Appendix 4 – SRM Slaughter and Meat Processing PCI Implementation Verification Tasks

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 for PCP implementation related to Specified Risk Material (SRM) removal, handling and disposal.

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 interpretive guidelines and industry guidance.

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

Under SFCR, licence holders who slaughter animals and process meat are required to prepare, keep and maintain a written Preventive Control Program (PCP), and as per SFCR section 88, any person who is required to prepare, keep and maintain a PCP must implement that plan.

On this page

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 Implementation Verification
Inspection task level 2
  • Choose appropriate task from the following:
    • SRM On-site Verification
    • SRM Records Verification
    • USA SRM On-site Verification
    • USA SRM Records Verification
    • Export BSE Requirements
Inspection task details
  • Choose 1 or more applicable description for the following "Inspection task level 2", based on the scope of verification activity, and write it in the "Inspection task details" box:
    • SRM On-site Verification
      Slaughter establishment; Processing only establishment
    • SRM Records Verification
      Slaughter establishment; Processing only establishment
    • USA SRM On-site Verification
      Slaughter establishment; Processing only establishment
    • USA SRM Records Verification
      Slaughter establishment; Processing only establishment
    • Export BSE Requirements
      Slaughter establishment; Processing only establishment

SRM On-Site Verification

Legal authorities

SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155(3)

Reference documents

Outcome

Operator/licence holder meets the regulatory requirements related to the removal and control of Specified Risk Material (SRM).

Rationale

Inadequate process control measures could lead to a risk of SRM contamination of food and products that do not meet commodity specific requirements.

Performance criteria

Slaughter with or without processing

Performance criteria for SRM controls are as follows:

  • age determination, identification and marking of carcasses:
    • determining the age of each animal by examination of birth documentation or examination of dentition
    • correct identification of cattle and/or carcasses as UTM (under thirty months) or OTM (over thirty months)
      • OTM cattle may also be a mixed lot deemed to be OTM by the operator
    • application of OTM identification marking (blue "3" or 3-triangled) on both sides of OTM carcasses
    • application of edible blue ink to exposed surface of the OTM vertebral column following removal of spinal cord and before chilling
  • SRM removal:
    • removal of entire spinal cord prior to stamping of carcass sides with Inspection Legend
    • vertebral column from OTM carcasses (dorsal root ganglia intact) are removed and disposed of as SRM (if the slaughter establishment conducts cutting and boning activities)
  • waste and inedible disposal:
    • utensils/tools and containers provided for SRM material are dedicated for the use of SRM and are marked with the words "Specified Risk Material" or "SRM/MRS" in both official languages
    • SRM material is removed frequently into a designated area in an inedible section of the establishment
    • slaughter room floor waste containing SRM, including solids recovered from the waste water, is treated as SRM
    • removal and disposal of the entire small intestine or the distal ileum as SRM (includes the ileocecal junction and at least 200 cm proximal from the ileocecal junction)
    • in the absence of proper work technique to remove SRM contamination, OTM face plates are disposed as SRM
    • in the absence of proper controls at stunning, non-edible blood is treated as SRM
    • following stunning of incidental OTM animal, the next adjacent 2 UTM carcass heads are treated as SRM at time of disposal
      • unless the operator has an alternative procedure that has been reviewed and accepted by the CFIA national specialists
        • in this case, verify that the procedure is implemented as per the written program
    • dead or condemned cattle carcasses (including term fetus and new born calf on the ground) are moved to a designated SRM inedible area and are treated as SRM unless the SRM has been removed from the carcasses
    • SRM waste is stored in SRM containers and stained with indelible marking dye as per written procedures
  • equipment:
    • protective measures are in place to prevent equipment used for SRM contaminating non-SRM meat products (for example split saw)
    • stunning equipment used is acceptable (that is no injection of air, no usage of pitting rod)
    • equipment/tools dedicated for the use of SRM are identified
  • good manufacturing and hygiene practices:
    • operational slaughters of known OTM animals at the end of the day's kill
      • Unless the operator has an alternative plan that has been reviewed and accepted by the veterinarian with supervisory authority
        • in this case, verify that the procedure is implemented as per the written program
    • proper flow of product and people to prevent SRM contamination of meat products
    • where the establishment salvages intestines for edible purposes, adequate removal and disposal of the distal ileum as SRM
      • includes the ileocecal junction and at least 200 cm proximal from the ileocecal junction
    • prior to boning, OTM carcasses are segregated in the cooler of the establishment
      • only if carcasses are boned
    • deboning of OTM carcasses at the end of fabrication work day (after the deboning of UTM carcasses and prior to full sanitation)
    • proper use of equipment for OTM and UTM (that is dedicated tools or proper sanitation before being used on UTM carcasses) such as: 
      • an acceptable split saw, vacuum, knife, etc.
      • acceptable stunning procedures
      • adequate plugging of OTM stun hole with CFIA approved methods to prevent SRM contamination of blood
    • proper work technique (trimming, washing, scraping and/or vacuuming) for removal of grossly visible brain material from OTM face plate (head hide)
    • following stunning of incidental OTM animal, proper management of the next adjacent 2 UTM carcass heads to mitigate the risk that inedible by-products be contaminated with SRM
      • if the operator has an alternative procedure related to the stunning of incidental OTM animal that has been reviewed and accepted by the CFIA national headquarters, verify that the procedure is implemented as per the written program 
  • receiving:
    • when/if OTM carcasses containing SRM (intact DRG (dorsal root ganglia) are received at the establishment, the vertebral column and OTM carcasses are appropriately marked
    • as applicable, the establishment has a valid CFIA permit to receive carcasses containing SRM

