detailed later in the following section, dedicated tools (for example knives), identified by colour-coding or another visual system, for all procedures involving the incision and direct or indirect handling of the SRM tissues.
If accidental contamination of the harvesting equipment with SRM, the site and all equipment used during the harvest process must be free of visible organic material, cleaned, and sanitized using water at 82°C, an applicable standard for sanitizing, or an approved grade chemical sanitizer.
1.7 OTM head removal
Dehorning OTM cattle, if required, should be conducted in a manner that will not open the brain cavity to prevent leakage of brain tissue. If it is not possible to determine cattle age prior to removing the head from the carcass due to plant design, the head removal process is performed by using a non-SRM dedicated knife to cut most of the muscles and connective tissues attaching the head to the carcass. This results in partial separation of the head at the junction of the occipital condyles and the first cervical vertebrae. A dedicated knife (uniquely identified e.g. colour coded) for SRM removal is used to sever the spinal cord. A non-dedicated knife is then used to complete the removal of the head. Both knives are adequately rinsed and sanitized after each animal and must not be stored in the same scabbard.
The skull including the brain, trigeminal ganglia, eyes, palatine tonsils of OTM cattle must be disposed of as SRM. The removal of the head must be achieved without contamination of the carcass or other meat products with SRM (namely spinal cord, brain) or other contaminants. The operator must take measures to prevent the contamination of edible products (head meat and tongues for example) by SRM.
As soon as the tongue and cheek meat have been harvested, the remainder of the head shall be placed without delay into a SRM leak proof container of suitable dimensions to prevent subsequent contact between the SRM head and any other meat products. Boning of the occipital area of the head including the area of the foramen magnum of OTM cattle is not permitted.
1.8 OTM hides and face plate (head hide)
Salvaged hides must be collected in a container immediately after their removal. Hides may be grossly contaminated with SRM from leakage during their removal or from contact with the floor onto which SRM may fall or leak. Preventative Control Plan (PCP) for hide removal to mitigate incidental gross contamination with SRM must be implemented that include the washing (or an equivalent procedure) of hides that become contaminated before they leave the premises. If the OTM animal is stunned by a penetrating stunning device, there is a strong likelihood that the face plate may be contaminated with neural tissue. Grossly visible brain material must be removed from the face plate by trimming, washing, scraping and/or vacuuming (as per the method outlined in the approved operator's PCP).
Refer to the tables below for disposition of face plates, namely, head hides from bovines.
|UTM||1A: UTM Animals stunned by a penetrating or non-penetrating stunning device.||Routine (non-SRM) inedible stream provided no cross-contamination with brain material or any other SRM from OTM animals takes place.|
|OTM||2A: OTM animals stunned by a non-penetrating stunning device (for example: electrical kill stunning, ritual slaughter, etc.)||Routine (non-SRM) inedible stream unless cross-contamination with brain material or any other SRM from OTM animals takes place.|
|OTM||2B: OTM animals stunned by a penetrating stunning device.||Routine (non-SRM) inedible stream provided the leakage of brain tissue from the stun hole is prevented with CFIA approved methods such as the application of edible grease, tampons or other equivalent devices, and grossly visible brain material is removed from the face plate by trimming, washing, scraping and/or vacuuming.|
1.9 Palatine tonsils
The palatine tonsils of OTM cattle are classified as SRM, head dressing procedures may result in tongues, being presented with associated tissues including lymph nodes, fatty tissues, salivary glands, and tonsils (namely palatine and lingual tonsils). These tonsils which are contained in the palatine fossa (crypts) must be treated as SRM in OTM cattle. It is important to inspect heads after tongue removal to check that the palatine tonsils remained with the head, if not further verification of the head dressing procedure is required.
1.10 Tongue and cheek meat
If cattle are OTM of age, cheek meat and tongues may be harvested as edible product providing there is no visible contamination with brain tissue, spinal cord or palatine tonsils. If a facility slaughters cattle from both age groups (UTM or OTM), it should have procedures for sanitizing between the two groups to prevent cross-contamination during head removal and processing. These procedures may include separating head lines, employing hot water sanitation between heads, processing heads while hanging on hooks rather than using tables, or other activities that will reduce the potential for cross-contamination between these two age groups.
1.11 Exhaust water from the band splitting saw
If the carcass splitting saw is equipped with an automatic rinse system, the exhaust water must be ducted away from carcasses and other edible and inedible products. The water-exhaust effluent should be adequately trapped or channeled to SRM stream.
