Department of Agriculture, Fisheries and Food
Trader Notice MH 17/2010
To: All Approved Meat Establishments
Subject: Animal By Products in Sheep Slaughtering Establishments
Role of the Food Business Operator
The FBO must have an up to date Standard Operating Procedure (SOP) on ABP detailing their systems and procedures to achieve compliance with the regulations. This SOP must be drawn up in consultation and agreement with the Veterinary Inspector and incorporate at the least details of (1 to 11):
1. Production, collection, segregation, identification, handling, storage, and transport of animal by-products including SRM at DAFF approved meat establishments.
2. The FBO must satisfy DAFF that a secure and workable system is in place to ensure that the categories of material that leave the plant are in compliance with the regulations. There must be a batching system in place, which will allow those parts of animals that have not passed post mortem inspection (and which have no exemption) to be diverted away from the Cat 3 stream.
3. In the case of approved slaughter plants where fleeces are dispatched for use as gelatine for human consumption it will be necessary for the FBO to have a segregation system for the fleeces that are ineligible for gelatine for human consumption (i.e. animals that have failed ante and/or post mortem)
Adequate separation between eligible / ineligible fleeces and documented evidence of the segregation system is required.
4. Where there is an approved Cat 3 fat melter attached to a slaughtering plant the FBO must have
· A HACCP plan with specific CCP points
· A traceability and recall procedure
· Take representative samples to check compliance:
(i) of each processed batch with the standards for the products established by this Regulation, 1774/2002
(ii) with the maximum permitted levels of physicochemical residues laid down in community legislation;
· Ensure that road tankers used to transport the tallow do not pose a risk of cross contamination of the tallow.
· A system of records must be put in place to support the monitoring and checks required.
5. Where there is an approved Collection Centre attached to an ovine meat plant the FBO must have:
· An operational system for the premises and facilities as outlined in the Authorisation Conditions for Collection Centres at DAFF Approved Ovine meat Establishments
http://ezone/vet/conditions/VPH_RedMeatCC_ConditionsfinalOct07.doc
· Documented procedures.
· Records including: (i) Register of Customers; (ii) Material Treatment Record; (iii) Dispatch Register.
6. Where there is a thermal boiler approved to burn ABP tallow attached to a slaughter plant the FBO must have:
· An operational system for the thermal boiler and tallow storage facilities as outlined in the Conditions for the Approval and Routine Supervision of the use of tallow as a fuel in thermal boilers
http://ezone/vet/conditions/BurningTallowconditionsRev216.11.07.doc
· Documented procedures and checks.
· A documented procedure in place to give the Veterinary Office advance notice of a delivery of tallow for combustion. Deliveries and unloading are to be during core hours only to facilitate DAFF breaking and re-sealing road tankers and on-site tallow tanks.
(This procedure is not required at non-slaughter plants where DAFF do not
have a permanent presence. However, the plant must have a documented
procedure whereby they break and re-seal on-site tanks. A record
is to be kept by the plant of the commercial seal numbers that they use).
· Records including: (i) Record of weights of incoming tallow (ii) Records of weights of tallow combusted; (iii) Records of reconciliation tallies of tallow intake vs. to tallow usage; (iv) Records of monitoring checks on combustion temperatures; (v) Thermographic records.
7. Transport of ABP between member states: Commission Regulation (EC) No. 93/2005 of 19 January 2005 amending Regulation (EC) No. 1774 of 2002 provides that the model commercial document as set down in the annex to that regulation must be used for all intra-community transportation of processed and unprocessed animal by-products (ABP).
8. It is the responsibility of the FBO to provide the commercial documents for movement of ABPs
9. Record Keeping.
In accordance with Regulation 93/2005 all commercial documents must be kept for a period of 2 years to verify the records referred to in Article 9 of 1774/2002.
Plant Management must keep the required records and documents to show compliance with this legislation, in particular the records specified in Annex II of Regulation 1774/2002
10. SRM
· A system for the ageing*, labelling and traceability of sheep for SRM removal as necessary.
· How SRM is harvested, handled, segregated, stored, identified and stained within the plant.
· Dispatch of sheep
· Disposal of SRM to Category 1 Plants.
· Cleaning of equipment and areas of the plant where SRM is handled and stored.
