Pre-chill microbiological monitoring program for raw poultry

On this page

1. Introduction
2. Purpose
3. What is included
4. What is not included
5. Roles and responsibilities
6. Definitions
7. General considerations for pre-chill microbiological monitoring
8. Assessment of test results
9. Deviation Procedures and Corrective Actions
10. Developing own PMMP

1. Introduction

Live birds inherently bring a certain load of enteric pathogens to the slaughter process. Every stage from the hanging of the carcass in the live receiving, to its entrance into the chiller, has a potential to influence the microbial load on the final product. Monitoring the microbial load at a defined point before carcasses enter the chiller (pre-chill) allows for a targeted evaluation of the contamination control measures applied during the dressing and evisceration stages.

Furthermore, data generated through the PMMP are intended to drive science-based decisions within an operator's food safety system to optimize interventions and enhance food safety. These data will empower licence holders to verify the effectiveness of their existing control measures, validate the impact of process changes, optimize interventions (such as microbial interventions, equipment sanitation protocols, or adjustments to evisceration techniques), and demonstrate ongoing compliance with their Preventive Control Plan (PCP) requirements under the Safe Food for Canadians Regulations (SFCR). Furthermore, establishing operator's own internal performance baselines using PMMP data will allow businesses to track their own performance over time, identify subtle shifts in process control, and pursue continuous improvement initiatives.

The principles of pre-chill or early-stage microbial monitoring can be integral components of comprehensive poultry safety management systems. Competent authorities in other jurisdictions, such as the United States Department of Agriculture's Food Safety and Inspection Service (USDA FSIS), also incorporate requirements for microbial monitoring at various stages, including consideration of pre-chill data, to verify process control in poultry slaughter establishments.

2. Purpose

The Canadian Food Inspection Agency (CFIA) developed the following microbial sampling measures to help food businesses comply with section 47 and 89(1)(c)(i) of the Safe Food for Canadians Regulations (SFCR).

The implementation of a PMMP directly supports compliance with:

• SFCR 47(1): Hazard identification and analysis: Requires operators to identify and analyze biological hazards (such as indicator organisms that reflect potential fecal or environmental contamination) which pose a risk of contamination of food.
• SFCR 47(2): Hazard control: Requires operators to prevent, eliminate, or reduce identified hazards to an acceptable level using control measures shown by evidence to be effective. The PMMP serves as a tool to generate such evidence for controls applied during evisceration and dressing.
• SFCR 89(1)(c)(i): Preventive Control Plan Content: Requires the written PCP to include a description of identified biological hazards, the control measures used to address them, and evidence demonstrating the effectiveness of those control measures. PMMP results contribute directly to fulfilling this evidence requirement.

The microbial monitoring of poultry carcasses at pre-chill location(s) and comparison with post-chill location (s) will specifically help demonstrate that contamination is effectively minimized throughout the evisceration and dressing process.

3. What is included

This document outlines general guidelines for establishing a PMMP utilizing microbiological indicator organisms on poultry carcasses to demonstrate effective process control.

This PMMP should be integrated to the PCP supporting the Process Verification Monitoring Program for generic E. coli – Biotype I for raw poultry (PVMP) as a complement, not duplicate. While this document outlines the PMMP separately for clarity, its implementation should leverage PVMP structures where appropriate (such as random sampling principles, record-keeping systems, corrective action framework) to ensure consistency and efficiency, avoiding unnecessary duplication.

The key distinction lies in the sampling point and primary focus: the PVMP assesses the overall process outcome by testing carcasses after chilling, reflecting the cumulative effect of all slaughter, dressing, and chilling interventions. In contrast, the PMMP can provide specific verification data on the effectiveness of upstream controls applied during evisceration and dressing (as examples) by sampling before chilling. The paired sampling approach (pre-chill and post-chill) allows for a direct assessment of the net microbial change occurring between these two important points. The PCP must clearly delineate how pre-chill results are analyzed and trigger investigations or actions specific to upstream processes, distinct from those triggered by post-chill PVMP results.

4. What is not included

This document is specifically focused on the pre-chill microbiological monitoring component of a licence holder's overall food safety system. It is intended to complement, not replace or duplicate, other essential elements of the Preventive Control Plan (PCP) and related regulatory requirements. Therefore, this document does not provide detailed specifications for:

• comprehensive development and content of a written PCP
• detailed requirements of the Process Verification Monitoring Program for generic E. coli – Biotype I for raw poultry (PVMP), except where it is referenced for context, alignment, or integration
• detailed protocols for specific interventions or control measures (such as specific parameters for carcass washes or antimicrobial applications); licence holders must validate their own chosen interventions

5. Roles and responsibilities

Food businesses are responsible for complying with the law. They demonstrate compliance by ensuring that the commodities and processes for which they are responsible meet regulatory requirements. If a written PCP is required, the food business develops a PCP with supporting documents, monitors and maintains evidence of its implementation, and verifies that all control measures are effective.

CFIA verifies the compliance of a food business by conducting activities that include inspection and surveillance. When a non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.