1.12 Cleaning and sanitizing of split saw
For the carcass splitting saw the operator has the option either to use dedicated equipment or to ensure that the equipment used on an OTM cattle carcass is cleaned and sanitized before being used on a UTM cattle carcass or on carcasses and parts of carcasses of other food animal species. The level of cleaning required is equivalent to what is required when the carcass splitting saw becomes contaminated (namely, the organic material must be removed to ensure adequate sanitation).
1.13 OTM spinal cords removal
The spinal cord (excluding the cauda equina taking origin at the first sacral vertebrae - S1) in OTM cattle is considered as SRM. It must be removed in its entirety before the carcass leaves the kill floor. The carcass splitting saw should separate the vertebral column in the midline to facilitate removal of the spinal cord, which is handled as SRM accordingly in OTM cattle. The operator shall identify any incorrectly split carcasses and ensure that the spinal cord is properly removed in the evisceration area. The operator must take appropriate corrective measures to prevent the occurrence of incorrectly split carcasses.
Hand tools used for spinal cord removal should be uniquely identified (for example, colour coded knifes) and dedicated to this purpose. Specialized spinal cord removal equipment, including vacuums can be used on all age categories of cattle. However they must be sanitized as required and after each time they are used on an OTM cattle carcass before being subsequently used on UTM cattle carcasses or on carcasses of other food animal species.
Operator verification of the complete spinal cord removal is one of the most important control points. The operator must make a thorough check of every carcass side to ensure that no remnants of spinal cord are present before the carcass leaves the kill floor. When any spinal cord remnant is discovered, the carcass must be retained for immediate rework by the operator (zero tolerance policy applies).
1.14 Use of chain mesh gloves
Lifting the spinal cord out of the vertebral canal can be achieved using a knife. Other specialized tools can be used, but chain link gloves are not to be used unless covered with intact rubber/latex gloves to minimize the risk of gross cross-contamination.
1.15 Staining of the vertebral canal of OTM cattle carcasses
The operator must apply food grade blue ink to exposed surfaces of the vertebral canal of each OTM carcass side following removal of the spinal cord and before chilling. For proper identification the operator shall apply food grade blue ink to the vertebral canal and may include the vertebral body. All vertebrae including the sacrum must be stained with food grade blue ink in order to achieve a readily visible mark at the time of cutting/boning.
Application of the blue ink to the vertebrae shortly after the carcass has exited the carcass wash, must only occur when the operator has a written PCP in place that can demonstrate ongoing effective controls, including carcass identification and marking system that will ensure all OTM carcasses are properly identified and marked before entering the cooler.
1.16 Removal of the entire small intestine, or the distal ileum
The distal ileum of all cattle, regardless of their age, is designated as SRM and must be removed and disposed of as SRM. To ensure the complete removal of the distal ileum from cattle of all ages, the ileo-cecal junction and at least 200 cm of the attached and uncoiled small intestine proximal to the ileo-cecal junction is removed and disposed of as SRM. The operator can comply with this requirement by choosing one of the following options:
- Remove and dispose of all cattle's small intestines and caecum as SRM
- In facilities where a preventive control plan is developed and implemented, the operator ensures that the entire distal ileum is removed according to the following specifications:
- ensure that at least 200 cm of the distal ileum and the entire caecum are completely removed as SRM
- once the distal ileum and the entire caecum are removed, the remainder of the small intestines can be treated as non-SRM inedible cattle tissues
- the PCP must include a description of the landmarks, procedures, and equipment used to define and measure the distal ileum and the caecum to be removed. In the absence of a measuring device, an alternative piece of equipment that consistently provides the same outcome is acceptable
- In facilities under daily oversight of an inspector, the operator ensures that the ileo-cecal junction and at least 200 cm of the attached and uncoiled small intestine proximal to the ileo-cecal junction are removed. That no piece of the distal ileum is included with any edible meat product or animal food product. If the large intestine is salvaged, there must be a PCP that identifies the landmarks for the portion being salvaged.
1.17 Control of SRM floor waste
Areas where SRM is removed or handled must be regularly cleaned by plant employees assigned this function. Systems for containing gross debris and operational cleaning of these areas are important. Carcass material and debris shovelled or squeegeed from the floor in areas where SRM is removed or handled and any debris collected from the channels and drain covers/traps derived from these areas must be disposed of as SRM and deposited in dedicated SRM containers. Collection of SRM from drain covers and traps must occur on each day of SRM removal and handling.
