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CHAPTER 3 - Sanitation

3.8 Operational inspection

General

Basically the key areas requiring adequate maintenance of sanitary conditions are the same as outlined in 3.7 of this chapter, however there is the added complication of the picture being confused by operations in progress. In addition, this facet of sanitation is a challenge, in that due to the rapidity of production, unacceptable practices could result in vast amounts of product out of compliance. Equipment, practices or services could be at fault.

The accumulation of proteinaceous material and fat on equipment over the course of a shift should be prevented as much as possible, but obviously this will occur within equipment in some locations where easy removal is not feasible. In order to reduce the hazard posed by such situations, adequate and correct temperature regulation is essential in order to slow down the reproduction rate of microorganisms.

Equipment such as sanitizers, hand washing facilities (including washrooms), etc. must be maintained in an acceptable fashion.
Operating procedures, from the stunning of animals right through processing to shipping, must be performed with regard to alterations in the environment that would put the product at risk. Procedures must be constantly reviewed and examined for potential problems. On the kill floor, areas of common contact should be identified and sanitation procedures instituted. Prevention of contact with contaminated or diseased tissues is of prime importance. Management must supply the required janitorial service (floor cleaning, trash removal, scrap removal, etc.) to maintain a satisfactory level of hygiene during operations. Also of importance are the work habits, dress and personal hygiene of plant employees.

The inspector must be aware of and capable of detecting potential problems. He is further required to assure himself that management will initiate action to resolve the problems.

Sanitizers and Sanitizing Dips

Sanitizers, when strategically placed, maintained and utilized, become a very important facet of sanitation during daily operations. They must be sufficient in number and located where required (see chapter 2). Plant management is required to assure that they are maintained and are functional prior to and during operations. Sanitizers must be operated at not less than 82C with adequate water overflow, in order to achieve a sufficient reduction in the number of microorganisms present. It must be remembered that the presence of organic matter on the equipment will act as a barrier, thereby protecting the micro-organisms. Equipment should therefore be as clean as possible before it is placed in a sanitizer. When a chemical sanitizer is used in lieu of an 82°C water sanitizer, the sanitizing agent must be approved for this use (listed in the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products) and the manufacturers instructions on the label must be followed including contact time and rinsing or draining as applicable, and efficacy is demonstrated.

Hand sanitizing stations (e.g., dips, gels, sprays, etc.) serve as purposeful adjunct to the hand-washing facilities located in processing areas. They are required and must be used by all employees which come in direct contact with microbiologically sensitive meat products (ready-to-eat meat products). They must not be located where contamination of the product could occur. They may be located next to the hand washing stations and used after hands have been thoroughly washed or closer to the production line where no contamination of product or direct contact surfaces can occur. The use of hand sanitizing solutions must be restricted to those listed in the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products. It is further required that they be used in keeping with directions on the label (eg: correct concentration, contact time). The hand dip solutions should be renewed throughout the day, as often as necessary, so that they, in themselves, do not become a source of contamination.

Caution must be exercised in that management and inspection personnel do not put excessive reliance on this aspect of sanitation, to the detriment of other sanitary control measures throughout the operations. Relaxation of sanitary requirements earlier in the production process cannot be offset by the ritualistic dunking of hands.

Antibacterial soaps can be used in place of hand sanitizing dips. These soaps must be listed in the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products and be used according to the directions on the label.

Plastic gloves may be worn by employees which come in direct contact with ready-to-eat meat products as long as their hands are washed upon entering the processing area, prior to putting the gloves on, and their gloved hands are sanitized in an approved hand dip prior to handling product.

For both chemical hand dips and chemical equipment sanitizers, the operator must perform effectiveness checks (eg: necessary concentration, contact time) and keep records of these checks.

Exemption from refrigeration of processing areas

The following rules supersede and replace all previously existing exemptions to refrigeration requirements for processing rooms. Note that temperature requirements for storage rooms, curing rooms and non-production areas are not changed. Therefore, these rules DO NOT apply to:

• Cooking rooms (e.g., oven, kettles, fryers, etc.);
• Fermentation and aging rooms;
• Transfer areas into and out of cook rooms (e.g. hallways where no product is kept);
• kill floors, evisceration floors, scalding rooms and slaughter associated processes such as tripe, feet, casings, etc.

As a general rule, all meat product processing operations (including those for shelf stable dry cured meat products having "keep refrigerated" on the label) shall be conducted in refrigerated rooms (i.e., maintained at a temperature of 10°C or less).

Exemptions from the requirement to maintain refrigeration ( 10°C) in processing rooms can be granted by a Regional Program Manager, Meat Hygiene, if ALL of the following conditions (A,B,C and D) are met:

1. The environment (equipment, contact surfaces, handlers,...) shall not pose a risk of product contamination at any time during operations. The operator has developed and implemented a HACCP-based Quality Control (QC) program (see FSEP Generic Models), including microbiological assessment of the product and environment, which ensures that the process meets the minimum criteria set out for the process in this document. Each HACCP- based QC program shall be reviewed and recommended by a team composed of the Inspector-in-Charge and a regional program specialist having the required specialized knowledge, then submitted to a Regional Program Manager, Meat Hygiene. After appropriate review by the Regional Program Manager, the program will be stamped and returned to the operator with the reviewers' conclusions. The operator must keep any letter of acceptance on file for future reference and review by the Inspector-in-Charge.
   As each process will be inherently different, it is impossible to provide set microbiological guidelines suitable for all operations. Microbiological programs will therefore need to be developed by the operator on a case by case basis to the satisfaction of the Regional Program Manager, Meat Hygiene and shall demonstrate the safety of the environment at all times during processing.
   
   
2. Any unclean equipment that was previously used and left unused for a period of 2 hours or more shall be completely taken apart, cleansed and sanitized before being reused;
   
3. Unless the operator is able to demonstrate the continual microbiological acceptability of the environment (by means of a valid microbiological sampling program), a complete mid-shift clean up (including equipment dismantling) of contact surfaces shall take place at least once every 4 hours during operations. Such a mid-shift cleanup procedure shall consist of removal of all meat products, other ingredients and packaging material from the room prior to conducting a thorough cleaning and sanitation of product contact surfaces. Should such cleaning create condensation on overhead structures, the condensate must be eliminated prior to the start-up of operations. At the end of a mid-shift clean-up, product contact surfaces shall meet the same criteria as for the pre-operational inspection stage.
   
4. The type of operation falls within one of the categories listed below.

[1] Kitchen / Formulation operations:

An exception for the refrigeration of formulation rooms under specific circumstances has been made. Most meat products entering these rooms come directly from the cooler and are at a relatively low temperature. All formulation, stuffing, handling, pre-blending, marination, etc. operations involved in the processing of meat products are eligible for exemption from refrigeration requirements provided ALL of the following additional conditions are met:

1. the meat used in the product was either hot boned immediately prior to processing OR previously chilled to a temperature of 4°C. or less, and
   
2. the meat surface temperature never exceeds 7°C; and
   
3. in the case of a non-cured product, cooking (product must be fully cooked), drying or fermenting of the product shall start within 2 hours of the time it first enters a non refrigerated area.
   
4. In the case of a cured product, cooking (product must be fully cooked), drying or fermenting of the product shall start within 4 hours of the time it first enters a non refrigerated area.

[2] Comminuting operations:

2.1) Comminuting operations (e.g., grinding, emulsifying, dicing, slicing, chopping, etc. of raw meat products) are eligible for exemption from refrigeration requirements provided ALL of the following additional conditions are met:

1. The meat to be comminuted was previously chilled to 4°C or less and
   
2. the comminuted product cooking cycle is initiated within 2 hours from the time the product enters a non refrigerated area.
   Note: Comminuting of raw meat product that is intended to be sold as fresh ground meat product or is intended to be further processed in a product that will be sold as raw or semi-cooked (i.e., not fully cooked) must be performed in a fully refrigerated area.

[3] Meat filled pasta/ meat filled pastries/ continuous line for breaded meat products:

The processing of meat-filled pastries and meat-filled pasta (e.g., ravioli, tortellini, etc.) that cannot technically be processed under refrigeration (because the dough will not stick together in a refrigerated area), as well as continuous lines for breaded meat products, could be allowed in a nonrefrigerated area provided ALL of the following conditions are met:

1. the meat product has been chilled to a temperature of 4°C. or less before being transferred to the nonrefrigerated area AND the meat product surface temperature does not exceed 7°C. at any time during the process; and
   
2. the product is either:
   1. placed in a freezer within 30 minutes after the preparation is completed OR
      
   2. fully cooked or pasteurized within 30 minutes after the preparation is completed and subsequently chilled or frozen.

[4] Handling of pork tongues, pork hocks & feet intended for immediate further acidification:

Such handling could be allowed in an nonrefrigerated area provided ALL of the following conditions are met:

1. there is a continuous drop in product temperature as defined by the "Time/Temperature Guidelines for Cooling Heat Treated Processed Product" in Chapter 4, section 4.10.3 (4) of the Manual of Procedures); and
   
2. handling is done with all precautions being taken to avoid re-contamination of the cooked product (e.g. disposable gloves, use of hand sanitizers, restricted area, special ongoing sanitation of equipment as required, etc.).