6. Definitions

Some terms use in this document are defined in the Process Verification Monitoring Program for generic E. coli – Biotype I for raw poultry. In addition, the following definitions apply in this document.

Raw poultry carcass

A whole poultry carcass which has not been cooked

Re-hang

A pre-chill location after post-defeathering carcass shower and after carcass has been transferred (re-hung) onto the shackles of the evisceration line, but before they undergo any subsequent interventions (such as pre-evisceration shower) or evisceration procedures such as venting or opening

Post-chill

A point immediately after chilling and completion of all interventions and processing steps, but before product leaves the establishment

Pre-chill Microbiological Monitoring Program (PMMP)

The systematic assessment of microbial levels on poultry carcasses at re-hang, designed to verify the effectiveness of evisceration and dressing processes in reducing contamination

Paired sampling

The practice of collecting two distinct samples from the same identifiable production lot (specifically, originating from the same flock) at two different, defined points in the manufacturing process (for this program: re-hang and post-chill) to allow for comparative analysis of microbial levels between those points

Indicator organisms

Microorganisms or a group of microorganisms that, whose presence, absence, or concentration is measured to assess the general microbiological condition of the food product or environment, the potential presence of fecal contamination, or the adequacy of process controls. They are typically not pathogens themselves but serve as indicators of hygiene and process effectiveness

Baseline criteria

A performance indicator set for a specific test and defined in operator's PCP. This can be a published standard or individually validated; serves as a reference point for assessing compliance with food safety regulations and identifying areas for improvement in processing and handling practices

7. General considerations for pre-chill microbiological monitoring

• Follow applicable principles presented in the "Section 6. Key sections of the written programs" of the Process Verification Monitoring Program for generic E. coli – Biotype I for raw poultry
• The principle of this program is to monitor the effectiveness of the evisceration processes by:
  • assessing a pre-chill microbiological sample against an equivalent post-chill microbiological sample
  • assessing the chosen samples against establishment's own baseline criteria
• The minimal annual poultry slaughter volumes that warrant pre-chill microbiological monitoring are:
  • chickens, quails: 440,000 birds per year
  • other poultry species (combined): 60,000 birds per year (this includes turkeys, ducks, geese)
• Sample type: A sample unit is a whole raw carcass with intact skin
• Recommended location for paired sampling
  • 1st sample (pre-chill): collected at re-hang location as defined in Section 6
  • 2nd sample (post-chill): collected at post-chill location as defined in Section 6 (this can be the same sample collected for the PVMP)

• Frequency:
  • use the random sampling methodology used in the PVMP program
  • one sample will be collected at the re-hang location using a defined indicator. The sample will be tested for the same indicator organism
  • sampling frequency is based upon the establishment's inspection program:
    • licence holders operating under the Modernized Poultry Inspection Program (MPIP) will sample once per week
    • licence holders operating under the Traditional Inspection Program will sample once per month
    • licence holders operating under both MPIP and Traditional Inspection, sample once per week
  • when multiple species are produced, they should be randomly sampled to ensure representation of your production
  • when multiple species are produced, the baseline criteria (defined in operator's PCP) should be developed separately for individual species
  • when a raw poultry product is produced over more than 1 shift, it should be randomly sampled over all shifts to ensure even representation
  • when raw poultry product is produced over more than 1 line, it should be randomly sampled over all operational lines to ensure even representation
• Indicator organism:
  • Selection: select one indicator organism (or group) from the list in Table 1 below for use in their PMMP.
  • Consistency: test the same selected indicator organism on both the pre-chill (re-hang) sample and the corresponding post-chill sample within each collected pair to allow for valid comparison

8. Assessment of test results

The analysis of the results from the paired samples is important for verifying process control.

• Paired comparison and analysis: compare the quantitative result of the post-chill sample to the result of its corresponding pre-chill (re-hang) sample for every pair collected.
  • Interpretation: effective interventions applied from re-hang to post-chill (carcass washing systems, chilling processes, microbial controls) are expected to lead to a reduction in the microbial load. Therefore, the post-chill result should generally be lower than the pre-chill result from the same flock.
  • Deviation: a post-chill result that is higher than its paired pre-chill result signals a potential failure in process control or a source of significant cross-contamination occurring between these two sampling points. Potential causes include:
    •  ineffective inside/outside bird washers
    • contaminated equipment surfaces contacting carcasses post-rehang
    • poor hygiene practices during transfer, or
    • issues within the chilling system (such as inadequate antimicrobial levels, excessive organic load, cross-contamination)
• Baseline criteria development and monitoring: When the licence holder includes baseline development and monitoring in their PCP, the licence holders should:
  • systematically collect and record all individual pre-chill (re-hang) test results over time.
  • utilize this accumulating data to statistically establish and validate their own establishment-specific performance baseline criteria (as defined in Section 6) for the chosen indicator organism at the re-hang location.
  • document the methodology you used to develop and validate these criteria (such as using control charts, calculating means and standard deviations over a defined period of demonstrated control) in the PCP.

This baseline will serve as an internal benchmark reflecting the typical microbial load entering the evisceration process when upstream controls (receiving, scalding, defeathering, washing) are functioning effectively.