Where there are effective controls to prevent floor from contact with SRM, floor waste and debris collected from the corresponding drain covers and traps do not need to be disposed of as SRM. An acceptable method of containing SRM in areas where SRM is removed or handled to prevent extensive floor contamination with SRM is through the implementation of strategic physical barriers such as troughs, trays, raised floor curbings or barriers of equivalent effects. The Operators should have a written program in place, to prevent the cross-contamination of floor from SRM tissues in these specific areas. When there are no effective controls to contain the floor waste generated from areas where SRM is removed or handled, carcass material and debris shoveled or scraped from the floor and debris collected from the channels and drain covers associated with these areas must be disposed of as SRM.
1.18 OTM and UTM carcasses segregation and storage
It is strongly recommended that the operator slaughters OTM animals at the end of the production day and as a definable group, this is in order to facilitate operational control and verification of SRM removal. If an operator chooses to slaughter and segregate OTM cattle using alternative methodology, a PCP should demonstrate how it achieves the same outcome however, in establishments that ship UTM and OTM cattle carcasses to another establishment for cutting/deboning, operators are required to visibly group the carcasses of OTM cattle in the cooler, track and record the number of OTM cattle carcasses pending their shipment.
1.19 Retention and rework of carcasses harbouring residual SRM
The operator must verify the complete removal of all SRM. Any carcass or part that is found to be harbouring fragments of SRM (e.g. spinal cord) must be retained by the operator for immediate rework and subsequent presentation for further examination by the operator. The operator should have a system which allows retention and rework of carcasses harbouring residual SRM to occur successfully and without gross SRM cross contamination to meat products. The operator must demonstrate control of the system at all times.
2. Processing (deboning)
2.1 OTM vertebral columns removal and disposal
Each plant that process bone-in carcasses or parts from OTM cattle will need to develop specific PCP to ensure the removal and disposal of the vertebral column and dorsal root ganglia (DRG) as SRM. The DRG are nodular expansions of nervous tissue connected to the spinal cord that are located in close proximity to the intervertebral foramen. Improper identification and staining of vertebral column from OTM cattle leads to incorrect disposal of the vertebral column and increases the risk of introduction of the DRG into the food and feed chains. This is why edible dye must be applied properly to the exposed surfaces of the vertebral canal of each OTM carcass side following removal of the spinal cord and before chilling. The vertebral column removal will most likely be done in the cutting and boning room after carcass chilling. Traditional T-bone or porterhouse steaks and bone-in rib roasts must not be produced from OTM cattle. In order to ensure complete removal of DRG, a portion of the vertebral column bone defining these cuts of meat (excluding the vertebrae of the tail, the dorsal and transverse processes of the thoracic and lumbar vertebrae and the wings of the sacrum) must be removed resulting in a semi-boneless cut of meat. In normal processing operations, two to three transverse cuts are made through the OTM vertebral column to facilitate subsequent handling of beef quarters. While there is a negligible likelihood that the saw dust resulting from this operation would contain SRM (DRG), it is highly recommended to make the transverse cuts through the body of the vertebral column avoiding the intervertebral foramen. The opportunities for these SRM to contaminate other materials including floor waste and waste water would be negligible. Therefore, there should be no need to treat as SRM the floor waste or waste water mixed with the saw dust from OTM vertebral column transverse cuts. Furthermore, since the DRG are contained within the vertebral column they do not pose any risk of cross contamination through direct exposure.
2.2 Harvesting meat around OTM vertebral column
It is the operator's responsibility to produce and handle fresh meat and meat products in a manner which ensures that such products do not contain and are not contaminated with the dorsal root ganglia (DRG) from OTM carcasses. The use of vertebral column of OTM cattle as raw material in the preparation of mechanically separated meat (MSM) or finely textured meat (FTM) is prohibited. The DRG is difficult to visually identify during processing therefore it has been determined that the best practice is to remove the meat between the ribs using a U-shaped cut rather than the traditional V-shaped cut at approximately 2.5 cm (1 inch) from the vertebral arch to ensure no DRG is inadvertently included with the edible meat. While it is not acceptable to harvest tenderloin from OTM cattle carcasses by scraping the ventral surface of the vertebral column, the number of cuts performed should be minimised to prevent accidental cross contamination with the DRG.
