SOP-PL-024 SRM Control Procedure

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Document No.

: SOP-PL-024
Document Name: SRM (Specified Risk Material) Control
Revision Date: January 18th 2024
Approved by: HACCP Team
P a g e | Page 1 of 11

1.0 SCOPE / PURPOSE


To ensure removal of all specified risk materials (SRM’s) as defined by CFIA in the “Guidance on Specified risk
material (SRM)” under Canadian requirements and the importing countries that which the product is sent.

Refer to CCP-PL-001 Lot Determination for Definitions and different SRM Risk Levels.

2.0 DEFINITION SRM BY COUNTRY


2.1 CANADA
Bison is not considered to contain SRM according to Canadian regulations [1].
Crosses of Bison are considered to contain SRM and are subject to BSE control.
The CFIA defines SRM as:
 Carcasses under 30 months: distal ileum
 Carcasses over 30 months: The skull, brain, trigeminal ganglia, eyes, tonsils, spinal cord, dorsal
root ganglia, and distal ileum.
 Condemned animals and dead stock, containing SRM. Any inedible material that is mixed with
SRM, such as floor waste or recovered solids from waste water, must also be treated as SRM.
DD
2.2 UNITED STATES OF AMERICA
According to the CFIA Export Requirements Library for the USA: Annex Z: Conditions Relative to BSE Controls”
Bovine: Bos taurus, Bos indicus and Bison.
Offal (APHIS definition): the inedible parts of a butchered animal that are removed in dressing,
consisting largely of the viscera and the trimmings, which may include, but are not limited to,
thymus, pancreas, liver, heart, kidney, intended for use other than for human consumption (e.g.,
pet food manufacturing, technical use, rendering).
Specified Risk Material (SRM) as defined by the USDA-FSIS includes: the brain, skull, eyes,
trigeminal ganglia, spinal cord, vertebral column (excluding the vertebrae of the tail, the
transverse processes of the thoracic and lumbar vertebrae and the wings of the sacrum) and
dorsal root ganglia of bovines 30 months of age and older, and the tonsils and the distal ileum of
all bovines.
According to the USA Regulations:
310.22 Specified risk materials from cattle and their handling and disposition.
(a) The following materials from cattle are specified risk materials, except when they are from
cattle from a country that can demonstrate that its bovine spongiform encephalopathy (BSE) risk
status can reasonably be expected to provide the same level of protection from human
exposure to the BSE agent as prohibiting specified risk materials for use as human food does in
the United States:
(1) The brain, skull, eyes, trigeminal ganglia, spinal cord, vertebral column (excluding the
vertebrae of the tail, the transverse processes of the thoracic and lumbar vertebrae, and the
wings of the sacrum), and dorsal root ganglia from cattle 30 months of age and older and
(2) The distal ileum of the small intestine and the tonsils from all cattle.
(b) Specified risk materials are inedible and prohibited for use as human food.
(c) Specified risk materials must be removed from the carcasses of cattle, segregated from
edible materials, and disposed of in accordance with § 314.1 or § 314.3 of this subchapter. The
spinal cord from cattle 30 months of age and older must be removed from the carcass at the
establishment where the animal was slaughtered [2].

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Document No.: SOP-PL-024
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Revision Date: January 18th 2024
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2.3 SRM in Exotic Species (Bison & Elk)


According to the USDA the SRM definition above applies only to cattle and not to the exotic species (Bison) [3].
[4]
As there is currently a discrepancy between Canadian Guidance documents and the USDA regulations on the
requirements for SRM control on Bison, the Canadian regulations will be followed as a precautionary measure
as they are stricter than the USDA regulations.

2.4 EUROPEAN UNION

According to the CFIA Export Requirements Library for EU as per 2015/728 regulation: -

(a) For Bovine animals:


(i) the skull excluding the mandible and including the brain and eyes, and the spinal cord of animals aged over
12 months;
(ii) the vertebral column excluding the vertebrae of the tail, the spinous and transverse processes of the cervical,
thoracic and lumbar vertebrae and the median sacral crest and wings of the sacrum, but including the dorsal
root ganglia, of animals aged over 30 months; and
(iii) the tonsils, the intestines from the duodenum to the rectum and the mesentery of animals of all ages.

