Guidance on Specified Risk Material
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Part I: Removal of Specified Risk Materials
- 1.0 Introduction
- 2.0 Cattle identification, age determination, marking and segregation of carcasses upon arrival and during slaughter/dressing, chilling, cutting and boning procedures
- 2.1 Age determination, identification and marking of carcasses
- 2.2 Control and segregation of carcasses during dressing, chilling, cutting and boning procedures
- 3.0 Stunning, dressing, cutting/boning and SRM removal
- 3.1 Dedicated SRM tools
- 3.2 Stunning
- 3.3 Head separation and removal of skull, brain, trigeminal ganglia, eyes and tonsils
- 3.4 Palatine tonsils
- 3.5 Tongue and cheek meat
- 3.6 Removal of the distal ileum
- 3.7 Carcass splitting
- 3.8 Removal of the spinal cord and its verification
- 3.9 Removal of the dorsal root ganglia
- 3.10 Verification by the licence holder of SRM removal and rework
- 4.0 SRM handling and disposition
- 5.0 SRM controls
Part II: Enhanced feed ban controls and SRM management
- 6.0 Introduction
- 7.0 Collection, segregation and staining of SRM
- 8.0 Shipping of SRM from the establishment
- 9.0 Record keeping
- 10.0 Compliance and verification
- Appendix A: Cattle dentition
- Appendix B: Cattle vertebral column
- Appendix C: Cattle gastrointestinal tract
- Appendix D: Identifying marks: carcass of cattle aged 30 months or older
For the purposes of this guidance the following definitions apply:
- means animals of the species Bos taurus or Bos indicus and any animal that is the result of a cross with a Bos taurus or Bos indicus animal.; but does not include other ruminants such as bison, muskox, yak or water buffalo. All cattle crosses, therefore, will be subject to SRM guidelines and BSE policy. Canadian Food Inspection Agency (CFIA) inspection personnel will perform categorization of crosses by phenotypic (observable physical characteristics) examination. To challenge the inspector's phenotypic categorization for any possible disagreement, industry must provide documented proof of purebred status (e.g. yak or bison registration).
- Specified Risk Materials (SRM)
- means the skull, brain, trigeminal ganglia, eyes, palatine tonsils, spinal cord and dorsal root ganglia (DRG) of cattle aged 30 months or older, as well as the distal ileum of cattle of all ages.
The brain, trigeminal ganglia, eyes, palatine tonsils, spinal cord, dorsal root ganglia and distal ileum are designated as SRM because, in Bovine Spongiform Encephalopathy (BSE) infected cattle, these tissues contain the BSE agent and may transmit the disease. The OTM skull, excluding the mandible and horns, is designated as SRM as well because of the high probability of it becoming contaminated at the time of stunning and during manipulation of the other tissues if their separate removal was permitted.
- means cattle that are under 30 months of age.
- means cattle that are 30 months of age or older.
Part I: Removal of Specified Risk Materials (SRM)
These controls came into effect on July 24, 2003 and enhanced on July 12, 2007. The 2007 enhancements were introduced to mainly protect health of animals, whereas the 2003 SRM control requirements were introduced strictly to protect public health.
Part I of this document provides guidance on removal of SRM from cattle slaughtered in Canada in order to prevent tissues that may contain BSE infectivity from entering the human food chain. It is also a guidance to ensure that SRM does not enter the animal feed chain. The enhanced feed ban controls described in Part II of this guidance require the removal and effective segregation of all SRM tissues from raw material destined for the production of animal feed, pet food and fertilizers.
The information in this document pertains to requirements under Part I.1 of the Health of Animals Regulations, describing minimum standards beef slaughter and cutting/boning licence holders must meet to ensure that specified risk material neither enters human food nor the animal feed chain. These Health of Animal requirements will also meet the outcome of section 125 (1) (e) of the SFCR, meaning that the edible product does not contain any specified risk material (SRM). These practices have been historically considered as acceptable by international trading partners and fundamentally allow Canada to demonstrate its BSE surveillance and SRM controls.
Therefore, a license holder wishing to use alternate procedures to those described within must have them evaluated and approved by CFIA prior to their implementation.
1.1 Regulatory basis
Pursuant to Safe Food for Canadian Regulations (SFCR), specified risk material has the same meaning as in section 6.1 of the Health of Animals Regulations. (matériel à risque spécifié).
Under SFCR section 125 (1) (e), a licence holder may identify a meat product as edible only if the meat product is edible and is not contaminated, including that it does not contain any specified risk material.
Under SFCR section 155 (3), the licence holder must keep a meat product that is a specified risk material, contains a specified risk material or is derived from a specified risk material in a separate area of the inedible products area and must handle and destroy it in accordance with Part I.1 of the Health of Animals Regulations.
