Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements are being phased in over the following 12 to 30 months. For more information, refer to the SFCR timelines. Note that this policy is currently being piloted in the Canadian red meat industry.
On this page
- Application
- Purpose
- Interpretation
- System inspection
- Verification procedures
- Unscheduled verification inspection
- Implementation correlation
- Appendix 1
Application
It supports the Post mortem Defect Management Program under the Safe Food for Canadian Regulations (SFCR). This policy has been designed to align with elements set out in the document Fundamentals of the Post Mortem Defect Management Program, incorporated by reference in the SFCR.
Purpose
The MSIP system focuses inspection efforts on ensuring the operator meets edible standards. Under traditional inspection methods, CFIA slaughter inspectors are tasked with the detection and identification of defects before the operator has the opportunity to ensure the product meets edible standards. The MSIP system places the onus on defect detection and identification onto the operator. Operators are encouraged to train slaughter employees to identify defects as they occur instead of relying solely on downstream defect detection. Operators under the MSIP system provide product for inspection that has been screened by the operator with defects identified or removed. Therefore CFIA inspectors conduct carcass-by-carcass inspection focussing on food safety concerns instead of assuming a routine defect detection role in the actual slaughter process. Focussing CFIA inspection on pre-screened product enhances CFIA's ability to oversee the production of safe meat products. The MSIP system fully aligns with HACCP principles by allowing the operator to identify and control defects. There are no line speed conditions within the MSIP system.
Interpretation
The following definitions apply in this policy:
Roles and responsibilities
- Industry
The operator is responsible for performing the ante-mortem examination, presenting all food animals for ante-mortem inspection, identifying defects during the slaughter process, performing an initial post-mortem screening, presenting screened products for post-mortem inspection and removing defects. - CFIA
Performs ante-mortem inspection, provides slaughter system oversight, and inspects head, viscera and the carcass of food animals.
Inspection points
CFIA inspection activities within the MSIP system include up to 3 online CFIA inspection points, the disposition rail, as well as system inspection, verification inspection and ante-mortem inspection.
Facilities required at each on line inspection point include:
- The conveyor and/or rail shall be level for the entire length of the inspection stand
- Floor space shall be adequate along the conveyor and rail
- Conveyor and rail stop/start switches shall be readily accessible
- Facilities provided by the operator shall be adequate to support inspection
- A minimum of 1000 lux of shadow-free lighting shall exist at each inspection and verification point
A rail out loop/tray system is recommended at each inspection point. The identification of food safety conditions as a result of inspection will require the carcass and parts to be held necessitating the stoppage of the main rail if a rail out/tray option does not exist.
CFIA head inspection
The head inspection point is located after the operator mandibular lymph node and head examination step. The inspector visually inspects operator screened incised mandibular lymph nodes and heads for non-identified defects.
CFIA viscera inspection
The viscera inspection point is located after the operator viscera examination step and before the viscera harvesting step. The inspector visually inspects operator's screened viscera for non-identified defects.
Note: The inspector also inspects operator's screened carcasses for systemic and generalized conditions for rail out to the disposition rail at the head and/or the viscera inspection point.
CFIA final carcass inspection
The inspector visually inspects operator's screened carcasses at a location after the final trim and sorting step and before the carcass wash step.
CFIA disposition rail
The function of the disposition rail is to provide CFIA veterinary staff the ability to inspect railed out carcasses and subsequently either pass carcasses after the removal of identified pathology or condemn carcasses with generalized and systemic conditions as well as condemn other carcasses meeting condemnation criteria but not previously rejected by the operator.
System inspection
The System Inspector (SI) functions may be conducted by a CFIA inspector or the Veterinarian in Charge (VIC), or the Veterinary designate (VD) or the Verification Inspector (VI). The SI has overall responsibility to assure that the plant and inspection personnel effectively conduct the required activities under MSIP, as designed.
Specifically, the SI:
- determines (or assigns to the verification inspector) the daily random sampling schedule and provides the schedule to the VI
- monitors and determines the effectiveness of ante-mortem inspection (Veterinary function only)
- monitors and determines the effectiveness of the operator's ante-mortem screening.