Note: For EU Eligible Cattle


I. The skull including the brain and eyes, the tonsils and the spinal cord of animals aged over 12 months
or which have a permanent incisor erupted through the gum
II. The spleen and ileum of animals of all ages.

2.5 JAPAN

According to the CFIA Export Requirements, Annex F (Export Beef product to Japan) is considered SRM and to
be hygienically removed:

 the tonsils and distal ileum from cattle of all ages


 the head (excluding tongue and cheek meat), spinal cord and vertebral column (excluding vertebrae of
the tail, the spinous and transverse processes of the cervical, thoracic and lumbar vertebrae and the
median sacral crest and wings of the sacrum) from cattle older than 30 months of age

2.6 BEC SRM Policy


BEC has implemented a strict SRM control procedure that meets or exceeds all of the standards listed above.
SRM identification at BEC is implemented per Lot Determination (CCP-PL-001)

3.0 PROCEDURE
Responsibility: Kill floor Supervisor/personnel

Frequency: Every day Bovine animals processed

Procedure:

3.1 SRM in dressing/processing


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1. Shackling - Post-stunning (Refer to JTP-KF-001)


For Cattle only:-
 If fire arm used: Application of edible grease to the knocking hole is required.
 If a captive bolt is used: It must be washed and sanitized immediately after use. And edible grease
must be applied to fill hole.

In the event if there is leakage of the brain matter employee will immediately cover the nostrils up to the
Masseter with a self-cinching plastic bag (i.e., clean bung bag). The employee must wash and sanitize
himself and any other contaminated equipment after removal of externalized brain tissue.
If visible brain material is seen, it must be removed from the face plate by trimming, washing, or
scraping. The equipment used to remove it must be fully sanitized, and brain material collected put into
an SRM container, that will be disposed accordingly afterwards.

The distinct color of knife is used. Refer to program SOP-PL-017 Knife Control.

2. Bleeding (Refer to JTP-KF-002)


In order to collect all blood as inedible food, it is important that the edible grease is applied properly after
stunning, to avoid cross contamination caused by drips of brain material into blood pit.
To collect blood as edible, it is preferred to use a hollow knife or cannula.

3. Head Removal (Refer to JTP-KF-013)


 A designated SRM Blue handled Knife for OTM(Cattle) and white handled for UTM (Cattle, Bison,
Yak) is used to cut only spinal cord
 The remaining flesh is then cut with a knife designated for cutting meat.
 Both knives and hooks (as required) are washed and sanitized.
 In the case of Class 1 and Class 2 animals (UTM by dentition), defined by CCP-PL-001 Lot
Determination, employee will confirm if animals are OTM or UTM by performing dentition (OTM if
have 3 erupted or full incisors/ in case of no birth certificate and 5 incisors in case of Birth
Certificate). OTM will be identified by putting a “3” stamp, spray the head with blue ink for identifying
animals in the rest of the dressing.

4. Head Wash (Refer to JTP-KF-014)


 Normal head washing and preparation procedures are conducted prior to CFIA inspection.
 Tonsils from all age’s carcasses are removed from head. Special care will be taken while removing
the tonsils that none are left connected to the tongue.
 UTM tonsils (Cattle, Bison and Yak) will be harvested with designated white knife and disposed off
as inedible.
 OTM tonsils (Cattle only) will be harvested with a dedicated blue SRM knife, and removed as SRM.
In case of Bison and Yak it will be removed and disposed off as inedible.

5. Head Offal Collection (Refer to JTP-KF-015)


 The tongue will be cut off at such a point or proximity to the “vallate papillae”, to include the lingual
 The entire head is disposed of, immediately by placing it in the inedible auger. In case of OTM and
Incidental OTM confirmed animal, the head is disposed of immediately by placing it in the SRM meat
auger.
 In case of Incidental Cattle carcasses only when addition head meat is harvested, it is prohibited to
harvest the meat from the occipital and the foramen magnum.