In addition, the licence holder must meet all the applicable provisions of the Health of Animals Regulations and Food and Drug Regulations.
The guidance is designed to meet the following objectives:
- to ensure removal of all specified risk materials (SRM); and
- to prevent cross contamination of edible meat products by SRM during slaughter and cutting/boning operations
- to ensure removal of all SRM from the animal feed chain
1.2 Preventive Control Plans
SRM is a food safety hazard and must be addressed in licence holders Preventive Control Plan (PCP) under the SFCR. When implementing PCP, licence holders are required to clearly identify Critical Control Points (CCPs) for animal aging (either by dentition examination or birth date documentation) and SRM removal. The licence holder is responsible for the development, implementation, and maintenance of control programs that address all components of this SRM removal guidance. These control programs are to be submitted to the CFIA for examination prior to their implementation and their implementation must demonstrate ongoing and effective control, including but not limited to, control over animal identification and aging, OTM carcass identification and marking, SRM removal and OTM carcass segregation. This is to make sure CFIA approved methods of preventing SRM cross contamination of product destined for the production of animal feed, pet food and fertilizer are consistent with the Health of Animal regulation components.
2.0 Cattle identification, age determination, marking and segregation of carcasses upon arrival and during slaughter/dressing, chilling, cutting and boning procedures
Licence holders slaughtering or cutting/deboning UTM and OTM cattle must develop 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.
At the slaughter establishment the identity of the cattle carcass and all its parts must be maintained until their final disposition is known. To achieve this, ear tags approved under the Livestock Identification and Traceability Program and distributed through the Canadian Cattle Identification Agency (CCIA), Lactanet and Attestra (Québec) will be attached, after its insertion into a plastic bag, to the fore shank of the carcass following hide removal.
2.1 Age determination, identification and marking of carcasses
Licence holders will reassess their Preventive Control Plan (PCP) and to develop a Critical Control Point (CCP) for age determination procedures (for example: by date of birth documentation review and/or dentition examination).
The age of cattle can be established by using reliable documentation that indicates the birth date of the animal or by examining the teeth. The birth date document, rather than dentition, provides the best means for determining the age of cattle. When documentation is available it should be used as the primary means of determining the age of animals.
Licence holders must maintain records of the age and identity of slaughtered cattle. The records are to include:
- information regarding the procedures used to determine the age of animals
- if age is determined by documentation, the document is to be maintained with the records for a period of two years from the date of slaughter
Determining age by birth date documentation
Submission of accurate birth date information by producers is strongly supported by the CFIA. Birth date information in the Canadian Cattle Identification Agency (CCIA) database, the Lactanet database or the Attestra database in the case of Quebec, is a CFIA recognized alternative to dentition for domestic meat inspection purposes, and live animal or meat exports. The availability of acceptable birth date information on a timely basis will mean that dentition assessment should not be necessary.
The CFIA also recognizes the original copies of official birth date documents issued by registered breed associations.
Agriculture and Agri-Food Canada (AAFC) has a web page that offers more details on the Animal Pedigree Act as well as a full list of Incorporated Breed Associations.
Acceptable methods for determining the age of an animal in the CCIA, Lactanet or Attestra database include either the actual date on which a calf is born or the first day of the calving period in which a group of calves was born. In cases where "estimated" birth dates are provided based on other methods, the date of birth is not to be accepted, and dentition will be used for aging.
CFIA will examine birth date documentation used by the licence holder for determining the age of cattle. If any deviations are observed at head inspection, CFIA will follow up on any discrepancy between birth date documentation and physical appearance of the head.
Loss of identification or no identification will result in the animal being aged by its dentition.
Determining age by dentition examination when no birth date documentation is provided
For the purposes of this guidance, cattle are considered to be aged 30 months or older (OTM) when they have more than two permanent incisor teeth erupted (that is, the first pair of permanent incisors and at least one tooth from the second pair of permanent incisors).
For the purpose of this guidance, 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 as less than 30 months of age (UTM) as long as the erupting third permanent incisor is not above the surface of the gum, whether it is at the back, on the top or at the front of the mandible. See Appendix A of this guidance for illustration and pictures of bovine incisor teeth and the corresponding age.
Visual examination of the incisor teeth of each carcass occurs at or before the head inspection station.
The licence holder will examine the incisor teeth of each carcass, and will determine if the carcass is derived from an OTM animal. The designated trained employee examining the teeth must be able to recognize permanent incisor teeth and be knowledgeable of this guidance. Alternatively the licence holder may decide to treat all slaughtered animals as being derived from OTM animals. In such a case, examination of the incisor teeth would not be required.
