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CHAPTER 4 - ANNEX N

REMOVAL OF SPECIFIED RISK MATERIALS (SRM) FROM CATTLE SLAUGHTERED IN ESTABLISHMENTS INSPECTED UNDER THE MEAT INSPECTION REGULATIONS, 1990

TABLE OF CONTENTS

DEFINITIONS

SECTION 1 - INTRODUCTION

SECTION 2 - CATTLE IDENTIFICATION, AGE DETERMINATION, MARKING AND SEGREGATION OF CARCASSES

SECTION 3 - STUNNING, DRESSING, CUTTING/BONING AND SRM REMOVAL

SECTION 4 - SRM HANDLING AND DISPOSITION

SECTION 5 - SRM CONTROLS

APPENDICES:

Appendix A Diagrams: Cattle Dentition

Appendix B Diagrams: Cattle Vertebral Column

Appendix C Diagrams: Cattle Gastrointestinal Tract

Appendix D Identification Mark: Carcass Of Cattle Aged 30 Months or Older

Appendix E Cattle And Bison Breed Associations

DEFINITIONS

For the purposes of this policy:

1.0 INTRODUCTION

The Canadian government has adopted this policy on the removal of Specified Risk Materials (SRM) from cattle slaughtered in Canada in order to prevent tissues that may contain BSE infectivity from entering the human food chain.

Every operator involved in the slaughter of cattle and/or the cutting/boning of bovine carcasses/quarters, shall implement the practices described in this annex, as required.

1.1 POLICY SUMMARY

The purpose of this document is to describe the minimum standards that beef slaughter and cutting/boning establishments must meet in producing dressed carcasses, cuts and deboned products.

The standards are designed to meet the following objectives:

(1) to ensure removal of all specified risk materials (SRM); and

(2) to prevent cross contamination of edible meat products by SRM during slaughter and cutting/boning operations.

1.2 HACCP PLANS

Operators are required to reassess their HACCP plans to ensure the hazard associated with SRM (i.e. BSE infectivity) is identified on Food Safety Enhancement Program (FSEP) Form 5 (or equivalent). Critical Control Points (CCPs) are clearly identified for animal aging (either by dentition examination or birth date documentation) and SRM removal. The operator is responsible for the development, implementation, and maintenance of control programs that address all components of this SRM removal policy. These control programs are to be reviewed and approved by the Veterinarian-in-Charge (or inspector in charge as is appropriate) and their implementation must demonstrate ongoing and effective control, including but not limited to, control over animal identification and aging, OTM carcass identification and marking, SRM removal and OTM meat segregation and labelling. If these requirements are not fully met by the operator, the Veterinarian-in-Charge or Inspector-in-Charge will review the situation and will take appropriate compliance action.

1.3 EXPORT REQUIREMENTS

In order to export beef and bison products to certain countries, the operator may be subject to other restrictions and required to implement different or additional controls and procedures regarding SRM than the ones described in this annex. For more information consult the appropriate importing country’s section in Chapter 11 of this manual. In order to export to the United States beef or bison refer to Annex Z.

1.4 EFFECTIVE DATE OF THE SRM POLICY

This policy came into effect on July 24, 2003. Subsequent amendments are effective on the date of publication of the associated Meat Hygiene Directive.

2.0 CATTLE IDENTIFICATION, AGE DETERMINATION, MARKING AND SEGGREGATION OF CARCASSES

Operators slaughtering UTM and OTM cattle should make every effort to slaughter OTM at the end of the slaughter shift. These operators must also establish procedures for identifying and separating these two types of cattle.

At the slaughter establishment the identity of the cattle carcass and all its parts must be maintained until their final disposition is known. To achieve this, the Canadian Cattle Identification Agency (CCIA) and Agri-traccabilite Quebec (ATQ) ear tag shall be attached, after its insertion into a plastic bag, to the fore shank of the carcass following hide removal. Alternative procedures that assure, with equal confidence, maintenance of the identity of the carcass and all its parts until their final disposition is known, may be approved by the veterinarian in charge.