In case Class 3 animals designated run: Application of blue paint to the head is not required as the
head chute will remain in SRM position for the entire lot.
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Document No.: SOP-PL-024
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6. Distal Ileum Removal (Refer to JTP-KF-027)

Cattle only:-

 The distal ileum of cattle of all ages slaughtered will be removed as SRM using a designated SRM
knife.
 The team member slices around the distal ileum nearest the caecum including the ileo-cecal
junction. The small intestine is uncoiled and measured to 200 cm and removed (see diagram of
CFIA MOP Chapter 17 of the cattle gastrointestinal tract). The distal ileum is disposed of in the
SRM chute/auger. After the removal of the distal ileum, the remainder of the small intestines from
cattle of all ages can be harvested as edible meat products, provided the intestines were found free
of pathological defects, and are from carcasses approved for human consumption.
 The Kill Floor Manager, Supervisors or Lead Hand is responsible in making sure that trained
personnel is present to remove, collect and dispose the distal ileum in the SRM auger prior to
starting the offal conveyor or start of offal collection.
 The content of SRM container is disposed into the SRM auger.

Bison and Yak:-


In case of Bisona and Yak, there is no need of distal ileum removal, and it can be disposed as inedible.

7. Carcass splitting (Refer to JTP-KF-021)


 The split saw must be cleaned and sanitized before and after each carcasses. Designated
personnel must ensure that the saw is clean and sanitized for at least 6 seconds at 83°C. If
using a separate saw for OTM/UTM in case of Cattle, ensure that it is still sanitized before and
after use.
 If the saw is not properly sanitized,
a. UTM carcass is downgraded to OTM by placing “3” Stamp on the shoulder and other carcass
parts is marked.
b. OTM carcass is trimmed along the split area to ensure that any defect and contamination are
removed.

8. Top Trim:
Cattle only:-
The spinal cord gets pulled out at the top trim while it’s still attached with the carcass. Designated tools
used for it in case of OTM SRM blue designated knife, and white color knife in case of UTM.
Designated tool will be used to remove the spinal cord at this station which is consisted of “SRM
designated tool” as shown below and white knife for UTM carcasses. Vertebra column of OTM animal
(Incidentals in Class 1 and Class 2 confirmed OTM by dentition and Class 3) will be painted in blue.

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For UTM Carcasses: -

Designated equipment and white knife for UTM Carcasses

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For OTM carcasses: -

OTM
Only

Designated equipment and blue knife for OTM and Incidental Carcasses

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Document No.: SOP-PL-024
Document Name: SRM (Specified Risk Material) Control
Revision Date: January 18th 2024
Approved by: HACCP Team
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For Bison and Yak: -


In case of Bison and Yak for all classes the spinal cord is removed by designated regular tool (Yellow handled)
and designated knife (White) as shown above. However, in case of animals over 30 months, the designated
spinal cord removal tool (OTM) along with the Blue designated knife. Although, the disposal is going to be done
as inedible in inedible bin. The spinal cord in case of confirmed OTM will be painted as green.

Note: It is important to emphasize that under no circumstances should hands be employed in the
removal of the spinal cord. However, if hands must be utilized for any reason, it is crucial to ensure
rigorous sanitization procedures are strictly adhered to, prioritizing the utmost hygiene and safety
standards.

9. Bottom Trim:
For cattle
The incidental OTM will be painted with blue ink on the spinal cord, only if not already done at Top trim
location.
For Bison and Yak: -
The spinal cord is painted with green color.

10. Final Trim (Refer to JTP-KF-025)


To ensure that the spinal cord is removed, the final check trimmer inspects each carcass.
If carcasses are found to have spinal cord remnants the final check trimmer uses designated tools in
case of UTM. Designated SRM removal tool will be used to remove the spinal cord and white knife for
UTM carcasses in case of Cattle, Bison and Yak.

For OTM carcasses (Cattle, Bison and Yak): -The designated tool, which says” OTM only”, will be used
along with the blue-handled knife

 Standard washing and sanitizing procedures apply following removal of SRM from OTM
animals.

Note: It is important to emphasize that under no circumstances should hands be employed in the
removal of the spinal cord. However, if hands must be utilized for any reason, it is crucial to ensure
rigorous sanitization procedures are strictly adhered to, prioritizing the utmost hygiene and safety
standards.

SRM is placed into an SRM container


At the time of weighing the side, the scale operator records whether each carcass is UTM or OTM in the
Bouvry Server, Stamps the OTM carcasses with “Triangle 3” in case of cattle. The scale then prints out
on the carcass ID tag if the carcass is OTM or UTM. The employee then removes the brad pins.

Segregation of carcasses in coolers will follow SOP Carcass Cooler Handling (SOP-CL-001)

11. Carcass cutting (Dorsal Root Ganglion)


When harvesting meat from OTM Cattle Carcasses, the vertebral column is separated from cuts through
a 1” laterally cut from inside of the vertebral arch (CFIA MOP Ch 17). Vertebral column is then disposed
of in SRM Auger.

UTM carcasses may be boned out with OTM, if downgraded to OTM. UTM carcasses will be cut before
OTM and clear the line as segregation. If not, then a complete wash-up will be necessary.
OTM boxes will be stamped with “Triangle 3” stamp
OTM and UTM boxes must not be mix together on same pallet.

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12. Carcass Shipping


Carcass OTM can be sent to another federal establishment under CFIA permit for boning. If transported
with UTM carcasses, a physical barrier will be placed between the OTM and UTM carcasses.

3.2 SRM Handling and Disposal:

Canada Regulations do not consider the Bison to contain SRM. As such there is no requirement for collection
and disposal of SRM for these species. Disposal of what other countries consider SRM in these species follows
the regular inedible disposal and process flow.

For Bison and Yak, regardless of age - the spinal cord, distal ileum, skull, brain, trigeminal ganglia, eyes, tonsils
and portion of the vertebral column (with dorsal root ganglia) are considered as non-SRM and will be disposed of
in the inedible auger.

The SRM trailer is provided by the company contracted to remove and dispose of SRM. Currently it is third party
contractor who transports of all SRM trailers and contents to and from Bouvry Exports Ltd.
1. SRM materials are separated from the carcasses at the earliest opportunity during the dressing process
and placed directly into the SRM auger or into SRM containers. When SRM containers are used, they
are emptied into the SRM auger with special care not to contaminate any carcasses in the process. The
SRM material disposed of in the SRM trailer is identified with blue marking ink spray application to the
top layer during production breaks (30 minute) and a final application at end of production by the Gut
Room Employee. (Dye used: BIRKO Blue Marking Ink)

2. SRM Trailer must be identified with an “SRM/MRS” placard on it. Prior to be removed from the SRM
room, designated team member will ensure trailer has no leaks to be observed and is properly covered,
to avoid outside cross contamination that could eventually spread BSE disease, as well as attract
undesirable pest near the facility. (Refer to Job Task Procedure for Shunt Driver (JTP-PL-003))

3. Floor waste on slaughter floor is managed through specific areas where SRM contamination may occur.
Floor waste in SRM area will be shoveled by designate employee directly into SRM container with a
shovel designated especially for SRM only. Other areas of kill floor, which have floor waste will be
shoveled in inedible containers with an inedible shovel. SRM floor waste areas are: Head drop, head
wash, Head collection, carcass split and bottom trim.

4. The blood pit will be treated as non SRM unless a deviation in application of edible grease and nostril
bags has occurred.

5. All drains contain screens and are plumbed to a central collection pit which is immediately pumped
through a Hydro-Sieve (<4mm slots) where the solids in the waste are separated from the liquid and
transferred to the SRM auger system. The liquid waste is pumped to a private lagoon where the still
water is aerated. An annual analysis of the lagoon water is performed and approved by the Alberta
Environment. All drains within the SRM production period are treated by contract sanitation with an
approved chemical as per their Sanitation Manual.

6. Cleaning and sanitization of the facility and equipment exposed to SRM is governed by our sanitation
program. The cleaning and sanitizing of SRM exposed facility and equipment is monitored in the pre-
operational inspection.

7. To ensure the proper and safe disposal of live animals that may and not (Including Horse) contain
Specified Risk Materials (SRM). Animals that die outside of the plant (e.g., in pens or Barn) is transferred
to the Dead pit. The third-party rendering company will be informed in case of an animal so that it will be
taken care of according to Canadian SRM handling procedure.

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4.0 MONITORING PROCEDURE


Responsibility: QA personnel

Frequency: Every day Bovine animals processed

Procedure:

1. Verify that SRM material as per the procedure has been removed for 5 heads, and 1 head will be
monitored every 2 hours, if 200 cm of the distal ilium/mesentery removed and disposed of in SRM auger,
and record findings on Kill Floor Hide-Off Monitoring (REC-KF-003), Record findings on REC-KF-001 Kill
Floor Hide-On Monitoring.
2. Monitoring of other SRM procedure will be done by filling throughout production day the Kill Floor Hide-
On Monitoring (REC-KF-001), Boning Room Monitoring (REC-BR-001), SRM Shipping, Receiving
(REC-PL-026), and Kosher Room Monitoring (REC-BR-002)

5.0 VERIFICATION PROCEDURE


Refer to JTP-PL-007 Verification procedure

6.0 DEVIATION PROCEDURE


1. If cross contamination is found between SRM and Non-SRM, Non-SRM will be downgraded to SRM.
2. If UTM carcasses, parts or materials cross contaminates with OTM carcasses, parts or materials, the
UTM ones will be downgraded to OTM.
3. If SRM auger is out of service, Inedible auger can be used and will be identified (By using placarded)
SRM trailer will be put in inedible room. Prior to re-use inedible auger, a full sanitation will need to be
performed. Notify CFIA of the situation to avoid confusion.

All deviation found as described above will be documented as detailed as possible on REC-KF-001 and/or REC-
KF-003 to show how it was controlled.
Other major deviation to this procedure identified that are a potential risk for food safety or loss of control of SRM
will be handled by filling a Generic Deviation Form (PF-02).

7.0 RECORDS)
Check Trim Monitoring Form (REC-KF-008)
Kill Floor Hide-On Monitoring (REC-KF-001)
Kill Floor Hide-Off Monitoring (REC-KF-003)
Boning Room Monitoring (REC-BR-001)
SRM Shipping, Receiving (REC-PL-026)
Kosher Room Monitoring (REC-BR-002)
Generic Deviation Form (PF-02)

8.0 REFERENCES
[1] Canadian Food Inspection Agency , "Guidance on Specified risk material (SRM)," 10 01 2019. [Online].
Available: http://www.inspection.gc.ca/food/food-specific-requirements-and-guidance/meat-products-and-
food-animals/srm/eng/1369768468665/1369768518427.

[2] Legal Information Institute, "9 CFR § 310.22 - Specified risk materials from cattle and their handling and
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Document No.: SOP-PL-024
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disposition.," 13 July 2007. [Online]. Available: https://www.law.cornell.edu/cfr/text/9/310.22.

[3] United States Department of Agriculture - Food Safety and Inspection Service, "SRM in Voluntary Inspection
of Exotic Animals," United States Department of Agriculture, 01 10 2008. [Online]. Available:
https://askfsis.custhelp.com/app/answers/detail/a_id/1114/kw/bison/session/
L3RpbWUvMTU1NTM2NzQ1NC9nZW4vMTU1NTM2NzQ1NC9zaWQvZlVGakxPTXFKT0dxMmEwbXdPNU
5tbGIlN0VKcjkxM25yaG52YU84OUxUT01kdGhuSVZ2eGlFeDlrdmVkdmNYdFl3djByNklpWThEVjRrX3VlYV
9kOXk2U19GbmpCOEY4bk9w. [Accessed 24 04 2019].

[5] Canadian Food Inspection Agency, "Policy Regarding Incidental Over Thirty Month Cattle Stunning and
Contamination with Specified Risk Material in Slaughter of Under Thirty Month Cattle," Government of
Canada, 24 07 2017. [Online]. Available:
http://www.inspection.gc.ca/animals/terrestrial-animals/diseases/reportable/bse/srm/abattoirs-meat-
processors/cattle-stunning/eng/1368993227531/1368993228422. [Accessed 29 04 2019].

[6] Canadian Food Inspection Agency, "Specified risk material - Blood collection during slaughter," Government
of Canada, 27 12 2018. [Online]. Available:
http://www.inspection.gc.ca/animals/terrestrial-animals/diseases/reportable/bse/srm/abattoirs-meat-
processors/blood-collection/eng/1369327046691/1369327047551. [Accessed 24 04 2019].