- determines final disposition of animals designated by the operator and/or VI as "suspects" at ante-mortem (veterinary function only)
- monitors and determines the effectiveness of the operator's post-mortem screening and disposition
- determines final disposition on carcasses retained by an online inspector or VI on post-mortem (veterinary function only)
- records non-conformance findings on the appropriate form
- determines if the operator is meeting relevant performance standards
- assesses the overall design and execution of the operator's HACCP System, process control and defect detection control program
- assures that all adulterated products are condemned in accordance with applicable regulations
- determines when unscheduled verification sampling is warranted
- maintains communication with the VIC, VD, VI and online inspectors to facilitate coordination of all ante-mortem and post-mortem findings
Verification inspection
The Verification Inspector (VI) does not have a fixed position on the line, and can move freely. Specifically, the VI:
- observes and evaluates the effectiveness of the operator's HACCP system, process controls and defect detection control programs, including the examination of records, to determine whether the operator is in compliance with applicable regulatory requirements
- conducts ante-mortem inspection of all animals at rest and 5-10 percent of animals in motion
- retains animals for further disposition by the VIC/VD, if the animal is suspected of having a condition that could result in condemnation
- documents ante-mortem findings on MSIP Hog Form 9
- takes verification samples to determine if establishment is complying with relevant performance standards, including scheduled and unscheduled sampling
- records all findings of noncompliance with applicable performance standards
- notifies the online inspector when verification samples are required and records the findings in each sample set during post-mortem
- evaluates the noncompliance findings and records in the appropriate category MSIP Hog Form 7
- investigates potential process control and defect detection control program problems
- notifies SI if the process control or defect detection control program is not being met or if performance standards have been exceeded
- retains carcasses and parts for further disposition by the VIC/VD if food safety and other conditions are identified that could result in condemnation
- maintains communication with the online inspectors and the VIC/VD
- in addition, the VI or SI will review operator's post-mortem records for FS-1. The SI and/or VI will review other operator's post-mortem records.
Verification procedures
CFIA conducts verification inspection to assure that plants are meeting the performance standards. Verification inspection occurs in ante-mortem and post-mortem.
Ante-mortem
- Establishment ante-mortem records for the FS-3 category are to be reviewed by the VI or SI
- The VI or the SI, or the VIC, or the VD will inspect 100% of live animals at rest that are presented by the establishment for slaughter
- The VIC, or VD, or SI, or VI randomly selects ante-mortem sampling times throughout the shift. Ante-mortem sampling times can be scheduled if the entire kill is available prior to start of shift. Usually live animals continue to be shipped to the establishment throughout the day and it is not possible to schedule the times for random sampling. Therefore, it is left to the discretion of the SI to determine randomness of sampling throughout the shift when live animals are available
- The VIC, or VD, or SI, or VI will inspect 5 to 10% of the live animals in motion randomly throughout the shift after operator screening for slaughter
- The VIC, or VD, or SI, or VI will assess screening activities and humane handling practices
- The VIC/VD will assess plant activities at the suspect pen
- The SI or VI will retain as suspect for veterinary disposition any animal that could result in condemnation
- MSIP Hog Form 9 is used to document ante-mortem procedures
- FS-3 deficiency suspected by the SI or VI and confirmed by the VIC or VD will be documented by the CFIA on MSIP Hog Form 9
- In the event of FS-3 failure , the CFIA is to verify that the operator implements and documents corrective action to:
- identify and eliminate the cause of the deviation;
- ensure that the hazard is under control after the action is taken;
- establish measures to prevent recurrence; and
- ensure that no product that is injurious to health enters commerce.
Post-mortem
The verification sampling procedures for both food safety and other consumer protection performance standards will be conducted on 24 samples for each shift based on randomly selected sampling time periods. This procedure is conducted online. The SI/VI will identify the samples and may conduct the sampling themselves or have the online inspectors examine each part and carcass. Operator screened heads, viscera and carcasses will be evaluated during randomly selected sampling times. The SI/VI will record a maximum of 1 defect in each performance standard category per sample unit (a sample having bile and a bruise on the carcass would be identified as 1 Other Consumer Protection OCP-3 defect. A sample having arthritis and fecal contamination of the viscera would be identified as 1 OCP-1 and 1 OCP-2).