2.1 AGE DETERMINATION, IDENTIFICATION AND MARKING OF CARCASSES

Operators are required to reassess their HACCP system and to develop a Critical Control Point (CCP) for age determination procedures (i.e. by date of birth documentation review and/or dentition examination). CFIA inspectors audit the company’s HACCP system as per the FSEP verification protocol.

For the purposes of this policy, the age of cattle can be established by using reliable documentation that indicates the birth date of the animal or by examining the teeth. The documentation described below, rather than dentition, provides the best means for determining the age of cattle. When documentation is available it shall be used as the primary means of determining the age of animals.

Operators must maintain records of the age and identity of slaughtered cattle. The records shall include information regarding the procedures used to determine the age of animals. If age is determined by documentation, the document shall be maintained with the records for a period of 2 years from the date of slaughter.

Determining age by birth date documentation:

Submission of accurate birth date information by producers is strongly supported by the Canadian Food Inpection Agency (CFIA). Birth date information in the national Canadian Cattle Identification Agency (CCIA) database, or the Agri-Traçabilité Québec (ATQ) database in the case of Québec, is accepted by the CFIA as an alternative to dentition for domestic meat inspection purposes, and live animal or meat exports. The availability of birth date information on a timely basis will mean that dentition assessment should not be necessary.

CFIA also recognizes the original copies of official birth date documents issued by Registered Breed Associations. The registered breed associations include associations established under the Canadian Animal Pedigree Act. See appendix E for a complete list of Canadian Registered Breed Associations or consult the following web site: http://www.agr.gc.ca/misb/aisd/redmeat/associations.pdf

Acceptable methods for determining the age of an animal in the CCIA or the ATQ database include either the actual date on which a calf is born or the first day of the calving period in which a group of calves was born. In cases where "estimated " birth dates are provided based on other methods, the date of birth is not to be accepted, and dentition will be used for aging.

As part of antemortem inspection procedures, CFIA inspectors will examine birth date documentation used by the operator for determining the age of cattle. If the veterinarian in charge concludes that the document is accurate and reliable, the document will be accepted as verification of the age of the cattle. However; if the veterinarian in charge finds significant reasons for questioning the validity of the document, the cattle in question will be processed as a lot and the document will be further verified in consultation with the original issuing authority. If verified by the issuing authority, the lot is released. If the lot can not be verified by the issuing authority, then dentition will be used for age determination. The producer who supplied the birth date information to either the CCIA or ATQ will be identified to the Chief Livestock Identification for possible auditing actions.

Similarly if an animal's birth date documentation has been deemed acceptable on AM inspection but at head inspection by CFIA, a head is observed where the fifth permanent tooth is above the gum line, the animal will be deemed an OTM and will be treated accordingly. The producer will be identified to the Chief Livestock Identification for possible auditing actions.

Loss of identification or no identification will result in the animal being aged by its dentition.

Determining age by dentition examination when no birth date documentation is provided:

For the purposes of this policy, cattle are considered to be aged 30 months or older when they have more than two permanent incisor teeth erupted (i.e. the first pair of permanent incisors and at least one tooth from the second pair of permanent incisors).

Note:

For the purpose of this policy, a permanent tooth is considered erupted when any part of the tooth is protruding through the gum. This will include teeth that have erupted behind or in front of the existing deciduous incisor. Cattle will be considered as less than 30 months of age as long as the erupting third permanent incisor is not above the surface of the gum. See Appendix A of this annex for diagrams of bovine incisor teeth and the corresponding age.

Visual examination of the incisor teeth of each carcass must occur at or before the head inspection station.

The operator examines the incisor teeth of each carcass, and determines if the carcass is derived from an animal aged 30 months or older. Plant personnel examining the teeth must be able to recognize permanent incisor teeth and be knowledgeable of this policy. Alternatively the operator may decide to treat all slaughtered animals as being derived from animals aged 30 months or older. In such a case, examination of the incisor teeth would not be required.

