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Microbial controls for meat products and food animals

Requirements for the Safe Food for Canadians Regulations

Although the Safe Food for Canadians Regulations (SFCR) came into force on January 15, 2019, certain requirements may apply in 2020 and 2021 based on food commodity, type of activity and business size. For more information, refer to the SFCR timelines.

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Introduction

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

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

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

Examples of microbial monitoring programs

General principles for the use of acceptable microbial control interventions

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

Chemical microbial interventions: food processing aids and preservative food additives

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

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

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

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

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

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

Non chemical microbial control interventions

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

Steam or hot water vacuuming for red meat carcasses

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

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

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

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

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