Baselines should be periodically reviewed (such as annually) and updated as necessary to reflect significant process changes or sustained shifts in performance, ensuring they remain relevant indicators.

9. Deviation procedures and corrective actions

A documented procedure for responding to deviations is an important component of the PMMP, ensuring timely and effective action is taken when monitoring indicates potential issues.

• Deviation: a deviation requiring investigation and potential corrective action under the PMMP is indicated when the post-chill sample result is quantitatively higher than its corresponding paired pre-chill sample result.
• Corrective action: the principles and steps for corrective actions taken in response to PMMP deviations should align with the licence holder's overall PCP corrective action procedures and the framework outlined in Section 10 (Corrective action procedures) of the Process Verification Monitoring Program for generic E. coli – Biotype I for raw poultry. Licence holders should refer to this section and general PCP guidance for detailed requirements.

Upon identifying a deviation trigger, initiate the following steps, documenting each stage:

• Inform CFIA: notify the local CFIA inspection staff of the deviation finding (for paired comparison analysis only).
• Apply immediate controls (processes which are under control of the licence holder): review and assess effectiveness of the process controls and sanitation procedures related to dressing, evisceration and microbiological controls.
• Conduct a root cause analysis: Conduct and document a thorough investigation to determine the underlying cause(s) of the deviation.
  • Post-chill > Pre-chill: investigate processes and conditions between the re-hang and post-chill sampling points such as:
    • effectiveness and maintenance of inside/outside bird washers
    • potential cross-contamination points during transfer or handling
    • sanitation of equipment post-rehang
    • chiller water quality and antimicrobial levels
    • chiller loading and operation
• Implement corrective action(s): based on the root cause analysis, determine, implement, and document specific corrective actions designed to address the identified cause(s) and prevent recurrence of the deviation. Examples include:
  • adjusting process parameters (such as water temperature, pressure, flow rates)
  • enhancing sanitation procedures for specific equipment
  • repairing or modifying equipment
  • retraining employees on specific procedures
  • implementing new or enhanced antimicrobial interventions
  • working with suppliers to address incoming flock conditions
• Verify effectiveness: conduct follow-up activities (such as intensified monitoring, additional sampling) to verify and document that the implemented corrective actions have been effective in resolving the deviation and bringing the process back into a state of control.
• Reassess (if needed): if deviations persist despite corrective actions, reassess the situation to understand why previous actions were ineffective. This may involve a more extensive review of the relevant components of the PCP and potentially implementing more significant process changes.
• Keep Record: maintain detailed records of all aspects of the deviation response, including the initial trigger, investigation findings, root cause determination, corrective actions implemented, verification activities, and outcomes.

10. Developing your own PMMP

Licence holders can use alternate procedure (for example different prechill location or enhanced frequency) or use a different indicator micro-organism to meet the outcome of the PMMP. As an example, an operator may leverage its current microbial staging approach as an equivalent measure achieving the intended outcome.

Examples of alternatives: potential alternatives include (but are not limited to):

• utilizing a different, validated pre-chill sampling location (such as post-evisceration, pre-final wash), provided justification and validation data support its suitability for monitoring evisceration/dressing control
• implementing a different sampling frequency than the minimum specified
• using an indicator organism not listed in Table 1, provided its suitability as an indicator of process control in poultry dressing/evisceration is scientifically validated and documented
• integrating PMMP objectives into an existing, comprehensive microbial staging program, when program includes validated monitoring at an appropriate pre-chill point, uses suitable indicators, meets minimum frequency requirements, and demonstrably achieves the PMMP's verification goal

If you are using an alternative approach your PCP will include a complete and detailed description of the alternative program, supported by the validation evidence. This description will clearly outline:

• the specific indicator organism(s) used and the rationale for their selection
• the precise sampling location(s), sampling methodology, and sampling frequency
• when using an accredited laboratory, identify laboratory (SCC or CALA accredited) performing the analysis, and the specific analytical method employed
• when using in house laboratory testing, describe how your laboratory procedures are maintained, how they are equivalent with an accredited laboratory testing method how you train employees to perform testing, and when requested how you will present results to the CFIA
• the performance standards, baseline criteria, or other metrics used to assess results, including the methodology for their establishment and validation
• the documented deviation procedures and corrective actions specific to the alternative program
• the complete validation package demonstrating the alternative program's effectiveness and equivalence
• procedures for ongoing verification of the alternative program's effectiveness
• procedures for record keeping and ensuring data accessibility for CFIA review during inspections

Additional information – Further reading

The following references contain information on food safety controls, including examples. CFIA is not responsible for the content of documents that are created by other government agencies or other external sources.

CFIA references

• Process Verification Monitoring Program for generic E. coli – Biotype I for raw poultry
• Annex – Sampling procedures for generic E. coli in raw poultry
• Conducting a hazard analysis
• Corrective action procedures for your preventive control plan
• Risk Assessment models
• Evidence showing a control measure is effective
• Microbial controls for meat products and food animals
• Monitoring procedures for your preventive control plan
• Verification procedures for your preventive control plan
• Record keeping for your preventive control plan