1. General requirements for defect control
- A sample consists of a pre-determined number of carcasses, heads, and viscera verified based on a randomly selected time period or an unscheduled time period
- The SI or the VI will notify the online inspector when to inspect verification samples during the shift
- The online inspector, when notified by the SI/VI, will inspect the verification samples and verbally inform the SI/VI of their findings during sampling
- The 24 unit samples per shift must be taken in subsets. Sample subsets are randomly taken in 1 of the following manner:
- 3 samples 8 times per shift
- 4 samples 6 times per shift
- 6 samples 4 times per shift
- 8 samples 3 times per shift
- Any OCP defects, which are identified at the post-mortem inspection points, should be identified to the operator but not scored toward plant performance unless it is part of a scheduled or unscheduled sample subset
- Sample times and sample subsets are to be selected randomly prior to the start of the shift
- The VI or SI will record FS-1, FS-2 and OCP findings on MSIP Hog Form 7. It is not necessary to record a specific condition within a performance standard category (for example, localized lung or heart conditions would be recorded as a noncompliance of the OCP-1 performance standard category)
- If the operator is engaged in product/process action at the time the random sample is to be taken, the SI will suspend random sampling until the operator has completed its actions
- In the event of unanticipated circumstances, such as breakdown, where 24 samples cannot be completed during a daily work shift, the SI/VI will note this on Form 7 and all Form 8s. The uncompleted daily totals will not be utilized in the 25 day window assessment unless the daily total in any of the categories has already failed. In this event, the failed OCP category will be recorded as a daily failure and contribute to the 25 day window, but the other OCP passed categories will not be considered for the 25 day window
Under MSIP, inspection personnel continue to perform carcass by carcass inspection in addition to MSIP verification. The operator's employees are expected to identify FS conditions (as well as non-food safety defects) as early in the slaughter process as possible. At the final online carcass inspection point, the online inspector takes action on any FS defect the establishment fails to identify for removal. If the operator repeatedly presents non-identified defects to any online inspector, the SI may order additional verification inspections. In addition, depending on the nature, degree, and extent of the loss of defect control, the SI can require additional CVS tasks to be conducted as well as a line speed reduction. The appropriate off-line (SI or VI) inspector will document noncompliance including any occurrence of FS-1 or FS-2 defects at final carcass inspection in MSIP Hog Form 10.
All carcasses identified for trimming at the final online carcass inspection point shall be re-presented for inspection after trimming has been conducted by the operator.
2. FS-1 and FS-2
FS-1
During and outside of verifications at all post-mortem inspection points; for FS-1 defects that the establishment fails to identify; the online inspector retains the carcass for veterinary disposition. The veterinarian makes the final determination whether the observed condition is or is not an FS-1 condition. The SI/VI will document in MSIP Hog Form 10 anytime an online inspector detects a confirmed operator non-identified FS-1 defect and:
- the CFIA will verify that the establishment implements corrective actions that meet HACCP requirements. The CFIA is to verify that the operator implements and documents corrective action to:
- identify and eliminate the cause of the deviation;
- ensure that the hazard is under control after the action is taken;
- establish measures to prevent recurrence; and
- ensure that no product that is injurious to health enters commerce.
FS-2
At the head and viscera online inspection point/s, the inspector stops the line and requires corrective actions anytime contamination is found that may create insanitary conditions; such that they can contaminate adjacent carcasses or edible product contact surfaces; has been missed by the operator. The online inspector informs the SI/VI who documents the finding on MSIP Hog form 10.
No carcasses are allowed to exhibit FS-2 defects at the final online carcass inspection point. Outside of or during verification, when an inspector detects FS-2 defects at the final carcass location, defects shall be removed by the operator either by railing the carcass out or having it trimmed online. Outside of MSIP verifications, when an online inspector finds an FS-2 defect at the final online carcass inspection point, the online inspector stops the line, identifies the FS-2 defect to the operator and reports the finding to the SI who will document the finding on MSIP Hog Form 10.