CFIA verifies the effectiveness and accuracy of age determination performed by the operator by examining the incisor teeth of all carcasses of cattle during the inspection of the head. The CFIA is to record errors in age determination by plant personnel and immediately notify the operator.

Identification and marking of carcasses:

The identification and marking of both sides of the carcasses of animals 30 months or older must be done as soon as possible after the carcass has been aged. The operator shall apply one of the marks described in Appendix D by means of a stamp (i.e. using blue edible ink) to each side of the OTM carcass. The mark must be visible to the employee responsible for splitting carcasses in order to ensure the use of appropriate splitting saw . When a single saw is used for splitting all carcasses, it shall be cleaned and sanitized after splitting an OTM carcass if it is to be subsequently used to split a UTM carcass.

Control and identity of the carcass, head and parts must be maintained. The head is identified as OTM by means acceptable to the Veterinarian-in-Charge.

The operator must apply edible blue ink to exposed surfaces of the vertebral column of each OTM carcass side following removal of the spinal cord and before chilling. For proper identification the operator he shall ensure to apply edible blue ink to the vertebral canal and may include the vertebral body however, the dorsal apophyses (finger bones) should not be stained with ink as it compromises grading. All vertebrae including the sacrum must be stained with blue edible ink in order to achieve a readily visible mark at the time of Cutting/boning

Application of the blue ink to the vertebrae shortly after the carcass has exited the carcass wash, must only occur when the plant has a written program in place which has been approved by the Veterinarian-in-Charge that can demonstrate ongoing effective controls, including a carcass identification and marking system that will ensure all OTM carcasses are properly identified and marked.

Operators of slaughter establishments may be able to reduce or eliminate the need for certain requirements under this part providing the same outcome is achieved. For example, an operator may decide to treat all slaughtered cattle, or cattle slaughtered from a particular lot, as being derived from animals aged 30 months or older (OTM). In such a case, SRM would be removed from all carcasses regardless of their age and there would be no need to examine incisor teeth for the purpose of age determination. However there would still be a requirement to apply one of the marks described in Appendix D by means of a stamp to each carcass side if the operator also slaughters UTM. Every vertebral column of OTM carcasses must be marked and stained as per the above requirements.

2.2 CONTROL AND SEGREGATION OF CARCASSES DURING DRESSING, CHILLING, CUTTING AND BONING PROCEDURES

Slaughter Establishments

Operators of federally inspected establishments that intentionally slaughter cattle aged 30 months or older are required to schedule their slaughter in a definable group at the end of the production day, in order to facilitate operational control and verification of SRM removal.

For the same reasons, operators of all federally inspected slaughter establishments are required to visibly group the carcasses of cattle aged 30 months or older in the chiller and to schedule the cutting/deboning of such carcasses at the end of the production day. Alternatively, an operator of a federally inspected establishment could remove the carcasses to another federally registered establishment for cutting/deboning.

Operators of all federally inspected slaughter establishments are required to track the number of OTM cattle slaughtered in the establishment. The number of OTM cattle must 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.

Cutting/Deboning Establishments

Operators of cutting/deboning establishments that receive carcasses/sides/quarters of OTM cattle are required to develop and implement written procedures to maintain the identity of these products until the vertebral column is removed and disposed as inedible product. The procedures must include:

1. recording of the number of OTM carcasses sides/quarters received and reconciliation this number with the number of OTM carcasses deboned and cut-up; and
2. cutting/deboning of such carcasses/sides/quarters at the end of the production day.

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

3.0 STUNNING, DRESSING, CUTTING/BONING AND SRM REMOVAL

3.1 Operational sanitation and use of tools dedicated to cattle 30 months and older (OTM)

The operator must use, except as detailed later in this section, dedicated tools (e.g. knife, steel, saw), identified by colour-coding or other visual system, for all procedures involving the incision, direct or indirect handling of the tissues designated as SRM.

Exceptions:

Due to plant design some slaughter establishments are unable to determine the age of a cattle by visually examining the dentition prior to head removal from the carcass. For the head removal process in these plants a non-dedicated knife is used to cut most of the muscles and connective tissue attaching the head to the carcass. This results in partial separation of the head at the junction of the occipital condyles and the first cervical vertebrae. A dedicated, uniquely identified knife (e.g. colour coded) is used to sever the spinal cord and is rinsed and sanitized after each animal (OTM and UTM) then a non-dedicated knife is used to complete the removal of the head. Both knives are adequately rinsed and sanitized after each animal.

In the case of the carcass splitting saw and the quarter band-saw the operator has the option to use either a dedicated equipment or to ensure that the equipment used on OTM cattle carcasses is cleaned and sanitized before being used on UTM cattle carcasses or on carcasses and parts of carcasses of other food animal species. The level of cleaning required is equivalent to what is required when the carcass splitting saw becomes contaminated i.e. the organic material must be removed to ensure adequate sanitation.

Specialized spinal cord removal equipment, including vacuums and hand tools can be used on all age categories of cattle; however, they must be uniquely identified (e.g. colour coded) and dedicated to this purpose. If used before final carcass inspection, specialized spinal cord removal equipment must be sanitized between each carcass. If used after carcasses have been approved, they must be sanitized as required and after each time they are used on an OTM cattle carcass before being used on UTM cattle carcasses or on carcasses of other food animal species.

3.2 STUNNING

As per section 4.4.5 of this manual, the use of a penetrating percussion device which injects air into the cranial cavity or the use of pithing rods are not permitted.

The operator must develop and implement an effective control system to collect brain tissue that has been externalized during the stunning process. This control system must include measures to ensure brain matter does not enter or contaminate meat products, animal food products ( i.e. hides saved for gelatin or collagen, blood salvaged for edible and/or animal food including blood meal).

Brain tissue that has fallen on the floor must be discarded as SRM. Head hide is assumed to be contaminated with brain tissue and must be discarded as SRM when a penetrating percussion device is used. Further leakage of brain tissue must be controlled. This is especially important after the hide has been removed. Special care must be taken to ensure the carcass and head are not contaminated with brain tissue during skinning and handling.

3.3 HEAD SEPARATION AND REMOVAL OF SKULL, BRAIN, TRIGEMINAL GANGLIA, EYES AND TONSILS

The skull including the brain, trigeminal ganglia, eyes, palatine tonsils of cattle aged 30 months or older are SRM and must be disposed of as inedible products. The removal of the head must be achieved without contamination of the carcass or other meat products with SRM ( i.e. spinal cord, brain) or other contaminants. The operator must take measures to prevent the contamination of edible products (head meat and tongues for example) by Specified Risk Materials.

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 in an inedible container of suitable dimensions to prevent subsequent contact between the SRM head and any other meat products. Boning of the occipital area of the head including the area around the foramen of magnum of cattle aged 30 months and older is not permitted.

3.4 PALATINE TONSILS

Palatine tonsils are removed from the head of all cattle during the preparation of the head for inspection (see section 4.5.1 of this manual). Palatine tonsils are considered inedible material for cattle of all ages, and SMR for cattle aged 30 months or older.

3.5 TONGUE AND CHEEK MEAT

The removal of the tongue, cheek meat and other edible portions must be achieved without contamination of the carcass and other edible meat products with SRM (e.g. spinal cord, brain) or other contaminants.

3.6 REMOVAL OF THE DISTAL ILEUM

In order to ensure complete removal of the distal ileum, the entire small intestine of all cattle regardless of their age must be removed and disposed of as inedible product. Best practice is to dispatch the small intestinal contents with the small intestine. If the large intestine is salvaged there must be a control program in place that identifies the landmarks for the portion being salvaged. See Appendix C of this Annex.

3.7 CARCASS SPLITTING

The carcass split saw should separate the vertebral column in the midline to facilitate removal of the spinal cord. If the saw is equipped with an automatic rinse system, the exhaust water must be ducted away from carcasses and other edible products. The water-exhaust effluent should be adequately trapped. The trap should be emptied, cleaned and renewed as and when necessary. All residue should be treated as SRM and should be emptied into an inedible container.

The operator shall immediately identify any incorrectly split carcasses and ensure that the spinal cord is properly removed in the evisceration area. Incorrectly split carcasses will not be approved by CFIA until the spinal cord is properly removed. The operator must take appropriate corrective measures to prevent the occurrence of incorrectly split carcasses.

3.8 REMOVAL OF SPINAL CORD AND ITS VERIFICATION

The spinal cord of OTM cattle is a SRM and must be removed in its entirety prior to stamping of the carcass sides with the meat inspection legend before the carcass leaves the kill floor. Lifting the spinal cord out of the vertebral canal can be achieved using a knife. Other specialized tools can be used, but chain link gloves are not suitable due to the increased risk of gross cross-contamination.

The spinal cord of UTM cattle is not designated as a SRM but, nevertheless, must still be completely removed from all split carcasses on the kill floor before the final carcass wash. In the case of carcasses that are split after chilling (veal carcasses), the spinal cord must be removed during boning/cutting operations if the vertebral column is split in a federally inspected establishment. It is required to prevent incorporation of spinal cord tissue into any meat products (adulteration), ensuring compliance with established meat product standards and simplifying verification measures.

Operator verification of the complete spinal cord removal is one of the most important control point. The operator must make a thorough check of every carcass to ensure that no remnants of spinal cord are present before the carcass is marked with the meat inspection legend. This check must be performed for each carcass side. When any spinal cord remnant is discovered, the carcass must be retained for immediate rework by the operator (ie zero tolerance policy applies).

3.9 REMOVAL OF THE DORSAL ROOT GANGLIA

It is the operator's responsibility to ensure SRM is not incorporated into any edible meat products. The dorsal root ganglia must be removed, designated as a SRM, and disposed of as inedible material. 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 the dorsal root ganglia, the vertebral column of OTM cattle excluding the vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae, and the wings of the sacrum must be removed and disposed of as inedible material. Cutting and boning procedures used to remove the OTM vertebral column shall not cause the removal of the dorsal root ganglia with the edible muscle tissue. As a best practice, the cut separating the edible muscle from the vertebral column should be made one inch from the vertebral arch to ensure no dorsal root ganglia is inadvertently included with the edible meat.

OTM carcass sides or quarters with the vertebral column attached (i.e. dorsal root ganglia not removed) can be shipped FROM A FEDERALLY REGISTERED SLAUGHTER ESTABLISHMENT TO ANOTHER FEDERALLY REGISTERED ESTABLISHMENT if the following controls are in place. Shipping OTM carcass sides or quarters with the vertebral column attached to non-federally registered facilities is not permitted.

Slaughter Establishments:

Slaughter establishments that do not remove the dorsal root ganglia from vertebral columns on-site will have to implement identification and shipping controls system satisfactory to the Veterinarian-in-charge. The controls shall include written confirmation that the receiving plant has a verifiable control system in place and a system to notify the Inspector-in-charge of the receiving cutting/boning establishment (i.e. where the removal of the vertebral column will take place) regarding the number of carcasses sides or quarters to be expected.

Receiving Establishments:

The receiving establishment must have a verifiable control system in place which will demonstrate to the satisfaction of the Inspector-in-charge that the sections of the vertebral column containing the DRG are removed and appropriately disposed of as inedible material. The receiving establishment must also advise the slaughter establishment of the number of OTM carcasses that they have received.

Note:

The vertebral column of cattle aged 30 months or older, must not be used as raw material in the preparation of mechanically separated meat or finely textured meat.

3.10 VERIFICATION BY THE OPERATOR OF SRM REMOVAL AND REWORK

The operator must verify the complete removal of all SRM. Any carcass or part that is found to be harbouring fragments of SRM (e.g. spinal cord) must be retained by the operator for rework and subsequent presentation for further examination by the operator. The operator 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 operator must demonstrate control of the system at all times.

4.0 SRM HANDLING AND DISPOSITION

This section describes effective separation of SRM from the carcass, provisions for storage of SRM and hygienic standards associated with floor waste and inedible containers. Because of structural differences between establishments, procedures for separating and isolating the various SRM may vary. Generally, separation of SRM should occur as soon as possible and care must be taken to avoid gross contamination of meat products and the establishment environment by SRM.