Identification and marking of carcasses
The licence holder will apply following measures:
- the identification and marking of both sides of the carcasses of OTM animals must be done as soon as possible after the carcass has been aged. The licence holder will apply one of the marks described in Appendix D by means of a stamp (for example, using blue edible ink) to each side of the OTM carcass.
- the mark must be visible to the employee responsible for splitting carcasses in order to ensure the use of appropriate splitting saw. When a single saw is used for splitting all carcasses, it shall be cleaned and sanitized after splitting an OTM carcass if it is to be subsequently used to split a UTM carcass.
- control and identity of the carcass, head and parts must be maintained. The head is identified as OTM by means acceptable to the Veterinarian with supervisory authority.
- the licence holder must apply edible blue ink to exposed surfaces of the vertebral column of each OTM carcass side following removal of the spinal cord and before chilling. For proper identification the licence holder will apply edible blue ink to the vertebral canal and may include the vertebral body, however, the spinous (dorsal) processes should not be stained with ink as it compromises grading. All vertebrae including the sacrum will be stained with blue edible 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, occurs when the licence holder has a written program in place that can demonstrate ongoing effective controls, including a carcass identification and marking system that will ensure all OTM carcasses are properly identified and marked. The written program must be submitted to the Veterinarian with supervisory authority for examination prior to its implementation.
Licence holders of slaughter establishments may be able to employ other procedures providing the same outcome is achieved. For example, a licence holder 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 and there would be no need to examine incisor teeth for the purpose of age determination. However there would still be a requirement to apply one of the marks described in Appendix D by means of a stamp to each carcass side if the licence holder also slaughters UTM. Every vertebral column of OTM carcasses must be marked and stained as per the above procedures.
2.2 Control and segregation of carcasses during dressing, chilling, cutting and boning procedures
Licence holders that slaughter UTM and OTM cattle will ensure that OTM animals are slaughtered as a definable group. The CFIA strongly recommends that the slaughter of the OTM group(s) proceed at the end of the production day, in order to facilitate operational control and verification of SRM removal. If a licence holder chooses to slaughter and segregate OTM cattle using alternative methodology, a written control program, that is able to achieve the same outcome, must be prepared and be submitted to the CFIA for examination. This must be reviewed and found acceptable to the Veterinarian with supervisory authority prior to implementation. The licence holder is responsible to ensure that the proposed segregation method meets all the eligible exporting requirements.
However, licence holders of all federal slaughter establishments will visibly group the carcasses of OTM cattle in the cooler and schedule the cutting/deboning of such carcasses at the end of the production day. Alternatively, a licence holder of a federal establishment could ship the carcasses to another federal establishment for cutting/deboning.
Licence holders of slaughter establishments will track the number of OTM cattle slaughtered in the establishment. The number of OTM cattle will be recorded after CFIA examination of the head is complete and 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.
Licence holders of cutting/deboning establishments that receive sides and/or quarters of OTM cattle must develop and implement a control program to maintain the identity of these products until the vertebral column is removed and disposed as SRM. The procedures include:
- recording of the number of OTM carcasses/sides/quarters received and reconciliation of this number with the number of OTM carcasses deboned and cut-up;
- cutting/deboning of such carcasses/sides/quarters at the end of the production day.
For domestic purposes it is not required to segregate meat by age category when boning of the vertebral column has been completed.
3.0 Stunning, dressing, boning and SRM removal
3.1 Dedicated SRM tools
The licence holder must use, except as detailed later in the following section of this guidance, 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 tissues designated as SRM.
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 (that is, non-ambulatory and compromised animals discarded as inedible), the use of such methods may be tolerated provided that the licence holder has in place a control program ensuring that OTM carcasses are entirely handled as SRM. Such a control program may include, for example, a marking procedure additional to the usual denaturation policy and/or letter of guarantee from the rendering/salvaging establishment. The outcome is to demonstrate that the licence holder 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 material can be harvested as pet food or removed to the prohibited material stream from these carcasses. Once exposed to such methods, all tissues derived from any OTM carcass are considered SRM.
The licence holder must develop, implement and maintain an effective control system to collect brain tissue that has been externalized at the time of stunning prior to bleeding of OTM cattle or from all animals if UTM and OTM cattle are not identified before stunning. This control system must include measures to ensure brain matter does not enter or contaminate meat products, animal food products (for example, hides saved for gelatin or collagen, blood salvaged for edible and/or animal food including blood meal that can be used as feed for calves).
Brain tissue that has fallen on the floor must be discarded as SRM.