During verifications, when the CFIA finds an FS-2 condition at the final carcass rail point "zero tolerance" noncompliance is documented by the SI/VI on MSIP Hog Form 10 and:
- The CFIA will verify that the establishment implements corrective actions that meet HACCP requirements. The CFIA is to verify that the operator implements and documents corrective action to:
- identify and eliminate the cause of the deviation;
- ensure that the hazard is under control after the action is taken;
- establish measures to prevent recurrence; and
- ensure that no product that is injurious to health enters commerce.
Note: for operators that locate FS-1 and FS-2 final control points in their HACCP system before the online inspector; the finding of a non-identified FS-1 or 2 indicates a HACCP system noncompliance. In these cases, in addition to verifying that the operator implements and documents corrective actions as above, the applicable CVS task shall be conducted to capture the noncompliance. The reason: the FS-1 and 2 critical limit is 0 and any FS-1 and 2 conditions found after the final HACCP system control point indicate the critical limit has been exceeded.
3. OCP
- The online inspector or VI will hold a carcass for final disposition by the VIC/VD when OCP defects are found that could result in condemnation
- If the VI or SI determines that defects in an OCP category exceed the performance standard as stated in Table 1, the VI or SI will check the operator's defect detection control program records for the same time frame. If the operator results show a potential or actual loss of control as defined in the defect detection control program, the VI or SI will check the operator's records to determine whether corrective actions described in the operator's defect detection control program were taken
| Maximum allowed per shift | ||||
|---|---|---|---|---|
| 24 Samples (head, viscera, carcass) | 27 Samples unscheduled | 30 Samples unscheduled | 33 Samples unscheduled | |
| OCP-1 | 2 | 2 | 2 | 2 |
| OCP-2 | 3 | 3 | 3 | 3 |
| OCP-3 | 7 | 7 | 8 | 9 |
If the operator failed to take proper corrective action according to their control program, the operator shall detail what new corrective and preventive action will be implemented to prevent recurrence. Any samples that exhibit defects in any of the OCP performance standard categories should be pointed out to operator personnel.
Unscheduled verification inspection
When the SI determines that an unscheduled inspection should occur, the SI will notify the VI to conduct the inspection. Each unscheduled verification inspection will be 3 carcass, viscera and head samples.
- Unscheduled verification sampling done at the direction of the SI will also be recorded on MSIP Hog Form 7
- Unscheduled verification sampling will count toward the operator's performance evaluation (see Table 1)
- The SI may call for unscheduled verification inspection because an online inspector has identified a potential problem
- The SI may call for unscheduled verification inspection after the operator has had sufficient opportunity to correct an operator or inspector identified problem. This would confirm that the problem has been corrected
- The SI and/or VI will notify the operator of the results of unscheduled verification sampling and operator record examinations
Examination of operator sampling records for OCP's
- In addition to the 24 OCP samples, VI will review, once per shift, establishment's records for OCP sampling results, for example, HIP presentation, evisceration and FPS results or the operator's validated alternative
- Examples of operator records evaluation may also include observations of the operator selecting samples and data recording procedures
- The VI or SI should record their review of the establishment's OCP sampling, including any findings, on the MSIP Hog Form 10
- The VI will notify the SI of any discrepancies in the record examination
SI evaluation of OCP defect categories 1 through 3 for 25 day performance
- To evaluate whether the operator maintains defect control, the SI will track the performance of OCP categories 1 through 3 for a 25 day period using MISP Hog Form 8-1 through 8-3 and Table 1
- Each OCP category will be tracked each shift and referenced to the Table 1 values
- In establishments where slaughter production occurs on multiple shifts, OCP category performance assessment of each shift will be performed independently. The SI will record that the operator passed or failed each of the 3 OCP categories on the appropriate MSIP Hog Form 8 and notify the operator of their findings
- For an entire 25-day period, the maximum number of days on which the Table 1 performance standards can be exceeded is:
- maximum days (OCP's) (number of days above maximum defects allowed Per 25-Day Period)
- OCP-1 is 2 days
- OCP-2 is 4 days
- OCP-3 is 3 days
- maximum days (OCP's) (number of days above maximum defects allowed Per 25-Day Period)
If the operator exceeds the maximum days for any OCP category for a 25-day period, at any point during the 25 days, the SI will indicate the non-compliance on Form 10 and in the applicable CVS task. The operator should detail what new corrective and preventive actions are implemented to correct the issue and prevent recurrence. The operator will provide this information to the SI. Verification testing results for the window failed OCP category are not recorded or tracked until the operator implements corrective actions.