3. SRM collection, staining and disposal
3.1 SRM is collected in dedicated containers after removal
SRM should be separated from carcasses at the earliest opportunity during the dressing process. It must then be placed in dedicated containers without delay and regularly moved to a designated area in the inedible products section for staining. This must include all SRM separated from the carcass, SRM from the floor and all other debris collected in the SRM areas. All containers used in the handling of SRM shall be cleaned and sanitized after being emptied and prior to reuse. Dedicated inedible and SRM containers must at all times be visibly clean. If containers are being returned by a rendering company in an unclean state they shall not be used until they are cleaned and sanitized. Cleaning of SRM containers should not occur in area where potential contamination of the meat products may occur. The cleaning and sanitizing of SRM containers should be an integral part of the cleaning schedule of the premises, and verified before each day of operation. Basic principles of hygiene must be observed at all times for dedicated inedible containers and equipment, such as chutes, augers etc., they must be cleaned and sanitized using effective non-food chemical following accidental contamination with SRM and prior to reuse. The operator must ensure that appropriate systematic measures are taken during the handling and storage of SRM to discourage access by birds, rodents, insects, and other vermin. Contaminants, such as hydraulic fluids, heavy metals and other chemicals, must not be discarded into SRM containers since tallow extracted from rendered SRM is used in animal feeds, cosmetics, soap, etc. The inclusion of such contaminants may pose animal and public health risks.
3.2 All inedible mixed with SRM are treated as SRM
If the operator chooses not to segregate SRM from other inedible tissues, all inedible material mixed with the SRM will be considered SRM, handled and disposed of as such. The operator and all staff directly involved should have demonstrable knowledge of the establishment's SRM controls and related PCP with emphasis on the handling of SRM cross contamination events including the treatment of inedible mixed with SRM.
3.3 The dedicated SRM containers are marked on the outside with the words "Specified Risk Material / Matériel à risque spécifié" or "SRM/ MRS"
It is important that all SRM and debris are contained within dedicated leak proof containers clearly and indelibly marked on the outside with the words "Specified Risk Material / Matériel à risque spécifié" or "SRM / MRS" in both official languages.
3.4 Stained SRM is stored in an inedible area designated for SRM
The operator is responsible for the segregation and staining of SRM after its removal during slaughter or cutting/ deboning. All SRM must be transferred to a dedicated leak proof container/ trailer in a designated area in the inedible products section for staining. The operator must convey immediately and directly the dead stock to a designated area in the inedible product section for staining and disposal.
3.5 Any animal material and solid particles recovered from wastewater are disposed of as SRM
Waste fluid and water generated in parts of the abattoir where the SRM is removed, must pass freely through a four (4) mm screen or equivalent. Screened organic debris that is greater than four (4) mm in size must be considered SRM. This requirement may not apply if:
- all effluents are collected in a septic tank and output is kept out of the feed manufacturing system
- all effluents are disposed of directly into the municipal sewer system according to the federal/provincial/municipal regulations
- all effluents are treated at a SRM rendering plant
- the removed SRM is contained within an intact anatomical structure such as distal ileum and OTM vertebral columns
Washing of the SRM designated area must be performed in such a way that it does not pose a risk of SRM contaminating non-SRM tissues. Where there are effective controls to prevent floor from contact with SRM, floor waste and debris collected from the corresponding drain covers and traps do not need to be disposed of as SRM.
3.6 Floor waste in all SRM designated areas is considered as SRM
When there are no effective controls to contain the floor waste generated from areas where SRM is removed or handled the floor waste from these areas will be considered SRM. Carcass material and debris shovelled or scraped from the floor and debris collected from the channels and drain covers associated with these areas must be disposed of as SRM.
An acceptable method of containing SRM in areas where SRM is removed or handled to prevent extensive floor contamination with SRM is through the implementation of strategic physical barriers such as troughs, trays, raised floor curbings or barriers of equivalent effects. The operators should have a PCP in place to prevent the cross-contamination of floor from SRM tissues in these specific areas.
The floor waste generated in other areas, without any contact with SRM tissues, will not be considered SRM. This is also applicable in areas where the distal ileum and the OTM vertebral columns are removed because the SRM is effectively contained within these tissues. However, the operators should have a PCP in place to prevent tracking of SRM tissues to these specific areas.
3.7 SRM designated areas of the kill floor are cleaned before slaughtering animals other than OTM cattle
Abattoir's operators slaughtering OTM cattle must clean and sanitize all non-dedicated equipment and surfaces in the SRM designated areas of the kill floor before slaughtering animals other than OTM cattle. Non-dedicated equipment and surfaces that comes in contact with SRMs from OTM cattle must be cleaned (i.e., washed to remove visible contamination) and then sanitized (i.e., 82°C water) before they can be used on carcasses or parts of carcasses from other than OTM cattle animals. Cleaning means the removal of organic debris that is adhering to the equipment and surfaces prior to sanitization. As a result, edible or inedible material if they have been accidentally dropped onto the floor would not be required to be treated as SRM in those areas.