When OTM cattle are stunned by penetrative captive bolt, there is a strong likelihood that blood may be contaminated with SRM (neural tissue). The following methods are approved 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 a OTM animal (zero tolerance)
- humane stunning using a non-penetrative method (for example, electrical kill stunning, ritual slaughter without stunning, etc.)
- closed blood collection method (for example, hollow knife or cannula);
- or any other method that is approved by the CFIA. The licence holder must develop control measures for the prevention of cross-contamination of the blood during the slaughter process and have a CFIA approved written protocol. For more information on blood collection during slaughter refer to enhanced animal health safeguards at Blood collection during slaughter.
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. For more information on prevention of cross-contamination from incidental stunning of OTM cattle, refer to enhanced animal health safeguards at Incidental OTM cattle stunning and contamination with specified risk material (SRM) in slaughter of UTM cattle.
Refer to the tables below for disposition of face plates, that is, head hides from bovines. The licence holder must develop and maintain specific control program for this purpose.
|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.|
|2A||OTM animals stunned by a non-penetrating stunning device (for example, electrical kill stunning, ritual slaughter without stunning, etc.)||Routine (non-SRM) inedible stream unless cross-contamination with brain material or any other SRM from OTM animals takes place.|
|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.|
|2C||That are not processed as per options 2A or 2B||SRM|
Additional CFIA guidance on prevention of contamination of food, animal feed, pet food and fertilizer with SRM are available at:
Sector-Specific Guidance: Abattoirs
3.3 Head separation and removal of skull, brain, trigeminal ganglia, eyes and tonsils
Cattle age should be determined prior to removing the head from the carcass. If this is not possible due to plant design, the head removal process is performed by using a knife not dedicated for SRM to cut most of the muscles and connective tissue 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 knife dedicated, uniquely identified (that is, colour coded) for SRM removal is used to sever the spinal cord and is rinsed and sanitized after each animal. A non-dedicated knife is then used to complete the removal of the head. Both knives are adequately rinsed and sanitized after each animal.
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 (that is, spinal cord, brain) or other contaminants. The licence holder must take measures to prevent the contamination of edible products (head meat and tongues for example) by SRM.
As soon as the inspection of the head is completed and 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.
3.4 Palatine tonsils
Palatine tonsils are removed from the head of all cattle during the preparation of the head for inspection. Palatine tonsils are considered inedible material for cattle of all ages, and SRM for OTM cattle.
3.5 Tongue and cheek meat
The removal of the tongue, cheek meat and other edible portions must be achieved without contamination of the carcass and other edible meat products with SRM (that is, spinal cord, brain) or other contaminants.
3.6 Removal of the distal ileum
The distal ileum of all cattle, regardless of their age, is designated as SRM. Therefore, the distal ileum must be removed and disposed of as SRM in accordance with this guidance. The licence holder complies with this requirement by choosing one of the following two options:
- removal and disposal of all cattle small intestines with the ileo-cecal junction as SRM; or
- removal of the distal ileum from the small intestine and disposes of the removed distal ileum as SRM. To ensure the complete removal of the distal ileum, the ileo-cecal junction and at least 200 cm of the attached and uncoiled small intestine proximal to the ileo-cecal junction must be removed (see Appendix C of this guidance for a diagram of the cattle gastrointestinal tract). After the removal of the distal ileum, the remainder of the small intestines from cattle of all ages can be harvested as edible meat products, provided the intestines were found free of pathological defects, and are from carcasses approved for human consumption.
Under this option, the licence holder must develop, implement and maintain a control program within their PCP (for example, HACCP system) that ensures that the entire distal ileum is removed according to the specifications stated above. The program includes a description of the landmarks, procedures and equipment used to define and measure the distal ileum to be removed. In place of a measuring device, an alternate piece of equipment that consistently provides the same outcome is acceptable. Prior to its implementation, the control program must be reviewed and found acceptable to the veterinarian with supervisory authority.
The licence holder must also ensure 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 control program in place that identifies the landmarks for the portion being salvaged. See Appendix C of this guidance.
3.7 Carcass splitting
For the carcass splitting saw the licence holder 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 (that is, the organic material must be removed to ensure adequate sanitation). A device (for example, catch tray/ screen) must be installed to capture SRM fragments in areas where potential for SRM cross contamination exists.
The carcass splitting saw should separate the vertebral column in the midline to facilitate removal of the spinal cord. If the 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. The trap should be emptied, cleaned and renewed as and when necessary. All residues should be treated as SRM and emptied into a SRM container.
The licence holder shall immediately identify any incorrectly split carcasses and ensure that the spinal cord is properly removed in the evisceration area. Incorrectly split carcasses will not be approved by CFIA until the spinal cord is properly removed. The licence holder must take appropriate corrective measures to prevent the occurrence of incorrectly split carcasses.
