Procedures for preparation of feet or paws (poultry), head and feet-on carcasses (poultry), head-on (rabbits) for edible purposes

1.0 Introduction

This document will be read together with Dressing procedures and Preparation of edible parts and Additional Poultry and Rabbit Dressing, Evisceration Floor Procedures.

This guidance provides general criteria, validation procedures (organoleptic and microbiological), and assistance to be provided to CFIA during verifications for:

  • poultry feet or paws
  • head and feet-on poultry carcasses
  • head-on rabbit carcasses

2.0 Poultry feet or paws

2.1 General criteria

The edible poultry feet or paws will be prepared as edible according to the following criteria:

  1. As part of Preventive Control Plan (PCP), the license holder must have written procedures for harvesting poultry feet or paws for examination by the CFIA veterinarian with supervisory authority. The written procedures will include provisions for validating and monitoring the edible feet or paws according to the microbiological and organoleptic procedures as written in the document.
  2. Follow good manufacturing practices as below:
    • all edible feet or paw contact surfaces (such as equipment, refrigerated and non-refrigerated rooms) will be maintained visibly clean during operations
    • sorting, trimming and packaging operations will be performed such that feet or paws ready for packaging are not contaminated by defective feet or paws
    • there will be sufficient separation (such as space) from other processing operations so that the poultry feet or paws do not present a contamination hazard to other processed poultry products
  3. When harvesting feet:
    • there is zero tolerance for fecal contamination
    • feet and carcass surfaces will be maintained visibly clean during operations
    • the feet will be removed at the tarsal joint
    • epidermis and the toenails are removed
    • only feet or paws free of faecal contamination are to be transferred to the edible product processing area
    • edible poultry feet or paws will be chilled to 4°C or lower within 4 hours after scalding operations
    • if feet remain attached to the carcass until after the post mortem inspection /detection, they will not present a contamination hazard
    • if feet are removed prior to post mortem inspection /detection, the license holder must have a written protocol examined by the CFIA veterinarian with supervisory authority to ensure that feet are not harvested from carcasses rejected or condemned for generalized pathology
    • the harvesting procedures will be validated and subsequently monitored using organoleptic and microbiological criteria
  4. If the licence holder has more than one shift, all microbiological and organoleptic sampling described in this section will be equally distributed amongst the shifts.
  5. The feet or paws may be sent under appropriate controls from a licensed slaughter establishment to another licensed establishment for scalding, cleaning and further preparation as an edible meat product. In such case, the licence holders of both the establishment must have a written procedures outlining how and where control measures, validation procedures are conducted.

2.2 Initial validation

The license holder will validate the effectiveness of salvage of edible poultry feet or paws procedures.

For licence holders that have two shifts, only one process validation is necessary for both slaughter shifts provided there are no significant operational differences between shifts.

The license holder that slaughters multiple species of poultry, such as chicken broilers, spent hens and turkeys, a separate process validation will be conducted for each species. Different weight ranges of the same species may be considered as one class and require only one process validation such as one process validation for chicken broilers and roasters or one validation for all weight ranges of turkeys.

Initial validation for poultry feet or paws will use the following principles:

  1. Organoleptic criteria
    • define and categorize the defects
    • develop accept and reject criteria for each defect category
    • define a lot
    • develop sampling plan
    • develop acceptance criteria which is representative of production shift(s)
    • develop corrective action to bring process under control
    • develop corrective action for affected product
  2. Microbiological criteria
    • define target organism which will be used as an indicator for process (such as generic E. coli)
    • develop sample size, frequency of microbiological sampling
    • develop acceptance criteria
    • develop corrective action to bring process under control
    • develop corrective action for affected product

Note

  1. The microbiological levels on final product are used as an assessment/indicator of process used for production of edible feet.
  2. A moving window approach (similar to poultry carcasses) is recommended when using microbiological criteria for feet.

2.2.1 Organoleptic sampling, testing and control procedures

Organoleptic defect definitions, acceptance criteria

The following accept/reject values apply to post-scald, young chicken feet after they have been sorted by the licence holder.