3.8 SRM is stained in dedicated leak-proof containers using a dye that is conspicuous, indelible and safe for consumption by animals
The operator is responsible for the segregation and staining of SRM after its removal during slaughter or cutting/ deboning. All SRM must be transferred to a dedicated leak proof container/ trailer in a designated area in the inedible products section for staining. It must be conspicuously stained with an indelible marking dye (for example denaturing agent). Carcasses unfit for human consumption, containing SRM, must also be conspicuously stained with an indelible marking dye approved by the CFIA.
The stain should be applied so that it is visible on all surfaces i.e. every time the SRM is transferred to a common SRM staining container or trailer, it has to be stained by spraying. A complete list of approved denaturing agents and dyes can be obtained from the CFIA Web site (namely Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products).
The operator must implement and maintain control measures that include segregating and staining of SRM in dedicated SRM containers following its removal from cattle carcasses.
- If the operator chooses not to segregate SRM from other inedible tissues, all inedible material mixed with the SRM will be considered to be SRM and will have to be stained.
- Staining requirements would not apply if all the inedible material whether mixed or not with SRM does not leave the premises (on-site disposal).
3.9 Cattle dead stock and condemnations containing SRM are moved to an inedible area designated for SRM
The operator is required to move to an inedible area designated for SRM cattle that are found dead on arrival or condemned at ante mortem or die of the causes other than the slaughter in the establishment.
An unborn fetus/calf recovered from the uterus of a cow slaughtered in a permanently inspected abattoir is non-SRM. Any term-fetus with body hair or newborn calf that is found on the ground inside the establishment is SRM, unless the distal ileum has been removed from such animals.
3.10 Cattle dead stock containing SRM are stained using a dye that is conspicuous, indelible and safe for consumption by animals
Carcasses of condemned or dead animals from which the SRM has not been removed must be stained with a wide stripe down the back of the head and length of the spine using a dye (contrasting with the animal's coat colour) that is conspicuous, indelible and safe for consumption by animals before shipping to another location under CFIA permit. Cattle deadstock being collected by companies authorised to salvage hides for leather production may stain just the head. This requirement would not apply if all of the abattoir waste does not leave the premises (on-site disposal).
Deadstock collected by companies that are solely dedicated to SRM (namely all trucks, all equipment, entire premises) may be marked to a lesser degree. For example, if the hide is being salvaged for leather production, and the available markers cannot be removed during the tanning process, then marking of just the head is acceptable.
3.11 All SRM waste disposed on site is stained
Abattoirs are allowed to dispose of SRM on the premises where the animals are slaughtered or found dead without the need for staining however in this case all inedible materials from all species, including SRM, carcasses considered SRM and composted SRM, must permanently remain on the establishment's premises.
Staining of all SRM is mandatory if non-SRM inedible material is segregated for offsite treatment, use or disposal. Containment options, such as burial, must comply with provincial/territorial and municipal standards and requirements. Where allowed by provincial/territorial and municipal requirements, inedible materials (SRM and non-SRM) may be composted to reduce waste volume. However, while no composted material may leave the premises without a CFIA permit to transport SRM, the SRM compost must be stained and remain identifiable until it is spread on a contiguous land.
3.12 SRM is transported (for example: rendering, salvaging sites, landfill, etc.) off site
SRM, including carcasses containing SRM, being moved offsite for any reason may only be sent to a person or company possessing the required CFIA permit and may only be transported by a person or company possessing the required CFIA permit.
The abattoir operator may obtain an annual CFIA permit to transport limited quantity of SRM to a non-contiguous piece of land owned by the operator. This permit would allow the CFIA to track the records of the weights and final disposal site information of the SRM. In addition, the receiving site would require an annual permit to receive the SRM and would be required to meet defined minimal requirements as outlined on the permit. The CFIA will evaluate permit applications for non-contiguous sites on a case-by-case basis.
3.13 Segregation of SRM and Non-SRM abattoir waste is maintained
Operators must comply with the following requirements if SRM or carcasses considered SRM and all inedible material from all animal species are not disposed of on the premises.