3.8 Removal of the spinal cord and its verification
The spinal cord of OTM cattle is SRM. It must be removed in its entirety prior to stamping of the carcass sides with the meat inspection legend and before the carcass leaves the kill floor. Particular attention needs to be paid to the extremities of the vertebral canal, since it is usually in these areas that pieces of spinal cord are found. Lifting the spinal cord out of the vertebral canal can be achieved using a dedicated SRM knife. Other specialized tools can be used, but chain link gloves are not recommended unless covered with intact rubber/latex gloves to minimize the risk of gross cross-contamination.
The spinal cord of UTM cattle is not designated as SRM. It is not required to remove the spinal cord from UTM cattle carcasses. Nevertheless, it is strongly recommended to remove the spinal cord from all split carcasses on the kill floor before the final carcass wash as it is a practice recognized by the trading partners. This is further recommended to prevent incorporation of spinal cord tissue into any meat products, ensuring compliance with established meat product standards and simplifying verification measures.
Hand tools used for spinal cord removal should be uniquely identified (for example, colour coded) and dedicated to this purpose. Specialized spinal cord removal equipment, including vacuums can be used on all age categories of cattle. However, if used before final carcass inspection, specialized spinal cord removal equipment must be sanitized between each carcass. If used after carcasses have been approved, 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.
Licence holder verification of the complete spinal cord removal is one of the most important control points. The licence holder must make a thorough check of every carcass side to ensure that no remnants of spinal cord are present before the carcass is marked with the meat inspection legend. When any spinal cord remnant is discovered, the carcass must be retained for immediate rework by the licence holder (that is, zero tolerance policy applies).
In the case of carcasses that are split after chilling (veal carcasses), the spinal cord should be removed during boning/cutting operations if the vertebral column is split in a federally inspected establishment.
3.9 Removal of the dorsal root ganglia
It is the licence holder's responsibility to ensure SRM is not incorporated into any edible meat products. The dorsal root ganglia (DRG) from OTM carcasses must be removed and disposed of as SRM. The vertebral column removal will most likely be done in the cutting and boning room after carcass chilling. In order to ensure complete removal of DRG, the vertebral column of OTM cattle (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 and disposed of as SRM. Cutting and boning procedures used to remove the OTM vertebral column shall not cause the removal of DRG with the edible muscle tissue. As a best practice, the cut separating the edible muscle from the vertebral column should be made approximately 2.5 cm (1 inch) from the vertebral arch to ensure no DRG is inadvertently included with the edible meat.
OTM carcass sides or quarters with the vertebral column attached (that is, DRG not removed) can be shipped under CFIA permit from a federal slaughter establishment to another federal establishment if the following controls are in place.
Shipping OTM carcass sides or quarters with the vertebral column attached to non-federally inspected facilities is not permitted if there is intent to trade to another province or to export.
Slaughter establishments that do not remove DRG from vertebral columns on-site will have to implement identification and shipping control system satisfactory to the CFIA. The controls should include written confirmation that the receiving plant has a verifiable control system in place and an agreement and notification system regarding the number of carcasses sides or quarters to be expected exist between both establishments.
The receiving establishment must have a CFIA permit to receive carcasses containing SRM. The receiving establishment must have a verifiable control system in place which will demonstrate to the satisfaction of the CFIA that the sections of the vertebral column containing DRG are removed and appropriately disposed of as SRM. The receiving establishment must also advise the slaughter establishment of the number of OTM carcasses that they have received.
The vertebral column of OTM cattle must not be used as raw material in the preparation of mechanically separated meat or finely textured meat.
3.10 Verification by the licence holder of SRM removal and rework
The licence holder must verify the complete removal of all SRM. Any carcass or part that is found to be harbouring fragments of SRM (for example, spinal cord) must be retained by the licence holder for immediate rework and subsequent presentation for further examination by the licence holder. The licence holder 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 licence holder must demonstrate control of the system at all times.
4.0 SRM handling and disposition
This section describes effective separation of SRM from the carcass, provisions for storage of SRM and hygienic standards associated with floor waste and inedible containers. Because of structural differences between establishments, procedures for separating and isolating the various SRM may vary. Generally, separation of SRM should occur as soon as possible and care must be taken to avoid contamination of edible and inedible products and the establishment environment by SRM.
4.1 Handling of SRM within the establishment
SRM should be separated from carcasses at the earliest opportunity during the dressing process. SRM should be placed in dedicated containers without delay and regularly moved to a designated area in the inedible products section for SRM staining. This must include all SRM separated from the carcass, SRM from the floor and all others debris collected in the SRM areas. Basic principles of hygiene must be observed at all times.