Stand-alone processing

This task applies only to stand-alone processing establishments that receive OTM cattle carcasses with vertebral column.

  • SRM removal and control:
    • when carcasses are received at the establishment, the vertebral column and carcasses are appropriately marked
    • when sides and/or quarters of OTM cattle are received, the identity of these products are maintained until the vertebral column is removed and disposed as SRM
    • vertebral column from OTM carcasses (containing dorsal root ganglia intact) are removed and treated as SRM
    • SRM waste is disposed of in an appropriate manner
    • prior to boning, OTM carcasses are segregated in the cooler of the establishment
    • OTM carcasses/sides/quarter are deboned at the end of the fabrication work day (that is, after the deboning of UTM carcasses and prior to full sanitation)
      • for domestic purposes it is not required to segregate meat by age category when boning of the vertebral column has been completed

Verification activities

For slaughter establishments, refer to Operational guidance - Food Animal Slaughter PCI Implementation Verification, Appendix 5 for guidance on the PCI tasks to be added to a weekly PCI case and how to manage weekly PCI cases when a non-compliance is observed while performing a PCI task.

When performing the SRM On-site Verification task:

Document/records review

  • not applicable

On-site: observation and interview

  • observe and interview where necessary to verify that the operator is meeting requirements related to age determination, identification and marking of carcasses
  • observe and interview where necessary to verify that the operator is meeting requirements related to SRM removal
  • observe and interview where necessary to verify that the operator is meeting requirements related to waste and inedible disposal
  • observe and interview where necessary to verify that the operator is meeting requirements related to equipment
  • observe and interview where necessary to verify that the operator is meeting requirements related to good manufacturing and hygiene practices
  • observe and interview where necessary to verify that the operator is meeting requirements related to receiving
  • when necessary, interview at least 1 person responsible for verification of implementation of the SRM controls process to determine if they understand and are following procedures as set out in licence holder's written PCP
  • when necessary, interview at least 1 person responsible for initiating actions to bring hazards back under control to determine if they understand and are following procedures as set out in licence holder's written PCP

SRM Records Verification

Legal authorities

SFCR 8, 15(c), 46, 47, 60, 61, 86, 88, 89, 125, 155(3)

Reference documents

Outcome

Operator/licence holder meets the regulatory requirements related to the removal and control of Specified Risk Material (SRM).

