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Microbial controls for meat products and food animals

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As part of the requirement to prevent, eliminate or reduce to acceptable level the microbial biological hazards that they identified in their Preventive Control Plan (PCP) (SFCR 47), operators are expected to manufacture meat products that do not pose a health risk due to the presence of microbial pathogens.

To achieve this goal certain monitoring programs can help demonstrate that dressing procedures are meeting hygienic standards.

As well, microbial control interventions, whether a chemical application or other (for example, steam or hot water vacuum, use of bacterial phages), can be integrated into a licence holders preventive control plan to manage microbial risks, however these controls must be validated and they must also, if applicable, comply with section 4 of the Food and Drugs Act. The following provides best practices to meet these outcomes, and should also be used as reference material when employing any food additive/processing aid within a slaughter process (for example anti-coagulants for the processing of blood).

Examples of microbial monitoring programs

  • Testing for generic E. coli

    Generic E. coli testing required by USA, as described in the export library, is a recommended method in demonstrating hygienic standards during dressing.

  • Testing for Salmonella

    Salmonella testing required by USA, as described in the export library, is a recommended method in demonstrating food safety standards during dressing.

  • Poultry pathogen reduction program

  • Policy on E. coli O157:H7

    Licence holders are required to identify E. coli O157:H7 as a hazard in their PCP if they handle raw beef products. This guidance does not address any microbial controls related to this specific hazard as specific guidance on this subject is available in Preventive controls for E. coli O157/NM in raw beef products.

General principles for the use of acceptable microbial control interventions

The following general principles for the use of microbial control interventions should be respected:

  • Operators must demonstrate that a microbial control intervention is necessary and that it is effective at achieving a defined outcome. Operators should also describe in their PCP that the actual operating conditions (including the critical operational parameters pertaining to the intervention within their specific establishment) are consistently met in order to achieve the desired food safety outcome in the establishment. The information presented in Evidence showing a control measure is effective should be used as guidance material to develop your PCP. Poultry establishments may also consult Protocol for piloting new technology and procedures for poultry slaughter.
  • Chemical components used as food processing aids or food additives entering into contact with meat products must be of food grade quality and meet their respective specifications set out in the most recent edition of the Food Chemicals Codex or their most recent specifications prepared by the Joint FAO/WHO Expert Committee on Food Additives (JECFA) available at Combined Compendium of Food Additive Specifications, where such specifications exist. In the case of food additives, the conditions of use set out in the Lists of Permitted Food Additives must be respected. In the case of processing aids, the operator must demonstrate that use of the chemicals result in no or negligible residues in or on the finished meat products, including residues of reaction products that may occur as a result of interaction between the food processing aid and the meat product. These aspects are normally considered during an evaluation by Health Canada, thus those products used as per a Letter of No Objection (LONO) or an Interim Letter of No Objection (iLONO) do not require any further validation.
  • Microbial control interventions should not affect the organoleptic characteristics of meat products offered for sale to consumers.
  • Meat products to which a food additive has been added must be appropriately labelled as per the Food and Drug Regulations. On the other hand, antimicrobial food processing aids are not required to be declared in the ingredient list of the meat product (food processing aids by definition are not present in the treated food and are therefore not required to be declared). For more information on labelling please consult the labelling page, and more specifically the food additive page.
  • The use of a microbial control intervention should not create a health and safety risk to any person entering the establishment.
  • Hazards associated with the use of a microbial control intervention must be controlled by the establishment's Preventive control plan.
  • The operator must develop, implement and maintain a control program for the validated microbial control intervention that describes, as applicable, the:
    • equipment used and methods to assure the intervention does not create any health and safety hazard
    • type, dosage, and concentration of the product used
    • formula for preparing solutions
    • operating parameters required to achieve performance, for example:
      • the process step where the microbial control intervention is applied (for example pre-evisceration, post-evisceration before chilling, blood de-fibrination)
      • the rate of application of the solution including flow rate and pressure
      • the temperature of the solution
      • the length of time meat products are directly exposed to the solution
      • the meat products dripping time after exposure to the solution
      • rinsing with potable water, as determined applicable
    • actions to be taken if the system is found to be operating out of compliance
    • training provided to plant employees
    • cleaning procedures, validated by bacteriological tests, for cleaning all pipes, tanks, pumps, etc. where microbial control solutions (for example chemicals, hot water) are recirculated
    • testing of solutions as delivered (to a minimum of every 4 hours) to verify compliance with established limits (for example contact time, temperature, nozzle pressure, minimum concentration to ensure efficacy, and maximum accepted concentration to avoid potential chemical hazards, as applicable)
    • actions to be taken in the event of a line stoppage (for example removal of carcasses and products from tanks, spraying cabinets; potable water rinses; other remedial treatment required, for example: segregation and, as applicable, the disposal of affected carcasses or parts subjected to excess application, or storage of the affected product pending submission of all information requested by the CFIA and/or Health Canada (HC) including test results (conducted at the operator's expense), as required for a health risk assessment); and
    • monitoring of the process with respect, but not limited, to:
      • frequency of monitoring
      • records to be maintained (for example the method of application of the microbial control product, namely concentration limits; temperature limits; immersion/spray/exposure time; flow rate and pressure; rinsing procedures); and
      • corrective action procedures when the intervention is found out of compliance
  • Operators should consider that a microbial control intervention application may also need to be included, and validated, in other control programs, such as water retention control program and chilling control program. For example, when an antimicrobial is used in a water chiller for poultry carcasses, the process will need to be validated for chilling, water retention and pathogen reduction to ensure that the resulting final product will meet the respective standards.