4.2 Floor waste
Areas where SRM is removed or handled must be regularly attended to 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 daily.
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 licence holder should have a written program in place, to the satisfaction of the CFIA, to prevent the cross-contamination of floor from SRM tissues in these specific areas (see Floor waste and Wastewater materials).
4.3 SRM containers
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.
4.4 Cleaning of SRM containers
The licence holder ensures that:
- all equipment and containers used in the handling of SRM are cleaned and sanitized after being emptied and prior to reuse
- dedicated inedible and SRM containers are visibly clean at all times. If containers are being returned by a rendering company in an unclean state they are not be used until they are cleaned and sanitized
- cleaning of SRM containers does not occur in area where potential contamination of the meat products and non-SRM inedible may occur. The cleaning and sanitizing of SRM containers is an integral part of the cleaning schedule of the premises, and verified during the pre-operational inspection
- dedicated inedible containers and equipment, such as chutes, augers etc, are cleaned and sanitized using a non-food chemical that is suitable for use following accidental contamination with SRM and prior to reuse
- blood and non-ruminant dedicated containers and equipment, if accidentally cross-contaminated with SRM are cleaned, and disinfected prior to reuse using a suitable priocidal chemical
5.0 SRM controls
The licence holder is responsible for the development, implementation, and maintenance of documented control programs that address all the components of this SRM guidance including ante mortem inspection, age determination, carcass identification and SRM removal. The control programs must ensure compliance with the relevant provisions of the Safe food for Canadian Regulations and the Health of Animals Regulations with respect to the control and disposition of bovine SRM and inedible material, including animals that are found dead on arrival or die of the causes other than the slaughter in the establishment. Licence holders are required to reassess, and if required modify, their PCP so that the food safety hazards of BSE are clearly stated and controlled.
The licence holder and all staff directly involved should have demonstrable knowledge of the establishment's SRM control programs and be able to demonstrate with accurate records that the SRM controls they have put in place have been implemented in practice, resulting in full compliance with the regulations and guidance. The licence holder's SRM control programs must be auditable and verifiable.
Part II: Enhanced feed ban controls and SRM management
The Canadian government implemented a ruminant to ruminant feed ban in 1997 to limit the spread of BSE. That feed ban prohibited the feeding of most mammalian proteins to ruminant animals, such as cattle, sheep and goats. Control measures related to the enhanced feed ban control regulations that came into effect on July 12, 2007 prevent accidental exposure of susceptible animals to BSE and accelerate the time for the eradication of BSE from the national cattle herd. The enhanced feed ban controls require the removal and redirection of all SRM tissues from animal feed, pet food and fertilizers, as are removed from human food (Part I of this guidance). To effectively implement these controls, all SRM be segregated from other edible and inedible materials, identified by staining; and handled appropriately until disposal.
In every establishment where SRM is handled, the licence holder will implement the practices described in Part II of this guidance, as required.
The enhanced feed ban regulations came into effect on July 12, 2007. The guidance is designed to ensure removal of all SRM from the animal food chain in a manner that minimizes risks associated with:
- potential adulteration or cross-contamination of ruminant animal feed with prohibited proteins of ruminant origin; and
- potential on-farm misuse of feed containing prohibited protein of ruminant origin.
6.2 Control programs
The licence holder is responsible for the development, implementation, and maintenance of control programs that address all components of this enhanced feed ban control guidance. These control programs are to be reviewed and approved by the Veterinarian with supervisory authority (or IIC as is appropriate) and their implementation must demonstrate ongoing and effective controls over SRM segregation, staining, shipping/ transportation, record keeping and compliance with the CFIA permitting process.
7.0 Collection, segregation and staining of SRM
7.1 Specified Risk Materials (SRM)
Licence holders involved in the slaughter of cattle and/or the cutting/boning of bovine carcasses/quarters shall collect and dispose of the following materials as SRM.
SRM removed from cattle carcasses
This includes SRM tissues removed from cattle carcasses during slaughter, dressing or cutting/ deboning operations (Part I of this guidance).
Animals condemned at ante mortem, post mortem, deadstock and bovine fetuses
The licence holder ensures the following controls are in place:
- animals condemned at ante mortem and cattle that die from causes other than slaughter are handled as SRM, unless the SRM has been removed from these carcasses.
- immediate and direct conveyance of the dead stock to a designated area in the inedible product section for staining and disposal in accordance with the Health of Animals Regulations (see section 7.3).
- carcasses of condemned or dead animals from which the SRM has not been removed are denatured by staining with a wide stripe from head to tail (contrasting with the animal's coat colour) before shipping to another location under CFIA permit (see section 7.3).