Rationale

Inadequate process control measures could lead to a risk of SRM contamination of food and products that do not meet commodity specific requirements.

Performance criteria

Performance criteria for SRM records verification is as follows:

Slaughter with or without boning and Stand Alone Processing

For stand-alone processing establishments, this task applies only when they receive OTM cattle carcasses with vertebral column.

  • the following information is recorded where applicable:
    • the name of the operator 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 cattle carcasses if applicable, that is transported or received
    • the number of dead stock or cattle condemned ante-mortem
    • the name of the dye used to identify the SRM or carcasses
    • from dead stock containing SRM, the number of the approved tags (CCIA (Canadian Cattle Identification Agency), Attestra and other approved groups) 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 (for example renderers, dead stock collectors, OTM carcass receiving establishment etc.)
    • reconciliation of OTM carcass numbers (that is, slaughter carcasses + received carcasses = cooler carcasses + shipped carcasses + deboned carcasses)
  • Regulatory requirements:
    • transport company has a valid CFIA permit for transporting SRM.
    • records for the identity of slaughtered cattle are maintained for a period of 2 years (if the operator chooses to use birth date documentation to determine the age of the animal)

Verification activities

For slaughter establishments, refer to Operational guidance - Food Animal Slaughter PCI Implementation Verification, Appendix 5 for guidance on the PCI tasks to be added to a weekly PCI case and how to manage weekly PCI cases when a non-compliance is observed while performing a PCI task.

When performing the SRM Records Verification task:

Document/records review

Each month, select at least 1 SRM control procedure implemented at the establishment such as age determination, identification and marking of carcasses; SRM removal; SRM disposal (waste and inedible disposal); good manufacturing and hygiene practices related to SRM; or receiving of OTM carcasses containing SRM. Review records that demonstrate control of the selected control procedure.

Note: selection of SRM control procedure for review should ensure that all control measures within the operator's SRM control program are reviewed at least once every 6 months.

  • review the verification records related to control of the selected control procedure
    verify that:
    • the verification records reflect non-compliant situations observed by CFIA
    • the verification frequency specified in the operator's written program is adhered to
    • the verification results are documented, including the recording of actual quantifiable values, when applicable
    • the verification records are completed using permanent ink
      • computerized records are permitted but access must be protected
    • the verification records are signed or initialed and include the date and exact time (for CCP (critical control points) and PC (process controls) an entry was made
  • review the corrective actions records related to control of the selected control procedure verify that:
    • corrective action procedures are implemented when the standards/critical limits are not met during monitoring
    • the following information is documented on corrective action records:
      • a description of the deviation and its cause when applicable
      • immediate actions taken to control affected or potentially affected product
      • corrective action(s) taken to restore control
      • monitoring of effectiveness of corrective action(s) taken
      • when applicable, measures taken to prevent reoccurrence of the deviation
    • the corrective action records are completed using permanent ink
      • computerized records are permitted but access must be protected
    • the corrective action records are signed or initialed and include the date and exact time (for CCP and PC) an entry was made
  • review the monitoring records (for CCP and PC) related to control of the selected control procedure
    Verify that:
    • monitoring frequency for record review, on-site reviews and other activities specified in the operator's written program is adhered to
    • monitoring identified when verification and corrective action procedures were not conducted according to the operator's written program or trends were identified that may lead towards loss of control
    • corrective action procedures were implemented when monitoring identified that verification and/or corrective action procedures were not conducted according to the operator's written program or trends were identified that may lead towards loss of control
    • the monitoring records are completed using permanent ink
      • computerized records are permitted but access must be protected
    • the monitoring records are signed or initialed and include the date and exact time an entry was made

On-site: observation and interview

  • Not applicable

USA SRM On-Site Verification

Legal authorities

SFCR 168

Reference documents

Outcome

Operator/licence holder meets requirements related to SRM removal and control for export of bison species to the USA,

Rationale

Inadequate process control measures could lead to a risk of SRM contamination of food and products that do not meet USA export requirements.