Defect definition (category) Dimensions Accept Reject
Inflammatory process - sore, wound or other defect associated with an active inflammatory process including, but not limited to, sanguineous (hemorrhagic), oedema, fibrinous, or cheese-like exudate and/or hyperaemia.
For example: bumblefoot, laceration, infection, or ammonia burn associated with oedema, necrosis, gangrene, or sanguineous fluid.		 Any 2 3
Resolving or healing wound - sore, wound, or other tissue condition showing evidence of resolving or healing not associated with an active inflammatory process.
For example: thickening of the skin, callus, scab, ammonia burn, dermatitis, tendonitis, or synovitis (not associated with active inflammation).		 Small ( < 1.25 cm) 13 14
Medium (> 1.25 - 2.5 cm) 6 7
Large (> 2.5 cm) 3 4
Βruise - tissue damage that resulted from trauma not associated with signs of inflammation. A bruise associated with an inflammatory process is recorded in the "Inflammatory Processes"category.
For example: red to black or greenish discoloration of the skin and/or underlying tissues associated or not associated with visible infiltration of blood or blood clots, and bruising associated with bone fractures.		 Small (< 1.25 cm) 6 7
Medium (> 1.25 - 2.5 cm) 3 4
Large (> 2.5 cm) 2 3
Compound fracture - a bone fracture that has caused an opening in the skin. A compound fracture associated with bruising is not scored in the "Bruise" category. A defect containing a compound fracture and bruising is scored only once in the "Compound Fracture" category. Any 5 6
Cuticle - the outer, or epidermal, layer of skin.
For example: any cuticle attached after scalding to remove the cuticle. A cuticle associated with a scab, callus, bruise, or mutilation is not scored/counted twice, such as, a callus with attached cuticle is scored only once in the callus defect category and not twice (once in the callus category and once in the cuticle category).		 Small (< 1.25 cm) 3 4
Medium (> 1.25 - 2.5 cm) 2 3
Large (> 2.5 cm) 2 3
Extraneous material - organic or inorganic material or carcass tissue observed on the paw that is not attached by natural attachments; also includes attached feathers when present.
For example: ingesta, grease, grease stains, unidentified material, identifiable material, i.e., plant fiber, seeds, dirt, metal, rust, unattached toe nail, unattached cuticle, unattached feathers (down, filoplums/hairs, bristle feathers), unattached skin or other carcass tissue, and attached feathers.		 Small (< 1.25 cm) 3 4
Medium (> 1.25 - 2.5 cm) 2 3
Large (> 2.5 cm) 1 2
Mutilation - post-mortem processing defect due to dressing and/or processing of the slaughtered bird or processing of the feet. Mutilation associated with bruising is not scored/recorded as mutilation. A defect containing tissue damage and bruising is scored/counted only once in the bruise category. Mutilation defects associated with acute inflammation are scored under the "Resolving or Healing Wound" category or under the "Inflammatory Process" category when associated with chronic inflammation.
For example: a cut or laceration of the skin and/or underlying tissues, more than two missing digits, broken or crushed bone without an associated opening through the skin, and joint separation.		 Any 7 8
Toenail - the hard keratin dorsal plate of the claw at the end of the digits of the foot. It does not include the softer keratin plate that remains at the end of the digit when the hard dorsal plate of the cuticle that covers softer keratin plate is removed. Any 4 5

Note

The licence holder may use the accept/reject values developed for young chicken feet for other poultry species.

Sample size, lot definition

A lot is defined as one hour production.

A sample of 50 randomly selected feet will be selected from each lot.

Using the definitions and corresponding accept/reject numbers check if the lot is accepted.

Acceptance criteria

For a lot to be considered acceptable there will be no failure of any "Organoleptic defect definitions" category.

The initial validation period is completed once 10 consecutive shifts (minimum of one lot per half shift, minimum 20 samples in total) are accepted.

Corrective actions following a rejected sample

If a sample fails a test, the entire lot will be reworked and another sample will be selected from the same lot.

If the second sample fails from the same lot, the entire lot will be reworked (again), an investigation will be conducted to determine the probable cause and corrective action will be taken as indicated.