Chemical microbial interventions: food processing aids and preservative food additives

All substances used in food manufacture must not result in a violation of section 4 of the Food and Drugs Act. Section 4 states, in part, that no person shall sell an article of food that has in or on it any poisonous or harmful substance or is adulterated. It is the responsibility of the licence holder to ensure that the use of a particular chemical substance will not result in a violation of section 4 of the Act.

Different chemical substances or mixtures may be used as a microbial control intervention and will fall either under the definition of food additive or food processing aid.

  • Food additives are regulated in Canada under various regulations issued under the authority of the Food and Drugs Act. A food additive is any substance, the use of which results – or may reasonably be expected to result – in it or its by-products becoming a part of or affecting the characteristics of a food. Exemptions to this definition are listed in Section B.01.001, Part B of the Food and Drug Regulations. Only those substances on Health Canada's List of Permitted Preservatives may be used as food additives, and the stated conditions of use must be respected.
  • A food processing aid is a substance that is used for a technical effect in food processing or manufacture, the use of which does not affect the intrinsic characteristics of the food and results in no or negligible residues of the substance or its by-products in or on the food (for example, organic acids used for carcass washes such as lactic acid). While the Food and Drug Regulations may not necessarily require premarket review of food processing aids, a licence holder will need to demonstrate the safety of any processing aid used and that the substance consistently leaves no or negligible residues (in other words not a food additive). For recommended options to demonstrate the safe use of processing aids, licence holders should refer to the Guidance for food establishments concerning construction materials and packaging materials and non-food chemicals.

Health Canada's Policy for Differentiating Food Additives and Processing Aids provides more information on the distinction between the use of a substance as a food additive and the use of a substance as a food processing aid.

In the case of an unapproved food additive, the manufacturer of the food additive must obtain legal approval for its use before it can be used in or on food sold in Canada. The request is made in the form of a food additive submission containing relevant scientific data which must be fully assessed by Health Canada. If a food additive submission is assessed favourably for safety and efficacy, a modification to the appropriate Lists of Permitted Food Additives and if necessary, an amendment to the relevant Marketing Authorization, is made at which point, the food additive may be legally used in foods sold in Canada provided all conditions of use are met.

Petitioners may refer to the following resources available on Health Canada's website:

Manufacturers should be advised that Health Canada has no set timelines for the issuance of a LONO and that, as per their policy for issuing an iLONO for a food processing aid, Health Canada has 60 days from the day they have received all the necessary information to issue an iLONO. In the case of food additive submissions, the general timeline to complete their safety review is 410 calendar days. However, an additional few months after review completion is generally needed to legally enable the use of the food additive. Regardless of the process, the outcome and its timing will, in part, depend on the quality and completeness of the data originally submitted to Health Canada.

Non chemical microbial control interventions

Operators can consider microbial control intervention approaches that do not rely on chemical substances (for example hot water or steam vacuuming, etc.). Normally, these technologies using water will only use potable water for microbial control purposes. If the operator wishes to re-cycle/re-circulate hot water within a contained system (such as a hot water washing cabinet), the operator must be able to demonstrate that parameters such as heating regime, filtration as well as the addition of potable water to the system, ensure control over potential risks.

Steam or hot water vacuuming for red meat carcasses

Fecal, ingesta and other extraneous (such as hair and wool) contamination may be removed using knife trimming and/or vacuuming with hot water or steam. The proper use of hot water or steam vacuuming can reduce bacterial load; however, in order to reduce the spreading of bacterial contamination to adjacent areas, this type of intervention will only be used before a full carcass decontamination intervention such as a post-evisceration carcass wash with a microbial reduction solution (for example lactic acid spray) or a steam or hot water carcass intervention. The operator will develop and incorporate control procedures for monitoring, deviation and verification purposes into their PCP.

Vacuuming with hot water or steam is limited to removing visible fecal and ingesta contaminations with greatest dimension of 2.5 cm or less. Fecal and ingesta contamination exceeding 2.5 cm should be removed by knife trimming before a decontamination intervention is performed by vacuuming with hot water or steam. The removal of open abscesses, septic bruises, parasites and parasitic lesions, and lactating udders should be done only by knife trimming.

The minimum standards for equipment used as a hot water or steam vacuum system are as follows:

  • The system will provide accurate temperature and vacuum readings. Once the temperature and vacuum parameters are set at the beginning of operation, controls will be in place to ensure and demonstrate that the system continues to function properly and without significant fluctuation throughout the day.
  • The system will be capable of delivering and maintaining water or steam temperature at a minimum of 82°C at the carcass surface. The temperature recording device should measure the hot water or steam temperature as close to the carcass surface as possible.
  • The vacuuming pressure will be set in such a manner that it can sufficiently remove any steam and water from the surface of the vacuum area to prevent dripping.

To ensure that the vacuum head is sanitized between each use, the vacuum head will be subjected continuously to a minimum of 82°C during its use. Alternatively, the vacuum head can be sanitized in 82°C water between carcasses. Alternate procedures should be shared with the veterinarian with supervisory authority prior to implementation.