Performance criteria

Performance criteria for SRM controls are as follows:

Bison Slaughter

  • monitoring procedures for the slaughter and dressing of bison include (but may not be limited to):
    • frequency of monitoring
    • proper age determination of each animal by examination of birth documentation or by examination of dentition
    • identification of the bison or bison carcass is maintained as UTM or OTM until all SRM is removed
    • if blood is harvested for edible product to be shipped to the U.S.A., controls are in place to prevent the cross contamination of blood with any exteriorized brain material from OTM animals after knocking
    • proper identification of dedicated tools used for OTM and UTM
    • removal and segregation as "not eligible for export to the United States", the entire small intestine or the distal ileum from all ages as "not eligible for export to the United States" (only applicable to establishments that salvage intestines for edible purposes)
    • sanitizing the split saw used on an OTM carcass before using the saw on an UTM carcass
  • employees handling SRMs use hygienic practices to prevent cross contamination (for example if product falls on the floor, the contaminated surfaces are treated as inedible)
  • ensure all remnants of the spinal cord are removed before the inspection legend is applied
  • for OTM carcasses:
    • marking of OTM carcasses before the head is removed (except where the lot is deemed OTM or the plant is dedicated to the slaughter of OTM)
    • brain tissue externalized during stunning and any product contaminated with brain tissue is disposed of as inedible
    • skull including the brain, trigeminal ganglia, eyes, palatine and lingual tonsils are removed and disposed of as inedible
    • for tongues destined to be exported to the U.S. ensure the complete removal of lingual tonsil from the tongue, the tongue is detached from the head with a cut proximal to the vallate papillae
    • carcasses are segregated and visually identified as OTM while being stored at the establishment
  • for UTM carcasses:
    • palatine and lingual tonsils are removed and discarded as inedible tissues

Bison processing

For stand-alone processing establishments, this task applies only to establishments that process bison carcasses with vertebral column still attached.

  • monitoring procedures for the cutting and boning of bison include (but may not be limited to):
    • frequency of monitoring
  • for OTM carcasses:
    • are properly visually identified as being OTM
    • OTM carcasses are processed in a group and separate from UTM carcasses (for example end of shift, separate day)
    • vertebral column from OTM carcasses (containing dorsal root ganglia intact) are removed and treated as inedible
    • UTM and OTM carcasses are segregated while being stored at the establishment
    • implementation of corrective action procedures when critical limits are not met

Bison Packaging and Labelling

  • monitoring procedures for the labelling of bison product include:
    • OTM bison product is labelled in compliance with Annex R-2.

Verification activities

For slaughter establishments, refer to Operational guidance - Food Animal Slaughter PCI Implementation Verification, Appendix 5 for guidance on the PCI tasks to be added to a weekly PCI case and how to manage weekly PCI cases when a non-compliance is observed while performing a PCI task.

When performing the USA SRM On-site Verification task:

Document/records review

  • not applicable

On-site: observation and interview

  • observe and interview where necessary to verify that the operator is meeting requirements related to age determination, identification and marking of bison carcasses
  • observe and interview where necessary to verify that the operator is meeting requirements related to SRM removal from bison carcasses
  • observe and interview where necessary to verify that the operator is meeting requirements related to equipment
  • observe and interview where necessary to verify that the operator is meeting requirements related to receiving
  • observe and interview where necessary to verify that the operator is meeting requirements related to package labelling
  • when necessary, interview at least 1 person responsible for verification of implementation of the bison SRM controls process to determine if they understand and are following procedures as set out in licence holder's written PCP
  • when necessary, interview at least 1 person responsible for initiating actions to bring hazards back under control to determine if they understand and are following procedures as set out in licence holder's written PCP

USA SRM Records Verification

Legal authorities

SFCR 168

Reference documents

Outcome

Operator/licence holder meets requirements related to SRM removal and control for export of bison species to the USA,

Rationale

Inadequate process control measures could lead to a risk of SRM contamination of food and products that do not meet USA export requirements.