- deadstock collected by companies solely dedicated to SRM (all trucks, all equipment, entire premises) may mark a lesser amount of the deadstock carcasses (for example, just the head). Denaturation of such carcasses by injecting a suitable agent is optional
- the bovine carcasses condemned at post mortem inspection must be treated as SRM unless they have had all the SRM removed. Once SRM has been removed, the rest of the carcass can be disposed of according to Section 155 of the SFCR
- an unborn fetus/calf recovered from the uterus of a cow slaughtered in a federal establishment is non-SRM. Any term-fetus with body hair or newborn calf that is found on the ground in side the establishment is SRM, unless the distal ileum has been removed from such animals.
The licence holder ensures that the following controls are in place for management of floor waste:
- in beef slaughter establishments, the floor waste from areas where SRM is removed or handled will be considered SRM. When there are no effective controls to contain the floor waste generated from areas where SRM is removed or handled, 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
- 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 licence holders should have a written program in place, to the satisfaction of the Veterinarian with supervisory authority, 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 (slaughter establishments) and the OTM vertebral columns (cutting and boning rooms) are removed because the SRM is effectively contained within these tissues. However, the licence holders should have a written program in place, to the satisfaction of the Veterinarian with supervisory authority, to limit the cross-contamination of floor from SRM tissues in these areas
The licence holder ensures that the following controls are in place for management of wastewater materials:
- in beef slaughter establishments, the animal material and debris recovered from wastewater must be disposed of as SRM if there are no controls in place to protect the floor from SRM contamination in areas where SRM is handled or removed. To retrieve this material, a screening system consisting of screens with apertures or a mesh size of no more than 4 mm diameter is in place as a step in the treatment of wastewater
- all animal materials and debris retained in this screening system is collected and disposed of as SRM
- no grinding or maceration shall take place which could facilitate the passage of animal material through the pre-treatment process. The wastewater beyond this screening system will not be subjected to CFIA's SRM controls but shall be treated in accordance with relevant provincial, municipal or environment legislations.
- animal material and debris recovered from wastewater screening systems and/or any downstream treatment system, will not need to be treated as SRM if, there are effective controls in place to prevent the wastewater and floor debris from becoming contaminated in areas where SRM is handled or removed
- the licence holder must be able to demonstrate that materials and debris recovered originated from a non-SRM or SRM controlled area and/or that SRM effluent originating from an SRM area has been treated by passing through a screening system consisting of screens with apertures or mesh size of no more than 4 mm diameter
- licence holders who wish to exempt the materials and debris recovered from the wastewater derived from the slaughter floor as SRM must have written program in place to the satisfaction of the veterinarian with supervisory authority.
7.2 SRM containers
SRM must be collected and placed in dedicated leak proof SRM containers without delay and regularly moved to a designated area in the inedible products section for staining. The SRM containers must be clearly and indelibly marked on the outside with the words "Specified Risk Material / Matériel à risque spécifié" or "SRM / MRS" in both the official languages.
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.
7.3 Segregation and staining of SRM
The licence holder 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 approved by the CFIA (for example, denaturing agent). Carcasses containing SRM (that is, vertebral columns of OTM carcasses containing DRG) must also be conspicuously stained with an indelible marking dye approved by the CFIA (that is, blue meat marking ink).
The stain should be applied to each layer of SRM so that the stain is visible on all surfaces that is, every time the SRM is transferred to a common SRM staining container or trailer, it has to be stained by spraying. A list of denaturing agents and dyes that have been historically considered suitable for use can be obtained from the Health Canada's reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products Database.
The licence holder develops, implements and maintains control programs with the following measures:
- segregating and staining of SRM in dedicated SRM containers following its removal from cattle carcasses.
- if the licence holder 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 parts of cattle carcasses do not leave the premises (on-site disposal).
- marking carcasses of condemned or dead animals from which the SRM has not been removed 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. Deadstock being collected by companies solely dedicated to SRM (all trucks, all equipment, entire premises) may mark a lesser amount of the deadstock carcasses (for example, just the head). This would not apply if the carcasses do not leave the premises (on-site disposal).
8.0 Shipping of SRM from the establishment
8.1 Shipping of SRM from the inedible are of the establishment
The Health of Animal Regulations require that no person shall transport SRM to another premise unless it is stained in accordance with the provisions of the Acts and Regulations and it is in a container marked on the outside with the words "Specified Risk Material / Matériel à risque spécifié" or "SRM / MRS" in both official languages.
Licence holders of cattle slaughter and/or cutting/deboning establishments must collect SRM in dedicated leak proof containers (see section 7.0). Only properly identified and stained SRM can be shipped from federal establishments. The licence holder and SRM transporter must maintain records for SRM shipped from the establishment in accordance with section 9 of this guidance.