[5] Assembling and Packaging of meat products:

Different situations could occur with different levels of risk:

5.1) Packaging of cooked refrigerated ( 4°C or less) meat products shall be done in a refrigerated room (maximum temperature of 10°C) in order to minimize reheating of product surfaces and possible growth of pathogens.

5.2) Packaging of frozen meat products in a non refrigerated room could be allowed if:

1. The product enters the nonrefrigerated room in a frozen condition; and
   
2. the product's surface temperature does not exceed 0°C. while in the nonrefrigerated packaging room.

5.3) Assembly and packaging of entrées, such as pizzas and TV dinners could be allowed in a nonrefrigerated room provided ALL of the following conditions are met:

1. The process is continuous in nature;
   
2. The meat product has been chilled to a temperature of 4°C. or less before being transferred to the nonrefrigerated area; and the product's surface temperature does not exceed a temperature of 7°C. at any time during the process;
   OR
   If trays of entrées such as TV dinners are hot filled, the chilling of the meat component (including the sauce) complies with the guidelines for cooling of heat processed meat products as given in chapter 4, section 4.10.3 (4) of the Meat Hygiene Manual of Procedures;
   
3. handling is done with all precautions being taken to avoid re-contamination of the cooked product (e.g. disposable gloves, use of hand sanitizers, restricted area, special ongoing sanitation of equipment as required, etc.); and
   
4. The product freezing process is initiated within 30 minutes of the beginning of the assembly operation.

5.4) Packaging/handling of meat products which have just been cooked but have not yet been refrigerated to the storage temperature of 4°C or less, and the application of a surface coating or glazing to a cooked meat product (e.g., chicken wings, etc) at the exit of the oven could be allowed in a nonrefrigerated area provided ALL of the following conditions are met:

1. packaging/handling operations are done while the product is still at 60°C or above;
   
2. packaging/handling operations in such a nonrefrigerated area do not interfere with the product cooling process (i.e., there is a continuous drop in product temperature: see Time/Temperature Guidelines for cooling Heat Treated processed product in Chapter 4 of the Manual of Procedures); and
   
3. handling is done with all precautions being taken to avoid re-contamination of the cooked product (e.g. disposable gloves, use of hand sanitizers, restricted area, special ongoing sanitation of equipment as required, etc.).

[6] Handling and packaging of dry soup mixes, bouillons, broths, concentrates, tallow, lard, suet, edible casing preparation, edible fat and shelf stable dry cured meats (if truly shelf stable i.e. the label does not have a "Keep refrigerated" statement):

Because these products are shelf stable and represent a very low health risk, an exemption could be granted.

Please note that the handling (e.g., boning, picking, dicing, etc.) of warm cooked meat product when those products could be used as ready-to-eat products (e.g. diced chicken that could be used for salads) is not exempted and shall therefore be conducted in a fully refrigerated area.

It should be remembered that unless the operator is able to demonstrate the continual microbiological acceptability of the environment (by means of a valid microbiological sampling program), a thorough and complete mid-shift clean up (including equipment dismantling) and a preoperational check shall take place at least once every 4 hours of operations. Some discretion is permitted when dealing with enclosed equipment through which product is passing on an almost continuous basis, e.g. stuffers. In these instances, dismantling and cleaning may be permitted on a daily rather than a shift basis.

Mid-shift clean-up

The only other case where a mid-shift clean-up procedure is allowed in lieu of adequate refrigeration is when there has been a temporary mechanical failure of refrigeration equipment making it impossible to maintain the prescribed room temperature. In this case, measures must be taken to ensure that product temperatures do not exceed 10°C. This may be accomplished by icing, or other satisfactory means. In those cases where the prescribed room temperature cannot be maintained, a thorough cleanup must be made after each four hours of operation.

Such a mid-shift clean-up procedure must consist of removal of all meat products, other ingredients and packaging materials from the room prior to a thorough cleaning of product contact surfaces and a rinse down of floor areas. Should such cleaning create condensation on overhead structures, the condensate must be eliminated prior to the start-up of operations.

3.8.1 Outside premises

This is an area which often does not receive the attention it deserves. The location of a plant (see chapter 2) in conjunction with the sanitation of the external premises has a bearing on sanitation with the premises. The standard of sanitation practised outside the premises may well be reflected in the attitude of plant employees within the establishment.

Consistent implementation of good groundkeeping habits is required to prevent product contamination from objectionable odours, vermin, ash, dust, etc.. Programs must be developed for the storage and removal of unwanted material. Suitable storage facilities must be provided for garbage which should be removed daily. Meat and bone scraps require proper containers and refrigeration to prevent a potential hazard from flies and bacteria. Unused and obsolete equipment, building materials, etc. must not be allowed to accumulate in disarray but should be piled neatly and routinely removed if of no further use. Grass and weeds should be kept under control. The location of an incinerator, if permitted by local authorities, should be such that the prevailing winds do not direct the fumes or smoke toward the plant. The incinerator must be placed on a suitable concrete foundation and fitted with a screen to control the emission of flying ash.