Performance criteria

Performance criteria for SRM records verification is as follows:

Bison Slaughter

  • monitoring procedures for the slaughter and dressing of bison include (but may not be limited to):
    • frequency of monitoring
    • proper age determination of each animal by examination of birth documentation or by examination of dentition
    • identification of the bison or bison carcass is maintained as UTM or OTM until all SRM is removed
    • if blood is harvested for edible product to be shipped to the U.S.A., controls are in place to prevent the cross contamination of blood with any exteriorized brain material from OTM animals after knocking
    • proper identification of dedicated tools used for OTM and UTM
    • removal and segregation as "not eligible for export to the United States", the entire small intestine or the distal ileum from all ages as "not eligible for export to the United States" (only applicable to establishments that salvage intestines for edible purposes)
    • sanitizing the split saw used on an OTM carcass before using the saw on an UTM carcass
  • employees handling SRMs use hygienic practices to prevent cross contamination (for example if product falls on the floor, the contaminated surfaces are treated as inedible)
  • ensure all remnants of the spinal cord are removed before the inspection legend is applied
  • for OTM carcasses:
    • marking of OTM carcasses before the head is removed (except where the lot is deemed OTM or the plant is dedicated to the slaughter of OTM)
    • brain tissue externalized during stunning and any product contaminated with brain tissue is disposed of as inedible
    • skull including the brain, trigeminal ganglia, eyes, palatine and lingual tonsils are removed and disposed of as inedible
    • for tongues destined to be exported to the U.S. ensure the complete removal of lingual tonsil from the tongue, the tongue is detached from the head with a cut proximal to the vallate papillae
    • carcasses are segregated and visually identified as OTM while being stored at the establishment
  • for UTM carcasses:
    • palatine and lingual tonsils are removed and discarded as inedible tissues

Bison processing

For stand-alone processing establishments, this task applies only to establishments that receive bison carcasses with vertebral column attached.

  • monitoring procedures for the cutting and boning of bison include (but may not be limited to):
    • frequency of monitoring
  • for OTM carcasses:
    • are properly visually identified as being OTM
    • OTM carcasses are processed in a group and separate from UTM carcasses (for example end of shift, separate day)
    • vertebral column from OTM carcasses (containing dorsal root ganglia intact) are removed and treated as inedible
    • UTM and OTM Carcasses are segregated while being stored at the establishment
    • implementation of corrective action procedures when critical limits are not met

Bison Packaging and Labelling

  • monitoring procedures for the labelling of bison product include:
    • OTM bison product is labelled in compliance with Annex R-2.

Verification activities

For slaughter establishments, refer to Operational guidance - Food Animal Slaughter PCI Implementation Verification, Appendix 5 for guidance on the PCI tasks to be added to a weekly PCI case and how to manage weekly PCI cases when a non-compliance is observed while performing a PCI task.

When performing the USA SRM Records Verification task:

Document/records review

  • review at least 1 week of the operator's shipping, receiving or other relevant records verify that the following information is recorded where applicable:
    • the documentation, including records, reflects the conditions observed on site
    • the documentation for monitoring, verification and corrective action procedures substantiates that the preventive control plan (PCP), in relation to the selected CCP/control measure, has been implemented and provides evidence that the control measures are effective
  • review the monitoring records (for CCP and PC) related to control of SRM removal in bison for US export
    Verify that:
    • the monitoring frequency specified in monitoring procedure is adhered to
    • the monitoring confirms that all control measures are followed
    • the results of monitoring are recorded as specified in the monitoring procedures
    • the corrective action procedures were followed when deviations were identified and were documented
  • review the verification records related to control of SRM removal in bison for US export Verify that:
    • verification activities can confirm that monitoring procedures are followed, and that control measures are capable of consistently achieving the outcome
    • the verification frequency specified in the verification procedures is adhered to
    • the results of verification are recorded as specified in the verification procedures
    • the corrective action procedures were followed when deviations were identified and were documented
    • if applicable, any verification activity that includes sampling and test methodologies is capable of demonstrating accurate and valid results (for example use of accredited laboratories)
  • review the corrective action records related to control of SRM removal in bison for US export
    Verify that the documentation demonstrates control of the commodity by:
    • determining if the affected or potentially affected commodity is in compliance with regulations
    • bringing an affected commodity into compliance (including validation) or disposing of it as appropriate
    • ensuring the prevention of a re-occurrence
  • the licence holder is effectively able to identify non-compliances, bring hazards back into control and prevent re-occurrence
  • verify documents reflect the conditions observed on-site

On-site: observation and interview

  • Not applicable

Export BSE Requirements

Legal authorities

SFCR 168

Reference documents

Outcome

Operator/licence holder meets foreign country requirements related to the removal and control of Specified Risk Material (SRM).

Rationale

Inadequate process control measures could lead to a risk of SRM contamination of food and products that do not meet foreign country export requirements.

Performance criteria

This task is to be completed at all establishments where bovine meat products are manufactured, regardless of export eligibility.

Performance criteria for foreign country Bovine spongiform encephalopathy (BSE) requirements are as follows:

Slaughter with Processing

  • the operator is meeting requirements related to removal of tonsils from beef tongues destined for export
    • If the country requirements do not specify palatine tonsils, the tongues must be harvested making a cut caudal to (just behind) the vallate papillae
  • the operator/licence holder is following their specific written procedures for OTM marking
  • the identification mark (see Annex R-2) appears on the products in the case of unpackaged products or on the main panel of the shipping container in the case of packaged products Footnote 1

    • The size of the mark should be of at least 5 cm (sides in the case of the triangle and height in the case of the numeral)

Processing establishments

  • at a receiving establishment, a written confirmation related to effective OTM marking from the operator/licence holder of the bovine product suppliers, is available on request
    • If the receiving processing establishment will be conducting additional steps on the OTM product prior to shipping to another establishment for further processing:
      • the operator/licence holder is following their specific written procedures for OTM marking
      • the identification mark (see Annex R-2) appears on the products in the case of unpackaged products or on the main panel of the shipping container in the case of packaged

Verification activities

For slaughter establishments, refer to Operational guidance - Food Animal Slaughter PCI Implementation Verification, Appendix 5 for guidance on the PCI tasks to be added to a weekly PCI case and how to manage weekly PCI cases when a non-compliance is observed while performing a PCI task.

When performing the Export BSE Requirements task:

Document/records review

Review a representative cross-section of documents /records to verify that:

  • performance criteria, as stated above, are being implemented as per written PCP
  • the documentation for verification procedures substantiates that the PCP for foreign country export BSE requirements is effectively being implemented
  • the records reflect non-compliant situations observed by CFIA
  • the licence holder is effectively able to identify non-compliances, bring hazards back into control and prevent re-occurrence
  • verify documents reflect the conditions observed on-site

On-site: observation and interview

  • observe and interview where necessary to verify that the operator is meeting requirements related to foreign country BSE requirements
  • when necessary, interview at least 1 person responsible for verification of implementation of the foreign country BSE requirements to determine if they understand and are following procedures as set out in licence holder's written PCP
  • interview at least 1 person responsible for initiating actions to bring hazards back under control to determine if they understand and are following procedures as set out in licence holder's written PCP
 
Date modified: