Appendix 4 – Specified risk material at slaughter PCI operational guidance

Note

In order to demonstrate compliance with Safe Food for Canadians Regulations (SFCR), operator/licence holders could follow the interpretive guidelines and industry guidance. This guidance document summarizes the expected performance criteria available in slaughter interpretive guidelines and industry guidance.

If the operator/licence holder does not follow the Canadian Food Inspection Agency (CFIA) guidance mentioned below and presents a different means of meeting SFCR requirements, the inspection team should consult with CFIA specialists to verify the validity of the approach.

As per SFCR 47, all licence holders are required to identify and analyse hazards and prevent, eliminate or reduce the identified hazards to an acceptable level using control measures shown by evidence to be effective.

Under SFCR, licence holders who slaughters animals are required to prepare, keep and maintain a written Preventive Control Program (PCP).

Pursuant to SFCR, specified risk material (SRM) has the same meaning as in section 6.1 of the Health of Animals Regulations.

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 (HAR) and Food and Drug Regulations (FDR).

The purpose of this document is to provide guidance to CFIA inspection staff on Preventive Control Inspection (PCI) procedures related to verifying that the operator/licence holder meets the regulatory requirements related to SRM controls at federal meat establishments.

PCI for sub-element 1.1bc: Product formulation, specifications and processing
PCI for sub-element 1.2: Product controls
- Stunning
PCI for sub-element 2.1: Sanitation, biosecurity and biocontainment
PCI for sub-element 5.4: Waste disposal
PCI for sub-element 6.1: Receiving, transportation and storage
- Receiving establishments
PCI for sub-element 7.1: Traceability and recalls
- Shipping of SRM from the establishment
- Record keeping

Table 1: Recording inspection data in Digital Service Delivery Platform (DSDP)
Inspection trigger	Choose appropriate selection from the following: Preventive Control Inspection plan Incident response
Business line	Food
Program	Meat hygiene
Commodity group	Leave it blank
Commodity sub-group	Leave it blank
Commodity type	Leave it blank
Product	Leave it blank
Inspection case	Preventive Control Inspection plan
Task type	Preventive Control Inspections
Inspection task level 1	Compliance Verification of a System
Inspection task level 2	Choose appropriate sub-element from the following: 1.1bc: Product formulation, specifications and processing 1.2: Product controls 2.1: Sanitation, biosecurity and biocontainment 5.4: Waste disposal 6.1: Receiving, transportation and storage 7.1: Traceability and recalls
Inspection task details	Leave it blank

PCI for sub-element 1.1bc: Product formulation, specifications and processing

Legal authorities

HAR 6.2, 6.21, 6.22; SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155

Reference documents

In addition, the processes meet the following criteria:

Preventive Control Plans

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.

Licence holders slaughtering or cutting/deboning Under Thirty Month (UTM) and cattle that are Thirty Months of age or Older (OTM) must develop and implement:

controls for age determination using 1 of the following:
- determining age by birth date documentation:
  - if age is determined by documentation, the document is to be maintained with the records for a period of 2 years from the date of slaughter
- determining age by dentition examination when no birth date documentation is provided
controls for identification and marking of carcasses:
- licence holders slaughtering or cutting/deboning cattle that are under 30 months of age (UTM) and cattle that are 30 months of age or older (OTM) must develop and implement procedures for identifying and separating these 2 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 cattle carcasses and all their parts must be maintained until their final disposition is known
- the Canadian Cattle Identification Agency (CCIA) and Agri-Traçabilité Québec (ATQ) ear tag will be attached, after its insertion into a plastic bag, to the fore shank of the carcass following hide removal
- 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 or
- a licence holder may decide to treat all slaughtered cattle, or cattle slaughtered from a particular lot, as being derived from OTM animals
For detail please refer to Industry Guidance – Guidance on Specified Risk Material (SRM).

Control and segregation of carcasses during dressing, chilling, cutting and boning procedures

Slaughter establishments:

licence holders that slaughter UTM and OTM cattle will ensure that OTM animals are slaughtered as a definable group
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
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
when OTM cattle are stunned by penetrative captive bolt, there are methods to prevent SRM-contamination of bovine blood that may be used in feeds and food for animals
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
the licence holder must develop and maintain specific control program for disposition of face plates

Cutting/deboning establishments:

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
for domestic purposes it is not required to segregate meat by age category when boning of the vertebral column has been completed

Head separation and removal of skull, brain, trigeminal ganglia, eyes and tonsils:

controls are in place, if cattle age is not determined prior to head removal
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
boning of the occipital area of the head including the area of the foramen magnum of OTM cattle is not permitted

Palatine tonsils:

are considered inedible material for cattle of all ages, and SRM for OTM cattle

Tongue and cheek meat:

removal must be achieved without contamination of the carcass and other edible meat products with SRM

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 by either:

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

If the large intestine is salvaged, there must be a control program in place that identifies the landmarks for the portion being salvaged.

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:

lifting the spinal cord out of the vertebral canal can be achieved using a dedicated SRM knife
use of chain link gloves is not recommended unless covered with intact rubber/latex gloves to minimize the risk of gross cross-contamination
hand tools used for spinal cord removal should be uniquely identified (for example, colour coded) and dedicated to this purpose

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. See Appendix B of Industry Guidance – Guidance on Specified Risk Material (SRM) for diagrams of cattle vertebral column.

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:
- 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

Slaughter/shipping establishments:

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

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

Verification activities

Refer to the 'Verification activities' section in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.1bc – Process Controls.

Document/records review

Refer to the 'Document/record review' section in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.1bc – Process Controls.

