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Chapter 4 - Inspection procedures, dispositions, monitoring and controls

4.11 Non-meat food products

(1) General Information

Products under this category refer to those ingredients that are normally added in the preparation of a meat product e.g. spices, fillers, extenders, curing agents, etc. Basically, they can be divided into 2 groups:

• restricted non-meat food product, e.g. nitrite and nitrate salts
• non-restricted non-meat food product, e.g.  spices, fillers, extenders, etc.

Storage and sanitation of non-meat food products

Non-meat food products shall be stored in a suitable dry storage room or in a cooler meeting all structural and sanitary requirements that apply in registered establishments.

The operator is responsible for maintaining nonmeat food products and the premises in which they are stored, in good sanitary conditions. The Inspector in Charge is responsible for monitoring the standard of housekeeping in these areas ensuring that the product and premises do not pose a hazard to the meat products subsequently prepared.

Vegetables, though considered to be in the nonmeat food product category, must be stored, washed and prepared in a separate room to avoid risk of contamination.

(See Chapter 8, section 8.10 for examination of incoming non-meat food products)

(2) Use of eggs in registered establishments

The operator of the registered establishment may use pasteurized processed egg which originates from a registered processed egg station or may purchase grade "Canada A" shell eggs from a registered egg station.

The major concern with the use of eggs is the possible presence of Salmonella bacteria, particularly Salmonella enteritidis.

Pasteurized processed eggs are considered the lowest risk form of eggs and continue to be the safest and preferred option, especially if the prepared food may be consumed by people particularly vulnerable to infection.

In the case of products which are fully cooked or intended to be cooked by the consumer before eating, the risk associated with the use of fresh uncracked (i.e. in the shell) grade Canada A eggs should be minimal if Good Manufacturing Practices (G.M.P) are met during food preparation.

A summary of the G.M.P. for the breaking of eggs is as follows:

1. Egg holding: Shell eggs are to be held in a cooler at 4C (40F).
2. Eggs may be tempered prior to breaking for better yield. Tempering may be done at room temperature; however, tempering shall be done in a way that the does not result in time-temperature abuse of the eggs. The quantity of eggs tempered should not exceed the amount needed for the production lot. Eggs should be used as soon as, or before reaching room temperature and should not be held for extended periods of time at room temperature.
3. Stainless steel equipment shall be used for the breaking of eggs. Any shell in contact with the egg meat shall be removed immediately. The egg should be broken in a manner that allows the person breaking the eggs to visually examine each egg for defects and to detect any odours which may be developing. Defective eggs, such as leakers, off odour, blood rejects, etc., must not be used for human consumption.
4. The breaking equipment shall be maintained in good working condition. Equipment shall be effectively cleaned and sanitized as per the establishment's written sanitation program.
5. Egg shells and any inedible eggs (leakers) shall be identified and promptly removed from the processing area. Control of inedible eggs should be maintained in an appropriate manner.
6. The liquid product must be used immediately or cooled to 4C (40F for holding purposes.
7. Holding tanks shall be constructed of stainless steel or other approved material; they should be equipped with agitators, and refrigerated, if they are to be used for holding liquid eggs.
8. No fresh or frozen liquid egg is to leave the premises unless it is marked "Inedible egg - unfit for human consumption", as it does not meet federal or provincial requirements.

Storing, tempering and breaking of shell eggs shall be done in a manner which does not result in cross-contamination of meat products.

Egg processing equipment must meet general requirements for equipment but does not require approval by the Meat and Poultry Products Division.

(3) Preparation of fillers, spices and preservatives

Where these products are purchased in bulk form, mixing and preparation must take place in a separate room as outlined in 2.8.15. The operator is responsible to execute these operations under acceptable sanitary conditions which in turn shall be monitored by the inspection personnel.

(4) Control over the use of restricted nonmeat food products

Although the control, preparation and use of restricted curing agents is the responsibility of the operator, the Inspector in Charge shall closely monitor their use. Where nitrite salts or nitrate salts are purchased in bulk form, the inspector must ensure that they are securely kept in a locked compartment and access allowed to authorized personnel only. Where these curing agents are purchased in prepackaged batch-sized units, storage restrictions are not required, however, the inspector should verify that the nitrite or nitrate components of the unit are packaged separately from any spice, seasoning or other proteinaceous ingredient. Monitoring the use of the above salts can be accomplished by requesting the operator to disclose the quantities of nitrite salts and nitrate salts being used in each formulation to verify that the quantity used does not exceed the permissible amount. When non-compliance is suspected, additional monitoring can be performed by submitting samples of the finished product in order to evaluate residual nitrite and nitrate level.

4.12 Non-food products

(1) General information

This section deals with all non-food products and materials used in registered establishments with the exception of construction materials and plant equipment. It deals with products which are noxious, others which are not noxious; products which come into contact with meat products and others which shall never come into contact with meat products. See Chapter 8, section 8.11 for requirements on receipt of incoming non-food products which may come into direct contact with food.

(2) Types of non-food products

Products covered by this section can basically be divided into two groups:

1. non-food products which require to be labelled. This group includes the following: bleaches, cleaners, creams, deodorizers, desiccants, disinfectants, denaturing agents, floor drying compounds, industrial antifreeze, inks, lubricants, pesticides, protective oils, processing adjuncts, refrigerating brine additives, refrigerants (immersion freezing), release agents, scalding compounds, sanitizers and water treatment compounds; and
2. non-food products which do not require to be labelled. This group contains all types of packaging materials (see 4.13.(5) and (6)).

(3) Submission for acceptance of nonfood products other than packaging materials

All non-food products dealt with in this section, which are not already listed in the reference listing for materials and agents, or exempted, as described below shall be submitted for evaluation and acceptance before use in registered establishments. Non-food products coming into contact with meat products shall be submitted for evaluation to the Chief of Food Science. Non-food products not normally coming into direct contact with meat products and inks shall be submitted for evaluation to the Chief, Plants, Equipment and Chemical Evaluation.

N.B. Use of wooden sticks for preparing specialty products in registered establishments.

Some prepared meat products such as chateaubriand, shish kebab, pogos, etc., are generally offered to the consumer mounted on or retained by a wooden stick. The manufacturing of these preparations is allowed in registered establishments providing they do not represent a source of contamination. Such sticks do not require submission for acceptance.

Exemptions: Labelled products not requiring divisional acceptance

1. Pesticide products for outdoor use only. Example: herbicides. These must bear P.C.P. registration number on the label and be used in keeping with label instructions to preclude direct or indirect contamination of food products, and are not to be used in or around outside food handling areas.
2. Products used in offices or similar non processing areas. Examples: furniture waxes and polishes, upholstering and rug shampoos or cleaners.
3. Products used in cafeterias or lunch rooms. Examples: rinse additives, hand washing soaps or detergents, tarnish removers. These are not to be used in processing areas, unless accepted.
4. Products used in heating systems. Examples: fuel additives, firebox or flue treatments or cleaners.
5. Products used outdoors only for sewage or waste water systems. Examples: grease solvents for external traps or lines, odor control compounds in lagoons or holding ponds.
6. Products used in cooling towers or evaporator condensers. Examples: corrosion inhibitors, algicides, (must bear P.C.P. registration number) cleaning compounds.
7. Products used for the cleaning or maintenance of the exterior of vehicles. Examples: car washes or shampoos, tire cleaners, body brighteners.

The materials in the above categories may be used in registered establishments with the following provisions:

1. The products have labels bearing the information as outlined (section 4 below).
2. The inspector in charge is satisfied that the use of the product does not directly or indirectly contaminate food products during application and storage and are not stored in food handling areas.

The initial submission is to be submitted in duplicate and shall consist of:

1. a letter of application;
2. the chemical composition of the product, listing all ingredients by percentage or quantitatively. All components shall be identified chemically;
3. labels for use in connection with the product (see (4) below);
4. under certain circumstances, additional information, such as migration studies or extraction data, may be required.

(4) Submission of labels for non-food products

Labels for all products required to be labelled shall be submitted for evaluation. The following number of labels shall be submitted: when in draft form, 2 copies; when in printer's proof form, 1 copy; when in final form, 3 printed labels.

Every label shall show the following basic information:

1. the name and address of the firm manufacturing or distributing the product. The address may be that of the head office of the firm;
2. the descriptive name of the product. This is required prominently, immediately adjacent to the brand name, to denote the function and include a statement on the specific intended use in food plants;
3. a list of major ingredients. If there is an active ingredients list on the label and the major ingredients in the product, are non-active, they should be declared under a separate heading such as contains or ingredients;
4. directions for use, including any precautionary statements necessary to avoid contamination of food, such as potable water rinse, where applicable;
5. a net content statement; and
6. where applicable, the words "Product of ...." indicating the country of origin. The statement should be placed below the descriptive name of the products.

(5) Packaging materials

Packaging material includes cartons, wrapping materials, films, synthetic casings, nettings, trays, pouches, bags, and any other material used in the shipping of meat products which may come into contact with the meat product shipped. Packaging material shall not impart any undesirable substance to the meat product, either chemically or physically and shall protect them sufficiently to avoid their contamination. Each new material must be evaluated in regard to its suitability for the intended purpose.

In order to demonstrate to the inspector that the materials used satisfy the above criteria, the operator shall maintain a listing of all the packaging materials used in the establishment. The material shall appear in the "Reference Listing of Accepted Construction, Packaging Materials and Non Food Chemical Agents" published by the CFIA or if not yet listed in this manual, a CFIA approval letter.

Manufacturers and distributors of packaging materials requiring acceptance shall send the new material for evaluation to the Program Officer, Hygienic Environment Program, Science and Technology. Submissions in duplicate (single sample) shall consist of the following:

1. a letter of application;
2. identification of the material;
3. details in regard to the proposed usage (indicate type of food to be packaged, temperatures at which food will be packaged, stored and reconstituted, etc.);
4. the complete chemical composition of the material listing the ingredients by percentage or quantitatively. Each component must be chemically identified and include trade name and manufacturer;
5. identification of all chemical agents which are used during the manufacturing process as processing agents but are not components of the finished product; and
6. a sample of the material. The sample should be adequately identified with all the other information provided. These are to be forwarded to this office F.O.B. (freight, custom duties, brokerage and delivery costs prepaid).

(6) Use of shipping containers with handholes or ventilation holes

Both open handholes and ventilation holes are permitted in corrugated cartons intended for use in the transportation and storage of prepackaged meat products.

Such cartons with open handholes and ventilation holes may also be used for the transportation and storage of meat products that are not prepackaged, provided an overwrap or liner is being used to protect the meat products from the possibility of contamination. This protection is required equally in waxed and unwaxed containers.

(7) Use of combo bins

Combo bins must be of sufficient strength to avoid collapse and spillage of meat products.

Acceptably constructed combo bins may be used for storage of refrigerated or frozen meat products. Whenever combo bins are used for the storage of meat products in freezers or for the shipment of refrigerated or frozen meat products from a registered establishment the meat products shall be protected by adequate lids or covers to prevent contamination and freezer burn.

(8) Reusable shipping containers

Accepted reusable shipping containers may be used in registered establishments provided the following conditions are met:

1. in the case of an accepted shipping container with lid qualifying for direct food contact:
   1. there is a suitable room adequately equipped for the washing of containers before reuse. The washing and rinsing must clean the containers to a degree which makes them visibly clean. The state of these containers should be maintained in a condition that will be acceptable as a food contact surface. Washing of reusable containers in outside facilities will be considered on an individual basis. Applications are to be made to the Chief of Plants and Equipment;
   2. there are separate facilities in the registered establishment for the storage of cleaned and non-cleaned, reusable containers. The cleaned containers shall be stacked on cleaned non-absorbant pallets. They may be stored in a dry storage area along with other new material as long as they are dry and protected against recontamination of any kind. Storage should be in accordance with 4.10.4 of the Manual;
   3. reusable shipping containers are of sufficient strength to support the weight of the ones above. They should not have perforations; if perforated, a liner must be used. The lid must be adequately designed to prevent contamination of the product; and
   4. the shipping container is labelled in one of the following manners:
      • marked with all mandatory information (see 7.12); or
      • a shipping tag bearing all mandatory information is attached to the shipping container.
2. in the case of an accepted container without a lid:
   1. there is a suitable room adequately equipped for the washing of containers before reuse. The washing and rinsing must clean the containers to a degree which makes them visibly clean. The state of these containers should be maintained in an undamaged condition. Washing of reusable containers in outside facilities will be considered on individual basis. Applications to be made to Chief of Plants and Equipment;
   2. there are separate facilities in the registered establishment for the storage of cleaned and non-cleaned, reusable containers. The cleaned containers shall be stacked on cleaned non-absorbant pallets. They may be stored in a dry storage area along with other new material as long as they are dry and protected against recontamination of any kind. Storage should be in accordance with 4.10.4 of the Manual;
   3. reusable shipping containers are of sufficient strength to allow stacking without collapsing under the weight of the ones above. They should not have drainage holes to prevent drainage into other containers;
   4. the bottom of stacked shipping containers will not be supported by the packaged product in the lower shipping container;
   5. only product packaged in sealed bags may be shipped in these shipping containers without lids; and
   6. the product/shipping containers are labelled in one of the following manner:
      • marked with all mandatory information (see 7.12);
      • a shipping tag bearing all mandatory information is attached; or
      • the sealed bag bears all mandatory information (printed or by means of an insert or a sticker).

All non-food products evaluated and found acceptable are listed in the "Reference Listing of Accepted Materials and Equipment" produced by the Agri-Food Safety and Strategies Division.

(9) Reuse of Cardboard Boxes

Cardboard containers may be reused by the operator provided that concerns regarding sanitary handling of the boxes, prevention of cross-contamination and labelling of the boxes are addressed in a satisfactory manner.

The operator shall have in place written protocols and procedures, which have been reviewed and found satisfactory by the Inspector-in-Charge, before reuse of cardboard boxes can begin. The procedures must ensure that:

i) Containers have not left federal inspectional control.

Containers must either have remained in the establishment or have been shipped directly to the establishment from another registered establishment or registered storage. Returned containers from retailers, hotels, restaurants, institutions or non-registered processing/slaughter establishments are not eligible for reuse.

ii) Container reused:

• are clean with no visible contamination;
• are in good condition with no physical damage liable to weaken the container's structure; and
• have remained completely dry at all times (even in the case of waxed corrugated cardboard boxes).

Provisions for the prompt removal of all unsuitable containers must be included as part of the operator's procedure.

iii) Containers destined for re-use are stored and handled in such a way as to prevent any possible contamination of product and/or of the plant environment.

When stacked containers must not enter into contact with the insides of box liners, product contact surfaces or employees handling exposed product.

iv) New liners are used when reused boxes are used for packaging exposed products.

Fibre containers may be reused without liners for fully packaged product.

v) All applicable labelling requirements for the container are met.

The reuse of cardboard containers is subject to compliance with the established protocol. Inspection staff are to monitor operations to assess that the procedures proposed are being followed and are suitable. It is understood that failure to respect the procedures or an unsuitable procedure shall result in loss of cardboard re-use privileges.