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CHAPTER 3 - Sanitation

3.4 Responsibility of the inspector

Inspectors are responsible for reviewing and approving the sanitation program developed by plant management. They are further responsible to monitor the implementation of the sanitation program carried out by plant management.

The implementation of control programs by the inspector will be greatly improved if a spirit of cooperation can be developed with a plant management which recognizes the benefits that accrue from an adequate sanitation program.

Action must be initiated by the inspector where plant and equipment sanitation is found unsatisfactory. The type of action may vary from a simple request for rectification of a deficiency to suspension of operations in a room or even an entire establishment. The action must be based on the magnitude of the problem and the associated risk to the integrity of product.

3.5 Control mechanisms and procedures

Control mechanisms must be implemented whenever there is a justifiable and identified need. However, they should be applied in a uniform and consistent manner.

It is not possible to describe or delineate all the control mechanisms or procedures that may be utilized in the monitoring of a plant's sanitation program. Those we implement have been developed through a practical application of check systems that assure an environment suitable to the production, handling and processing of a wholesome meat product. The frequency and severity of application have a direct relation to the degree of risk involved, the past history of compliance and possible changes or variations in operating procedures.

Control should not be limited to those systems that have been historically developed in the field of meat hygiene but should be viewed as a dynamic and challenging opportunity to review the packing house environment as it relates to the production of acceptable products, with a view to developing modified or new procedures that will facilitate the monitoring of a sanitation program. It is imperative to review a control mechanism or procedure based on the three questions as follows:

Is it necessary? Is it effective? Should it be modified?

A positive analysis and response to these three questions tend to assure the credibility of a monitoring program.

3.6 Potential contamination sources

A control program is this area of sanitation requires a knowledge and understanding of the total environment in which meat products are handled. It further requires keen observation and constant review to assure that environmental influences have not arisen that could adversely affect the acceptability of the product. Look up, look down and look around, and examine the product itself.

3.6.1 Paint, dust, rust, condensation and disintegrating insulating material

The above is a partial listing of contaminants or hazards. This type of contamination can fall on or into product, equipment and packaging material. The sanitation program requires an ongoing campaign of good maintenance which will eliminate peeling paint, dust, rust, condensation and disintegrating insulating materials. Where overhead structures are so affected, it may be necessary to restrict the use of a room or an area. Equipment so affected must be withdrawn from use, until brought back into a satisfactory state.

3.6.2 Metal contaminants

Staples used for box forming operations are a real source of contamination. Box forming operations shall not be performed in close proximity to open containers of meat. Tag fasteners or skewers must be removed after serving their function and before carcasses are cut or boned.

At no time are cleaning aids such as wire brushes or steel wool, to be used on meat products. It is further understood that they are not to be used in productions areas of a registered establishment, when meat products are present.

Metal contaminants may come from a multitude of other sources and may include the following: friction of metal hooks on overhead rails, beads and pieces of slag from welding equipment, poorly welded equipment, broken and worn equipment, can openers and containers, metal hangers, loose strapping, wires, etc.

3.6.3 Equipment or substances which generate gases or odours

The use of metal detectors should be encouraged in order to alert all concerned to the presence of metallic foreign material. The presence of metal in meat product is a serious situation which calls for a careful review of meat handling practices from slaughter through shipping of the product. Every effort must be expended to establish the source of the problem in order to rectify same.

Certain equipment and substances which generate gases or odours may have received approval for use from the Meat and Processed Animal Products Division. In many instances this approval has been conditional on a particular location, venting system or use. Other types of equipment such as mechanized vehicles do not require such approval.

Inspectors must satisfy themselves that, in the case of the former group, the conditions are complied with and that in all instances the use of equipment and substances does not create a hazard to personnel, nor to meat products.

3.6.4 Other types of contaminants

These may include, but are not restricted to, the following: broken glass, packing paper, packing film, wood splinters, etc. Prevention consists of forbidding the use of glass, other than the product containers, in a processing area, the adequate defrosting of meat blocks in order to preclude the retention of wrapping paper and plastic films; assuring that the internal surfaces of meat transport vehicles are intact and free of wood splinters, that wooden skewers are not used as neck pins, etc. Any type of contamination requires a serious investigation on the part of management, in cooperation with inspection personnel, to establish the cause and to rectify same.

Only those cleaning agents, disinfectants, protective oils and lubricants which are listed in the "Reference Listing of Accepted Construction Materials, Packing Materials and Non-Food Chemical Products" may be used, (visit our Website: http//www.inspection.gc.ca/reference/conteng.html). Where necessary, there must be adequate rinsing off of cleaning agents and disinfectants, and in addition, equipment surfaces subject to food contact must have all protective oil removed prior to use.

Care must be taken that machinery and equipment lubricants do not contact or enter edible products in any manner. Much will depend on the placement of equipment such as motors. Plant maintenance personnel must be made aware of their responsibility in this facet of their work.

3.6.5 Packaging material

Only those packaging materials which are listed in the "Reference Listing of Accepted Construction Materials, Packing Materials and Non-Food Chemical Products" may be used, (visit our Website: http//www.inspection.gc.ca/reference/conteng.html). Unlisted packaging materials may contain toxic ingredients that may migrate to meat food products.

It is further required that the use of packaging materials be constantly reviewed from a functional standpoint. They must protect the product and not disintegrate, tear, etc. and thus, in themselves, become a contaminant.

Cardboard containers must be stored and handled in a manner that minimizes contamination with dust, etc., and prevents contamination with liquids.

When packaging exposed meat products into unwaxed cardboard containers, liners must be used and every effort must be made to prevent the meat products from coming into contact with the exposed surfaces of the containers. When waxed cartons are used, contact with the external surfaces should be avoided.

The packaging of exposed meat products into cardboard containers should not result in the external surfaces of the containers becoming stained with blood or fat.

3.6.6 Control of wooden pallets in registered establishments

Essentially, wooden pallets are permitted for use primarily in freezers and dry storages.

The restriction results from the fact that wood is pervious to liquids and therefore difficult to clean.

It is, however, realized that pallets must be loaded, unloaded and moved into areas, other than freezers and dry storages. This means that adequate control and judgement must be exercised to maintain the pallets free of contamination and damage which can adversely affect the level of sanitation in an establishment.

In view of the above, the onus rests with management to utilize pallets in a manner and in areas which prevent the creation of an unsanitary state; on this matter, also refer to section 4.10.4 of this Manual ("Storage of Palletized Meat Products").

Plant management must ensure that pallets are in good repair and clean before use. In some cases, where problems are encountered, the use will require restriction or change to appropriate alternate equipment.

3.6.7 Use of products with volatile substrates

Certain paints, floor sealants, etc. contain a volatile element which may transfer an odour or chemical contamination to meat products. It is essential that areas treated with such products be adequately ventilated during and after the drying period, before meat products are permitted to enter those areas. It is recommended that the areas be closed off for a few hours, then a check for odours be made to ensure that complete dispersion has occurred.

3.7 Pre-operational inspection

As indicated earlier in this chapter, plant management is responsible for all aspects of quality control including the pre-operational inspection of all production areas. Management must assure that sanitary standards are met prior to permitting the commencement of operations.

The Meat Hygiene personnel monitors the effectiveness of management's sanitation program by periodically conducting inspections of the premises, facilities and equipment. The responsible inspector checks if control is being exercised over the environmental influences which may adversely affect meat or meat products processed therein.

The frequency of monitoring of the sanitation program will be based on the known credibility of management to assume and perform their responsibilities.

Room temperatures where refrigeration is a requirement must be at a correct level before the commencement of operations. A room temperature should, at this stage, be below the required level, since the movement of personnel into the room, plus their own body heat and the operation of sanitizers will cause the room temperature to rise.

Product contact zones are of immediate importance and would include table surfaces, equipment e.g. saws, and the interior of equipment. The latter shall be dismantled for ease of cleaning and not reassembled for use prior to receiving a pre-operational sanitary inspection.

Room surfaces such as floors, walls, ceilings and overhead fixtures are next in importance and must be maintained free of cracks and of rust, dust, and other extraneous material in addition to reasonable housekeeping practices. Condensation forming above product areas is not acceptable and this item must be covered on the pre-operational inspection.

The external and under-surfaces of equipment, such as product trucks, emulsifiers, mixers, etc., shall be examined for cleanliness. Such surfaces, if unclean, can serve as ready reservoirs for product contamination.

The sanitation of employees' equipment, which may include knives, steels, hooks, mesh gloves, aprons, etc., is another responsibility of management. Sanitizers must be checked for the ability to function correctly at the required temperature.

It is to management's advantage to institute a check of effectiveness of their sanitation program by the use of bacteriological methods of review: e.g., Millipore, Swab Test or total plate count.

Where deviations from accepted norms are found, management shall initiate the required action to remedy the situation. If the problem is not corrected, the use of equipment and/or facilities could be denied.