3.8.2 Transportation of finished products

The vehicle used in the transport of meat products is technically an extension of the plant premises. When examined or considered in this light it is obvious that the vehicle acts as the interim storage facility from the plant to its point of destination. Acceptance of this premise dictates that construction, maintenance, sanitation and refrigeration standards must equate, as closely as is reasonably possible, to those standards required of the registered establishment. (See Chapter 8, section 8.6)
Management is required to assume the responsibility of providing satisfactory conveyance vehicles and mechanisms for the transport of meat product. (See Chapter 8, section 8.6)

Inspection personnel are required to monitor this aspect of plant operations and are further empowered to deny the use of unsatisfactory vehicles and to hold for reworking or refuse entry to products received in unsatisfactory vehicles or which have been subjected to abuse, e.g., defrosting, contamination, etc. during transportation.

3.8.3 Animal transportation and holding pens

The vehicles and crates used to transport animals to slaughter play an important role, not only in the humane treatment of animals and the control of animal disease, but also in sanitation.

In general, the cleaner animals are upon reaching the slaughter floor, the better the chances of reducing contamination levels on dressed carcasses, assuming good dressing practices are put to use. To encourage those transporting animals to load them into clean vehicles and crates, it is important that a good example be set, by ensuring that all vehicles and crates leaving a registered establishment are cleaned and disinfected in accordance with the Health of Animals Act and Regulations.

Construction and design should be such that this area may be kept reasonably free of manure, straw, odour, etc., that may attract and harbour insect and rodent populations. Total sanitation is further enhanced through the provision of adequately lighted "held pens" for reactor and suspect animals in order to isolate them from other animals.

A cleaning and disinfecting program should be developed in keeping with the operations and disease control requirements, e.g., reactor pens to be cleaned and disinfected after each day's use or more frequently, if directed. Routine cleaning shall be performed as often as is necessary to meet the objectives as outlined above.

Good animal husbandry must be manifested in the provision of clean feed, water and bedding, where necessary. Implicit in good husbandry practices is the maintenance of the facility so that it is free of exposed nails, broken boards, floors, etc. that may injure the animals.

3.8.4 Waste disposal

It is preferable that waste such as paper, boxes, strings, etc. be removed from the plant premises on a daily basis. Properly identified containers designed for holding this material must be provided throughout the plant. Janitorial service is to be supplied, that will remove and replace these containers as often as necessary. Overflow and spillage on the floor defeats their purpose. Attention to detail in this area of plant sanitation helps create an atmosphere and attitude that is reflected in employees' work attitudes. A sloppy work place begets sloppy work habits.

Waste materials within the livestock pens, such as manure and straw, may be collected and deposited on a hard surfaced slab for subsequent removal (see chapter 2). A program must be initiated for the routine removal of this material so as to prevent the possibility of its becoming a harbouring place for flies and vermin and giving rise to objectionable odours.

3.8.5 Disposal of condemned and other inedible meat products

Control of this aspect of packing house sanitation is of vital importance. Every effort must be made to assure that the storage and handling of these materials does not put edible products at risk.

Segregation is the key to control. This is achieved through developing an acceptable flow system, so that inedible meat product is directed away from the edible meat product. Part of this system may be appropriately marked containers or chutes used to move product to the designated inedible and condemned product rooms of an establishment. The identity of these products must be maintained at all times until they are used as animal food products or, in the case of condemned material, until they are subjected to a sterilization process or disposed of in accordance with the Meat Inspection Regulations. These products should always move directly to their designated areas and should never be rerouted through the processing areas used for edible products. Odour in the plant from inedible operations may indicate an error in the pattern of air flow. The equipment used for the handling of these products must be frequently cleaned and disinfected and any equipment returning into edible areas must first be cleaned. The storage areas or rooms must also be subject to a scrupulous cleaning and sanitizing program. This equipment and the storage facilities represent a very real sanitation hazard to the establishment, if not subjected to a rigid sanitation control program.

3.8.6 Welfare facilities

The provision of adequate welfare facilities is an indispensable requirement for the promotion of hygienic practices. The quality of facilities provided to employees in this area of their work environment is so often reflected in their attitude and work habits relating to sanitation at the work stations. Attention must be paid to the size, lighting, ventilation, etc. (see chapter 2).

These facilities must be maintained and provided with adequate janitorial service throughout the day. Close attention must be paid to the possible infestation with vermin, e.g., cockroaches. Failure to respond to the needs and standards in these areas may require withdrawal of inspection privileges until rectification of the deficiencies has been accomplished.