The licence holder will decide if

  • the affected product is edible
  • the feet or paw operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder must present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

2.2.2 Microbiological sampling, testing and control

Microbiological test requirements

According to a written procedure examined by the CFIA veterinarian with supervisory authority, the license holder will specify:

  • how samples are randomly selected
  • how carcasses are identified in order to differentiate between head and feet-on and without head and feet on carcasses
  • sampling location
Microbes to be tested

E. coli counts from packaged, chilled, edible poultry feet or paws will be validated using the Poultry Pathogen Reduction Program using a moving window approach. This includes using E. coli sampling, testing and analyzing results similar to poultry carcasses.

Sample size and frequency

Sufficient samples (minimum of 10 paws per sample) will be collected once per half shift to complete one "moving window" for each species of poultry.

Acceptance criteria

The microbiological validation is performed using a moving window of 13 samples and will be considered acceptable when:

  • no sample is above 1,000 cfu/ml
  • no more than 3 samples are greater than 100 cfu/ml
Corrective actions following a rejected sample

If at any time the samples do not meet criteria, then an investigation will be conducted to determine the probable cause and corrective action taken as indicated.

The licence holder will decide if

  • the affected product is edible
  • the feet or paws operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder will present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

2.3 Post-validation procedures

Post-validation for poultry feet or paws will use the following principles:

  1. Organoleptic criteria
    • continue using the defect definition and defect category as defined in initial validation
    • continue using the accept and reject criteria for each defect category
    • define a lot
    • develop sampling plan
    • develop acceptance criteria which is representative of production shift(s)
    • develop corrective action to bring process under control
    • develop corrective action for affected product
  2. Microbiological criteria
    • define target organism which will be used as an indicator for process (such as generic E. coli)
    • develop sample size, frequency of microbiological sampling
    • develop acceptance criteria
    • develop corrective action to bring process under control
    • develop corrective action for affected product

2.3.1 Organoleptic criteria

Once the initial validation of poultry paw collection has been successfully completed, the licence holder will continue to sample each lot (1 hour production) with a minimum of 1 lot per half shift, using a sample of 50 randomly selected feet.

If at any time the samples do not meet criteria, then an investigation will be conducted to determine the probable cause and corrective action taken to bring process back under control.

The licence holder will decide if

  • the affected product is edible
  • the feet or paw operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder must present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

2.3.2 Microbiological criteria

Once the initial validation procedure is successfully completed, the testing frequency may be reduced to a randomly selected sample once per week for 2 months; and if the samples continue to meet the criteria, then the testing frequency may be reduced to a randomly selecting and testing 1 sample once per month.

If at any time the samples do not meet criteria, then an investigation will be conducted to determine the probable cause and corrective action taken to bring process back under control.

The licence holder will decide if

  • the affected product is edible
  • the feet or paw operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder must present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

2.4 Recording poultry feet defects

A separate poultry feet defects log will be used for each species of poultry.

For abattoirs with more than one shift per day, test results for each shift will be considered independently because of differences of personnel and supervisors between shifts and test results for each shift will be considered independently. Thus, test results will be recorded on separate poultry feet defects log.

Defects will be recorded by the licence holder on the “Defect log for poultry feet and paws” contained in guidance document titled Forms.

2.5 Assisting CFIA verification

Organoleptic verification

When requested the license holder will assist CFIA personnel (at least once per week) to evaluate licence holder’s process control. An organoleptic evaluation may be conducted in two ways:

  • Evaluate the licence holder’s monitoring methods (such as sampling frequency, random sampling methods, defect evaluation, defect recording, evaluation of results, corrective actions taken).
    • If monitoring methods are assessed by CFIA to be unacceptable, the licence holder will initiate corrective actions.
  • Perform a test once per shift
    • If a sample is rejected, the licence holder will initiate an immediate retest and implement correctives measures as necessary.
    • If faecal material is found, immediate corrective action will be initiated.

Microbiological verification

When requested, the license holder will assist CFIA personnel ensure that the process is in compliance to the Poultry Pathogen Reduction Program.