On-site: observation and interview

Refer to the 'On-site: observation and interview' section in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.1bc – Process Controls.

PCI for sub-element 1.2 – Product controls

Legal authorities

HAR 6.2, 6.21, 6.22; SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155

Reference documents

Outcome

Refer to the section 'Outcome' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.2 – Product Controls.

Rationale

Refer to the section 'Rationale' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.2 – Product Controls.

Performance criteria

In addition, the processes meet the following criteria:

Stunning:

licence holder can demonstrate that the licence holder can clearly segregate any OTM carcasses that have been exposed to the use of a penetrating percussion device which injects air into the cranial cavity or the use of pithing rods 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
the vertebral column of OTM cattle must not be used as raw material in the preparation of mechanically separated meat or finely textured meat

Verification activities

Document/records review

Refer to the 'Document/record review' section, 'End product specification', in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.2: Product controls.

On-site: observation and interview

Refer to the 'On-site: observation and interview' section 'End product specification', in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 1.2: Product controls.

PCI for sub-element 2.1 – Sanitation, biosecurity and bio-containment

Legal authorities

HAR 6.2, 6.21, 6.22; SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155

Reference documents

Outcome

Refer to the section 'Outcome' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 2.1 – Sanitation, biosecurity and bio-containment.

Rationale

Refer to the section 'Rationale' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 2.1 – Sanitation, biosecurity and bio-containment.

Performance criteria

In addition, the processes meet the following criteria:

Dedicated SRM tools:

required for all procedures involving the incision and direct or indirect handling of tissues designated as SRM

Carcass splitting

licence holders have the option to either 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.

Potential SRM cross contamination of both edible and inedible products must be avoided:

the carcass splitting saw should separate the vertebral column in the midline to facilitate removal of the spinal cord
the licence holder shall immediately identify any incorrectly split carcasses and ensure that the spinal cord is properly removed in the evisceration area
the licence holder must take appropriate corrective measures to prevent the occurrence of incorrectly split carcasses

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

Verification activities

Document/records review

On-site: observation and interview

PCI for sub-element 5.4: Waste disposal

Legal authorities

HAR 6.2, 6.21, 6.22; SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155

Reference documents

Outcome

Refer to the section 'Outcome' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 5.4: Waste disposal.

Rationale

Refer to the section 'Rationale' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 5.4: Waste disposal.

Performance criteria

Processes have:

Refer to the section 'Performance criteria' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 5.4: Waste disposal.

In addition, the processes meet the following criteria:

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

Floor waste:

areas where SRM is removed or handled must be regularly attended to by plant employees assigned this function
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:
- the licence holder should have a written program in place, to the satisfaction of the CFIA (to the satisfaction of the Veterinarian with supervisory authority with consultation of the Regional Veterinary Officer), to prevent the cross-contamination of floor from SRM tissues in these specific areas (see Floor waste and Wastewater materials of Industry Guidance – Guidance on Specified Risk Material (SRM))

Collection, segregation and staining of 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
animals condemned at ante mortem, post mortem, deadstock and bovine fetuses:
- 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 of Industry Guidance – Guidance on Specified Risk Material (SRM))
- 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 of Industry Guidance – Guidance on Specified Risk Material (SRM))
- 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
- 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
floor waste:
- 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 (with consultation of the Area and Regional Veterinary Officers), to limit the cross-contamination of floor from SRM tissues in these areas
wastewater materials:
- 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 (with consultation of the Area and the Regional Veterinary Officers)

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

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)
- 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
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 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)

Verification activities

Refer to the 'Verification activities' section in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 5.4: Waste disposal.

Document/records review

Refer to the 'Document/record review' section in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 5.4: Waste disposal.

On-site: observation and interview

PCI for sub-element 6.1 – Receiving, transportation and storage

Legal authorities

HAR 6.2, 6.21, 6.22; SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155

Reference documents

Outcome

Refer to the section 'Outcome' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 6.1 – Receiving, transportation and storage.

Rationale

Refer to the section 'Rationale' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 6.1 – Receiving, transportation and storage.

Performance criteria

In addition, the processes meet the following criteria:

Receiving establishments:

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 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 receiving establishments must keep records that contain the information stated in section 9 of Industry Guidance – Guidance on Specified Risk Material (SRM)

Verification activities

Document/records review

On-site: observation and interview

PCI for sub-element 7.1: Traceability and control

Legal authorities

HAR 6.2, 6.21, 6.22; SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155

Reference documents

Outcome

Refer to the section 'Outcome' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 7.1: Traceability and control.

Rationale

Refer to the section 'Rationale' in Operational guideline: Food preventive control and traceability inspection – Compliance verification of a system: Sub-element 7.1: Traceability and control

Performance criteria

In addition, the processes meet the following criteria:

Shipping of SRM from the establishment

Shipping of SRM from the inedible area 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 of Industry Guidance – Guidance on Specified Risk Material (SRM)):
- 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 Industry Guidance – Guidance on Specified Risk Material (SRM)
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
the licence holder of a slaughter/shipping establishment must keep daily records that contain the information stated in section 9 of Industry Guidance – Guidance on Specified Risk Material (SRM)

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 Industry Guidance – Guidance on Specified Risk Material (SRM)
the vehicle/trailer transporting OTM carcasses must be cleaned prior to reloading in accordance with the licence holders written program

On-site disposal:

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, ATQ 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 Industry Guidance – Guidance on Specified Risk Material (SRM))

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 or ATQ) 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; and
- the name and address of the person or company that received or will receive the SRM (renderers, deadstock collectors, OTM receiving establishments, etc.)