[7] Canadian Food Inspection Agency, "Accredited Veterinarian's Manual," 30 01 2019. [Online]. Available:
http://www.inspection.gc.ca/animals/terrestrial-animals/diseases/accredited-veterinarian-s-manual/chapter-
5/eng/1345235704516/1345235803337?chap=0.

[8] REGULATION (EC) No 999/2001 OF THE- EUR-Lex


https://eur-lex.europa.eu/legal-content/en/TXT/PDF/?uri=CELEX:02001R0999-20130701&from=en

9.0 REVISION CONTROL


Date No. Description of Change Revised by
May 31, 2012 0 Create Procedure
April 07, 2021 1 Updated, simplified NE
April 25, 2021 2 Updated format NE
July 27, 2021 3 Updated Japan SRM requirements NE
Added reference to CCP01B and BEC SRM policy statement.
August 26, 2021 4 JB
Added monitoring and verification procedures.
October 14, 2021 5 Updated format and ref # NE
October 18, 2021 6 Changed monitoring forms to REC-KF-001 & REC-KF-003 NE
November 05, 2021 7 Added Dye ink brand used NE
December 04, 2021 8 Changed form DC-03b to REC-BR-001 NE
January 13, 2022 9 Added Kosher room Monitoring form when OTM Kosherized NE
February 09, 2022 10 Updated deviation procedure NE
February 16, 2022 11 Change form DC-03d to REC-PL-026 NE
March 04, 2022 12 Added reference to JTP # for each step of SRM control NE
April 30,2022 13 Updated the EU requirement as per regulation N.K
June 20,2022 14 Added the reference to Knife N.K
July 26th, 2022 15 Updated the monitoring procedure N.K
October 6th, 2022 16 Updated the procedure to match the current practices N.K
Updated the Bottom Trim and Top Trim locations in the
October 14th, 2022 17 N.K
procedure
October 17th, 2022 18 Updated the deviation procedure N.K

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October 31,2022 19 Updated Head Removal Procedure A.K


nd Added Class 1 incidental OTM’s under carcass splitting for
January 2 , 2023 20 RA
blue paint
January 24th, 2023 21 Removed SRM Checklist DC-03 from records RA
Added the following procedure under no. 6. Distal Ileum
Removal to ensure that distal ileum will be removed from the
offal and will be disposed of properly.

“The Kill Floor Manager, Supervisors or Lead Hand is


April 17, 2023 22 responsible in making sure that a trained personnel is present MG
to remove, collect and dispose the distal ileum in the SRM
auger prior to starting the offal conveyor or start of offal
collection.”

The updated SOP now includes the scenario for handling


October 20th, 2023 24 N.K
euthanized animals in the barn as per SRM Handling rules.
Updated to state that under 3.2 SRM Handling and Disposal
that;

For Bison and Yak, regardless of age - the spinal cord, distal
November 07, 2023 25 MG
ileum, skull, brain, trigeminal ganglia, eyes, tonsils and portion
of the vertebral column (with dorsal root ganglia) are
considered as non-SRM and will be disposed of in the inedible
auger.
Updated the color of the knife for UTM carcasses to use White
November 08th, 2023 26 dedicated knife for Head wash station, and for spinal cord N.K
removal at Bottom and Top trim.

Updated the spinal cord removal procedure to incorporate the


following changes:

 The spinal cord will be removed at the


Bottom Trim Station only.
 The dedicated spinal cord tool will be used,
along with a white knife for UTM carcasses
November 10th, 2023 27 N.K
and a different dedicated tool with a blue
knife for OTM carcasses and incidentals.
 The disposition of the spinal cord in the case
of Bison and Yak will be deemed as inedible.
 Under ideal conditions, the spinal cord cannot
be removed by using hands. However, if it
has to be done, hands need to be washed
thoroughly.
Updated the following:
January 3rd, 2024 28  Updated the verification frequency and updated the N.K
monitoring form
January 18th, 2024 29 Updated the verification procedure N.K

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