3.0 Head and feet-on poultry carcasses

3.1 General criteria

  1. The edible poultry feet or paws will be prepared as edible according to the following criteria:
    1. As part of Preventive Control Plan (PCP), the license holder must have written procedures for head and feet-on poultry carcasses for examination by the CFIA veterinarian with supervisory authority. The written procedures will include provisions for validating and monitoring the head and feet-on poultry carcasses according to the microbiological and organoleptic procedures as written in the document.
    2. Dressing of poultry carcasses with head and feet on will be performed according to the following criteria:
      • heads and feet will not present a contamination hazard
      • all carcass and equipment surfaces will be maintained visibly clean during operations
      • the feet will be free of faecal contamination prior to the venting and/or opening of the abdominal cavity
      • prior to chilling
        • all pathological, processing and trimming defects of head and feet-on carcasses will been removed
        • the oral cavity and nostrils will be free of extraneous material
        • epidermis and the toenails will be removed
  2. If the licence holder has more than 1 shift, all microbiological and organoleptic sampling are to be equally distributed amongst the shifts.
  3. The uropygial or oil gland may be left on carcasses with the head and feet attached when:
    • the carcass is labelled so as to indicate the presence of the oil gland
    • the oil gland is completely removed from carcass, carcass part which will be incorporated into meat product such as mechanically deboned meat (MDM)/mechanically separated meat (MSM)

Note

The head and feet-on poultry carcasses guidance is also applicable to poultry with just head attached or just feet attached.

3.2 Initial validation

Initial validation for head and feet on poultry carcasses will use the following principles:

  1. Organoleptic criteria principles
    • define and categorize the head defect
    • define and categorize the feet defects
    • develop accept and reject criteria for each defect category
    • define a lot
    • develop sampling plan
    • develop acceptance criteria which is representative of production shift(s)
    • develop corrective action to bring process under control
    • develop corrective action for affected product
  2. Microbiological criteria principles
    • define target organism which will be used as an indicator for process (such as generic E. coli)
    • develop sample size, frequency of microbiological sampling
    • develop acceptance criteria
    • develop corrective action to bring process under control
    • develop corrective action for affected product

Note

  1. The microbiological levels on final product are used as an assessment/indicator of process used for production of carcasses with head and feet.
  2. A comparative approach (comparing the carcasses with head and feet on to ones produced with head and feet removed) is recommended when using microbiological criteria for carcasses with head and feet.

3.2.1 Organoleptic sampling, testing and control procedures

Defect definitions

The head and feet defects are defined below:

Organoleptic defect definitions – head defects
Head defects (category) Definition
Attached feathers 10 or more feathers < 10 mm is counted as a defect
5 or more feathers ≥ 10 mm is a defect
Extraneous material Any extraneous material, specks, smears, or stains of inedible material in the oral cavity, nares or on the surface of the head.
3 or more specs ≤ 1.5 mm is counted as a defect
Each spec > 1.5 mm is a defect
Examples: ingesta, unattached feathers, grease, bile, unattached epidermis.
Faecal material Any visible material determined to be from the lower gastrointestinal tract.
Sinusitis A foamy discharge from the nares which may be accompanied by a swelling of the paranasal sinuses. Gross lesions may include exudate in the nasal and respiratory system. Comb and wattle discolouration may range from red to dark blue.
Substandard condition Inadequate condition that affects the structure or colouration of the headTable Note 1.
Examples: BruisingTable Note 2, mutilation, inadequate bleeding.

Table Notes

Table Note 1

Does not apply to the beak.

Return to table note 1 referrer

Table Note 2

Only a bruise ≥ 13 mm is counted as a defect.