All SRM, if moving from the premises of origin to another location, in any form with the sole exception being laboratory submissions (level 2 or higher laboratory), must be transported under a CFIA permit. The licence holder of the shipping establishment must develop, implement and maintain a control program that ensures only transport vehicles with a valid CFIA permit are used to remove SRM from the establishment. The responsible CFIA Inspector will verify the licence holders control program.
8.2 Shipping of OTM carcasses containing DRG
Slaughter establishments that do not remove vertebral columns containing DRG from OTM carcasses on-site have to implement identification, segregation and shipping controls satisfactory to the CFIA (see part 2.2 and part 3.9 of this guidance). The licence holder of a slaughter/ shipping establishment must keep daily records that contain the information stated in section 9 of this guidance.
OTM carcass transporters
All SRM, if moving from the premises of origin to another location, in any form with the sole exception being laboratory submissions (level 2 or higher laboratory), must be transported under a CFIA permit. Licence holders and owners of companies or vehicles who wish to transport OTM carcasses should contact the Veterinarian with supervisory responsibilities/Inspector In-Charge of the establishment or the local CFIA Animal Health District Office for permit application information. Transportation of the SRM must be done in accordance with the conditions of the permit. The transporter will keep records in accordance with the issuance of the permit, the Health of Animals Regulations and section 9 of this guidance. The vehicle/trailer transporting OTM carcasses must be cleaned prior to reloading in accordance with the licence holders written program.
The receiving establishment must have a CFIA permit to receive carcasses containing SRM. Licence holders who wish to receive SRM must submit a permit application to the Veterinarian with supervisory responsibilities/Inspector In-Charge of the establishment or local CFIA Animal Health District Office. The application includes written procedures documenting design and operating parameters for the site/facility. The receiving establishment must have a verifiable control system in place (see section 2.2 and section 3.9). The receiving establishments must keep records that contain the information stated in section 9 of this guidance.
8.3 On-site disposal
Inquiries regarding the acceptability of an on-site disposal method should be directed to local CFIA Animal Health District Office. When SRM is treated, confined, or destroyed on-site, the licence holder will keep daily records that include the name and address, date of slaughter and SRM removal, the combined weight of SRM or the number of carcasses (if applicable), the number of the approved tags (CCIA, Lactanet, Attestra etc.) and the date on which and the manner in which the SRM or the carcasses were treated, confined or destroyed (refer to section 9 of this guidance).
9.0 Record keeping
SRM records required by the Health of Animals Regulations
Section 6.23(1-2) of the Health of Animals Regulations requires that SRM records be maintained for at least 10 years by every person who:
- is required to remove or stain SRM;
- collects the carcasses of cattle containing SRM that died or were condemned at the ante mortem; or
- receives SRM or carcasses containing SRM from another person.
In addition to the requirements of this section, the licence holders will maintain additional SRM records as indicated earlier in this guidance.
The licence holder of an establishment that removes (at pre-slaughter, slaughter or OTM deboning), stains, ships, transfers or receives SRM (including meat products containing SRM) shall keep a record for each day on which the SRM is removed, stained or received or the carcasses containing SRM are collected or received. The licence holder must maintain records for 10 years that contain the following information where applicable:
- the name of the licence holder and address of the establishment
- the date of SRM removal, staining, shipping, transporting or receiving
- the weight of the SRM, as well as the number of carcasses if applicable, that is shipped; transported or received
- the number of deadstock and animals condemned at ante mortem
- the name of the dye used to identify the SRM or carcasses
- from deadstock containing SRM, the approved ear tag number (CCIA, Lactanet, Attestra) as defined in section 172 of the Health of Animals Regulations; or the information referred to in the paragraph 187(2)(a)
- the name and address of the person, company or establishment that transports the SRM or carcasses containing SRM from the establishments or to the establishment
- the name and address of the person or company that received or will receive the SRM (renderers, deadstock collectors, OTM receiving establishments, etc.)
10.0 Compliance and verification
Licence holders responsibilities
The licence holder will develop, implement, and maintain documented control programs that address all components of regulations and associated guidance including SRM collection, segregation and staining, shipping/ transportation, record keeping and compliance with CFIA permitting process.
The control programs must ensure compliance with the relevant provisions of the Safe food for Canadian regulations and the Health of Animals Regulations with respect to the control and disposition of bovine SRM and inedible material, including animals that are found dead on arrival or die of the causes other than the slaughter in the establishment. The licence holders SRM control programs must be auditable and verifiable to the satisfaction of the CFIA officials.
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