Note: a 25 day period will end at a full 25 days provided that the maximum number of days is not exceeded. If the maximum number of days are exceeded before 25 days are completed, the period stops, then while the operator responds to the noncompliance (as described above), a new 25-day period will begin when those conditions are satisfied.
CFIA verification of slaughter floor harvested edible products
- The CFIA will once per shift review the operators PCP records for slaughter floor harvested edible products to ensure control is maintained. The PCP must contain validated sample size, sampling frequency, monitoring records and corrective action records. The CFIA will document this record review and any findings on MSIP-Hog Form 10.
Should a record demonstrate lack of control on food safety defects, the CFIA will verify that the operator took corrective actions on the process and the implicated product to the last negative check, and verify that the operator implements and documents corrective action to:
- identify and eliminate the cause of the deviation;
- ensure that the CCP (critical control point) is under control after the action is taken;
- establish measures to prevent recurrence; and
- ensure that no product that is injurious to health enters commerce.
- CFIA will inspect 1 type of harvested edible product at least once per shift immediately prior to packaging using the sampling volume specified and validated in the operator's PCP. The type of product inspected will alternate each shift. If there is a suspicion of an issue with any product, it may be sampled in addition to the scheduled product for the shift. Any product with an observed defect and product cross contaminated with a food safety defect will be removed and shown to the operator. Removed product may be discarded or made to conform to edible standards by the operator and re-inspected by the CFIA to confirm edible status before repackaging. The results of this verification will be recorded on MSIP Hog Form 10.
- Should, during CFIA verification of slaughter floor harvested edible products, an observed defect be fecal, ingesta, milk, or food safety pathology; the operator must take corrective action on the process and implicated product to the last negative operator check. SI will document the finding on MSIP Hog Form 10. The CFIA will verify and document on Form 10 that the operator did:
- identify and eliminate the cause of the deviation;
- ensure that the CCP is under control after the action is taken;
- establish measures to prevent recurrence; and
- ensure that no product that is injurious to health enters commerce.
Implementation correlation
The VIC and/or SI will meet regularly with the operator to conduct correlation activities during the implementation period. Regular correlation will aid CFIA and the operator in establishing a common basis for both FS and OCP determinations.
Appendix 1
| Performance standard categories | Operator performance standards |
|---|---|
| FS-1, condition: infectious (septicemia/toxemia, cysticercus) |
0 |
| FS-2, condition: digestive content/milk (fecal material, ingesta, milk) |
0 |
| FS-3, ante-mortem suspect (neurologic conditions, moribund, pyrexic) |
0 |
| OCP-1, carcass, pathology Footnote * (for example: arthritis, emaciation, erysipelas, localized abscess, mastitis, metritis, mycobacteriosis [M Avium], neoplasms, pericarditis, pleuritis, pneumonia, uremia) |
4.1% |
| OCP-2, visceral pathologyFootnote * (for example: cystic kidneys, enteritis/gastritis, fecal contamination of harvested non gastro intestinal tract viscera, contamination of grey or red offal if it impedes inspection, nephritis/ pyelonephritis, peritonitis, parasites—other than Cysticercus |
7.2% |
| OCP-3, miscellaneous (for example: anemia, bile, bruise, edema, external mutilation, fractures, icterus, odor, skin lesions, scabs, toenails not removed) |
20.5 % |
Table Notes
- *
-
Conditions exhibiting a septicemia or toxemia are considered food safety hazards