Return to table note 2 referrer

Organoleptic defect definitions – feet defects
Feet defects (category) Definition
Attached epidermis Failure to completely remove attached epidermis from the foot.
Attached toenail(s) Failure to remove the toenail.
Bumblefoot Swollen foot pads with chronic infection of the sub dermal area including the joints ≥ 6 mm.
Compound fractures Any bone fracture of the feet or toes that has caused an opening through the skin.
Dermatitis Any blisters, ulcers, scabs affecting the skin and/or subcutaneous tissues.
Any visible lesion ≥ 3 mm is counted as a defect.
A cluster of lesions in close proximity within an area > 13mm is counted as a defect.
Extraneous material Any extraneous material, specks, smears, or stains of inedible material on the surface of the feet.
3 or more specs ≤ 1.5 mm is counted as a defect.
Each spec > 1.5 mm. is counted as a defect.
Examples: Ingesta, unattached feathers, grease, bile, unattached epidermis.
Faecal contamination Any visible material determined to be from the lower gastrointestinal tract.
Substandard condition Imperfect condition that affects the structure or colouration of the feet.
Ammonia burns less than 6 mm and with no secondary pathology are also not counted as a defect.
Each bruise ≥ 13 mm is counted as a defect.
Each black/green bruise ≥ 6 mm is counted as a defect.
Each ammonia burn ≥ 6 mm is counted as a defect.
Examples: Bruising, mutilation, inadequate bleeding, ammonia burns
Note: slight skin reddening and minimal bleeding from cut ends are not counted as a defect.
Organoleptic test criteria (sample size, acceptance criteria)

During initial validation, ISO-based sampling will be conducted by randomly selecting enough cases to perform a 20 carcass sample at a frequency of once per half shift as per the following table:

Sampling Standard for Head and Feet-on Carcasses
Acceptance and Rejection Numbers
Carcass part Sample size code letter Inspection mode Sample size AQL Accept number Reject number
Head and feet F Normal 20 Carcasses 6.5% 3 4
Feet Only F Normal 20 Carcasses 4.0% 2 3
Head Only F Normal 20 Carcasses 4.0% 2 3

The initial validation period is completed once 10 consecutive shifts (minimum of one lot per half shift, minimum 20 samples in total) are accepted.

Note

The licence holder may write an equivalent ISO-based establishment specific Statistical Process Control program.

Corrective action

If a sample fails a test, the affected case(s) will be reworked and another sample will tested from the same half shift.

If the retest fails, the entire half shift will be reworked, an investigation conducted to determine the probable cause, corrective action taken to bring process back under control.

The licence holder will decide if

  • the affected product is edible
  • the head and feet operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder must present the written corrective action and procedures for examination by the CFIA veterinarian with supervisory authority.

3.2.2 Microbiological sampling, testing and control procedures

Microbiological test requirements

According to a written procedure examined by the CFIA veterinarian with supervisory authority, the license holder will specify:

  • how samples are randomly selected
  • how carcasses are identified in order to differentiate between head and feet-on and without head and feet on carcasses
  • sampling location
Microbes to be tested

E. coli counts from head and feet-on carcasses will be validated using the Poultry Pathogen Reduction Program. This includes using E. coli sampling and testing similar to poultry carcasses.

Sample size, location of sample

Microbiological validation consists of the collection of 50 concurrent (paired) samples. A concurrent sample is comprised of one carcass without head and feet on (control population) and one carcass with the head and feet on (target population) collected from the evisceration line just prior to entering the chilling system. Both samples will be approximately selected at the same time.

Acceptance criteria

The licence holder will use CFIA developed Excel-based application ("Micro Data Analysis") and user’s manual or may develop an equivalent establishment specific Statistical Process Control (SPC) program. The licence holder may obtain a copy of "Micro Data Analysis" from the CFIA veterinarian with supervisory authority.

After the data is entered, in the CFIA developed Excel-based application (“Micro Data Analysis”), the result of the geometric mean of head and feet-on carcasses will be equal to or less than that of carcasses without head and feet on or is not significantly different as determined by statistical analysis.

The test results will be presented to the CFIA for examination by the Veterinarian with Supervisory Authority.

Corrective actions following a rejected sample

If at any time the samples do not meet criteria, then an investigation will be conducted to determine the probable cause and corrective action taken as indicated.