4.1 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 inedible containers without delay and regularly moved to the inedible products area. This must include all SRM separated from the carcass, SRM from the floor and gross SRM debris. Basic principles of hygiene must be observed at all times.

4.2 FLOOR WASTE

Areas where SRM are removed or handled must be regularly attended to by plant employees assigned this function. Systems for containing gross debris and operational cleaning of these areas is important. SRM shovelled or squeegeed from the floor and any SRM debris collected from the channels and drain covers/traps must be deposited in an inedible container. Collection of SRM from drain covers and traps must occur daily.

4.3 SRM CONTAINERS

It is important that all SRM and debris are contained within leak proof inedible containers.

4.4 CLEANING OF SRM CONTAINERS

All equipment and containers used in the handling of SRM shall be cleaned and sanitized after being emptied and prior to reuse. Inedible containers must at all times be acceptably clean. If inedible containers are being returned by a rendering company in an unclean state they shall not be used until they are cleaned and sanitized. Cleaning of inedible containers should not occur in area where potential contamination of the meat products may occur. The cleaning and sanitizing of inedible containers should be an integral part of the cleaning schedule of the premises, and verified during the pre-operational inspection.

5.0 SRM CONTROLS

The operator is responsible for the development, implementation, and maintenance of documented control programs that address all the components of this SRM removal policy including antemortem, age determination, carcass identification and SRM removal. The control programs must ensure compliance with the relevant provisions of the Meat Hygiene Manual of Procedures (MOP), the Meat Inspection Regulations, 1990 and the Health of Animals Regulations with respect to the control and disposition of bovine SRM and inedible material, including animals that are found dead on arrival or die from the causes other than the slaughter in the establishment. Operators which have implemented a HACCP system are required to reassess and to modify their HACCP system so the hazard of BSE is clearly stated and CCPs are added at least for animal aging, identification, and for SRM removal.

All appropriate staff including supervisors and managers must have general and current knowledge of the potential risk of BSE to the human population as well as the risk to the national cattle herd. The operator and all staff should have demonstrable knowledge of the establishment’s SRM control programs and be able to demonstrate with accurate records that the SRM controls they have put in place, have been implemented in practice, resulting in full compliance with the regulations and policy requirements. The operators SRM control programs must be auditable and verifiable.

CFIA staff shall verify the operator’s full compliance with all relevant regulations and this policy through the completion of relevant MCAP tasks (inspection or audits) and other inspection records as required.

APPENDIX A

Cattle Dentition

[D]

Cattle Dentition
Figure II

Extracted from: FSIS Notice 5-04, January 12, 2004

[D]

Cattle Dentition
Figure III

Extracted from: FSIS Notice 5-04, January 12, 2004

[D]

APPENDIX B

Cattle Vertebral Column
Figure I

[D]

Extracted From
Sisson and Grossman’s
The Anatomy of the Domestic Animals - Volume 1

Cattle Vertebral Column
Figure II

Note: The Dorsal Root Ganglia may protrude from the intervertebral foramen into the space that lies between the body and transverse processes of adjoining vertebrae. The ribs are attached to shortened transverse processes in the thoracic region. Extracted from: Sisson and Grossman’s, The Anatomy of the Domestic Animals - Volume 1

[D]

Cattle Vertebral Column
Figure III

[D]

Appendix C

Cattle Gastrointestinal Tract
Figure I

Gastrointestinal tract of cattle laid out in one plane.

Extracted from: Dyce, Sack and Wensing’s, Textbook of Veterinary Anatomy, 3rd edition

[D]

Appendix D

Identification Mark: Carcass of Cattle Aged 30 Months or Older

Appendix E

Cattle and Bison Breed Associations incorporated under the Animal Pedigree Act

For a complete list of Canadian Registered Breed Associations consult the following web site: http://www.agr.gc.ca/misb/aisd/redmeat/associations.pdf