All SRM must be kept effectively segregated all the time until their final use, shipping and disposal (whether onsite or offsite) that include:
- raw SRM in the inedible area must be stained with a dye that is conspicuous, indelible and safe for consumption by animals
- condemned cattle and cattle deadstock must be visibly stained along their spines
- SRM in the inedible area must be kept in a dedicated container that is clearly marked on the outside with the words "Specified Risk Material / Matériel à risque spécifié" or "SRM/ MRS"
- PCP indicating that all inedible materials cross contaminated must be treated as SRM namely dyed and collected in a dedicated container that is clearly marked as SRM/ MRS"
4. Record keeping
The operator is required to maintain records as follow:
4.1 SRM records are maintained for each day of operation
Operators are required to maintain daily records sufficient to document the implementation and monitoring of the SRM removal and staining. It may take over two days to bone all of the slaughtered OTM cattle, the operator in this case may be able to subdivide lots and produce a record for a partial lot provided the operator can ultimately account for all cattle slaughtered on a single day.
4.2 Name of the operator is recorded
The name of the person responsible for the verification of the complete removal and staining of SRM must be recorded.
4.3 The date of SRM removal from the carcass is recorded
The date or shift when SRMs are removed and stained must be recorded.
4.4 The date SRM is transported off site is recorded
In certain circumstances, a partial or whole cattle carcass intended for human consumption may be moved to a separate location for further processing (harvest). During this process, some SRM may remain in the carcass until processing is completed. Records must indicate the date on which such carcasses are moved offsite. Furthermore, the operator must record the date in a separate document if the partial or whole cattle carcass containing SRM are not intended for human consumption and are moved offsite for further processing (for example salvage, compost, rendering) or disposal (confinement or destruction).
4.5 The combined weight of SRM and intact carcasses (deadstock, condemned) that are transported is recorded
When SRM is treated, confined, or destroyed offsite, the operator must keep records of the combined weight of SRM and carcasses or parts of carcasses containing SRM. In plants where scales are not installed, operators must develop acceptable methods of estimating the weight and ensure recording of any conversion method used in the calculation. The calculation method must be corrected if the operator finds more than 3% variability between the weight estimated and the weight recorded by a scale at the destination.
4.6 The number of intact cattle carcasses (deadstock, condemned) that are transported is recorded
When SRM is treated, confined, or destroyed offsite, the operator must keep records of the number of cattle carcasses that died or were condemned before they otherwise would have been slaughtered for human consumption as food.
4.7 The total number of deadstock and cattle condemned at ante-mortem is recorded
When SRM is disposed onsite (for example composted or confined), the operator must keep records of the number of cattle carcasses that died or were condemned before they otherwise would have been slaughtered for human consumption as food.
4.8 The name of the marking agent used to identify SRM is recorded
The name of the dye used to stain partial or whole OTM cattle carcass intended for human consumption must be recorded and confirmed as an edible meat marking dye, conspicuous and indelible. The name of the dye used to stain SRM in the inedible area must also be recorded and confirmed to be safe for consumption by animals, conspicuous and indelible.
4.9 The approved ID tag numbers or other approved ID information of all deadstock and condemnations containing SRM is recorded
Operators of abattoirs must record approved ID tag numbers of all dead cattle whether disposed of onsite or transported from an abattoir to another site (for example for off-site disposal, post-mortem examination). In the event the dead cattle does not bear an approved tag, the operator of the abattoir must apply a species-specific approved tag to the dead animal before it is loaded into the conveyance and record it.
4.10 The name and address of the person or the company that transports SRM and carcasses containing SRM from the establishment is recorded
When SRM is treated, used, confined, or destroyed offsite, the operator must record the name and address of the person or company responsible for the transportation and indicate whether the transportation concerns:
- partial or whole carcasses intended for human consumption or
- partial or whole carcasses not intended for human consumption as well as any abattoir waste considered as SRM
4.11 The name and address of the person or company that received or will receive the SRM is recorded
When SRM is treated, used, confined, or destroyed offsite, the operator must record the name and address of the person or company receiving SRM and indicate whether it is to:
- treat partial or whole carcasses intended for human consumption (cut and wrap facility, butcher shop, etc.) or,
- treat partial or whole carcasses not intended for human consumption as well as any abattoir waste (salvaging, rendering, composting etc.) or,
- use SRM (land application of SRM compost) or,
- dispose of SRM by confinement or destruction.
4.12 The SRM records are maintained for a minimum of 10 years
The operator is required to retain the above described records in a readable and accessible format for a minimum of 10 years. The records have to be produced for inspection, no matter where they are stored. The operator remains responsible if third party changes occur that affect records. Such changes might include take-overs, transfers and property sell to other third parties.
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