The licence holder will decide if

  • the affected product is edible
  • the head and feet operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder will present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

3.3 Post-validation procedures

Post-validation for head and feet on poultry carcasses will use the following principles:

  1. Organoleptic criteria principles
    • define and categorize the head defect
    • define and categorize the feet defects
    • develop accept and reject criteria for each defect category
    • define a lot
    • develop sampling plan
    • develop acceptance criteria which is representative of production shift(s)
    • develop corrective action to bring process under control
    • develop corrective action for affected product
  2. Microbiological criteria principles
    • define target organism which will be used as an indicator for process (such as generic E. coli)
    • develop sample size, frequency of microbiological sampling
    • develop acceptance criteria
    • develop corrective action to bring process under control
    • develop corrective action for affected product

Note

  1. The microbiological levels on final product are used as an assessment/indicator of process used for production of carcasses with head and feet.
  2. A comparative approach (comparing the carcasses with head and feet on to ones produced with head and feet removed) is recommended when using microbiological criteria for carcasses with head and feet.

Organoleptic criteria

The licence holder has the option of continuing to use the ISO sampling plan from initial validation step or to write an equivalent establishment specific Statistical Process Control program. For both options, the frequency of sampling will at least be conducted as per the following table as a minimum.

Post-validation sampling frequency
Step Frequency Number of Shifts Requirements to shift to next lower frequency of sampling
Step 1 Once per shift 10 consecutive shifts All samples are accepted
Step 2 Once per 2 shifts N/A N/A

If at any time the samples do not meet criteria, then an investigation will be conducted to determine the probable cause and corrective action taken to bring process back under control.

The licence holder will decide if

  • the affected product is edible
  • the head and feet operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder will present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

Microbiological criteria

The production of head and feet-on carcasses will be monitored by using sample collections and laboratory test procedures for generic E. coli as outlined in Poultry Pathogen Reduction Program.

Once the initial validation procedure is successfully completed, the post-validation testing frequency may be reduced to

  • a randomly selected sample once per week for two (2) months; and
  • if the samples continue to meet the criteria, then the testing frequency may be reduced to a randomly selecting and testing one (1) sample once per month

If at any time the samples do not meet criteria, then an investigation will be conducted to determine the probable cause and corrective action taken to bring process back under control.

The licence holder will decide if

  • the affected product is edible
  • the head and feet operations need to be revalidated
  • the written procedure and feet harvesting procedures needs to be amended

The license holder will present the written corrective action and procedures for examination to the CFIA veterinarian with supervisory authority.

3.4 Recording poultry head and feet-on carcasses defects

A separate poultry Head and Feet-on Carcasses log will be used for each species of poultry.

For abattoirs with more than one shift per day, test results for each shift will be considered independently because of differences of personnel and supervisors between shifts and test results for each shift will be considered independently. Thus, test results will be recorded on separate poultry feet Defects Log.

Defects will be recorded by the licence holder on the “Defect Log for Head and Feet-on Carcasses” contained in guidance document titled Forms.

3.5 Assisting CFIA verification

Organoleptic verification

When requested the license holder will assist CFIA personnel (at least once per week) to evaluate licence holder’s process control. An organoleptic evaluation may be conducted in two ways:

  • Evaluate the licence holder monitoring methods (such as sampling frequency, random sampling methods, defect evaluation, defect recording, evaluation of results, corrective actions taken).
    • If monitoring methods are assessed by CFIA to be unacceptable, the licence holder will initiate corrective actions.
  • Perform a test once per shift
    • If a sample is rejected, the licence holder will initiate an immediate retest and implement correctives measures as necessary.
    • If faecal material is found, immediate corrective action will be initiated.

Microbiological verification

When requested, the license holder will assist CFIA personnel ensure that the process is in compliance with the Poultry Pathogen Reduction Program.

4.0 Head-on rabbit carcasses

A domesticated rabbit may be dressed with the head on.

As part of Preventive Control Plan (PCP), the license holder must have written procedures for dressing of head-on rabbit carcasses which will be available for examination by the CFIA veterinarian with supervisory authority.

The licence holder’s written protocol will include the applicable conditions from the head on poultry (section 3).

Additional Guidance

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