· Checks on incoming sheep
· Checks and the frequency of checks that the Food Business Operator (FBO) will carry out on all aspects of SRM at the plant [examples attached in Appendix A].
· Auditable records must be kept of all the checks carried out to provide evidence of compliance with the legislation, including a record of staining ink purchased.
· Records of dispatch of SRM including a record that confirms the arrival of the Category 1 material at the approved rendering plant. - Receipts
· Waste water handling
· Training records must exist for all staff dealing with SRM procedures.
* [Ageing sheep – FBO Responsibilities
The FBO is primarily responsible for the ageing of sheep.
Preliminary ageing of sheep is routinely carried out in the lairage of slaughter plants by plant staff and this is verified in the slaughter hall by the plant operative, at the point of removal of the head of the sheep.
Categories of age for sheep.
The age categories necessary to distinguish sheep are
- Under 12 months old - this category is determined as having no permanent incisors erupting or in wear[1].
- Over 12 months old - this category is determined as having permanent incisors erupted or in wear 1.
The FBO must have an effective documented standard operating procedure in place to ensure that sheep with at least one permanent tooth erupting are identified and SRM properly removed, stained and disposed of. This means that the mouth of each hogget carcase must be examined on the slaughter line and a decision taken on them. The procedure to be followed in slaughter plants is as follows:
(a) In the Lairage all animals should be inspected by plant personnel and all animals clearly over 12 months (ewes/ rams and hoggets) should be segregated and slaughtered in batches in line with current practice. The regulations on SRM disposal would automatically apply to these animals.
(b) The other animals should be slaughtered as normal but at the time of removal of the head, a designated factory employee, whose function should be to determine whether a permanent incisor tooth has erupted through the gum, should examine the mouth. Where any head is found to have a permanent incisor tooth erupted the head should be classed as SRM and carcase must be identified as one from which the spinal cord must be removed and treated as SRM.
(c) SRM heads should be segregated and stained with regulation dye as per the current practice. Individual FBOs should agree procedures with the local veterinary inspectorate to ensure the absolute segregation of non-SRM heads.
Provisions must be made to have the age categorization of the sheep attached on a label to carcases (under 12 months old or over 12 months). This may be done by generating additional information on the NSIS label or by the use of an additional label. The method adopted to categorise the carcases within age groups must be clearly and easily understood e.g. colour coding or number coding.
Where sheep carcases are split on the slaughter line, there must still be an age categorization attached to the carcase.
Where carcase splitting takes place outside the slaughter hall, plant management must ensure that all carcases over 12 months old have been split.
The labeling for NSIS and age categorization must remain with the carcase up to the point of entry to the boning hall or dispatch.
In the case of carcases that are split for the removal of SRM, full traceability of both sides of the carcase must be ensured after splitting.
FBO must draw up a Standard Operating Procedure specifying the means by which they comply with the necessity to demonstrate the ages of the carcases. This SOP must be incorporated into the SRM protocol and must be made available to the VI. ]
11. Cleaning of Category 3 Containers /Trailers that are contaminated with
Cat. 1 material
In the event of a category 3 container being inadvertently used to hold or transport category 1 material the container may be cleaned and reused as a cat 3 container if the following criteria can be met
Location of cleaning
Cleaning can only take place in a facility, which has received prior approval by Animal By Products Division after examining its cleaning and disinfections SOP. Facilities where trailers that transported Cat 1animal by products are cleaned must have a 6mm grid in place prior to the entry to the waste water system.
Specific Procedure
a) Visual assessment
A visual assessment of each container/ individual trailer must be carried out to establish the physical condition,
b) Gross material
Remove any gross material from the trailer.
c) Wet Cleaning
All surfaces should then be washed using a high pressure/low volume water spray heated to 80 degrees Centigrade to remove any residual animal by product remaining.
d) Disinfections Step
All surfaces must be sprayed using a disinfectant approved by DAF. The surfaces should then be rinsed down with the minimum of water and the receptacle allowed to dry naturally.
e) Final Confirmation
A final written completed Clean 3 Form will be given by the washing facility to the person responsible for the container/trailer confirming that the procedure has been carried out.
Vehicle Canopies
a) Canopies are to be cleaned and disinfected as outlined above.
b) Because of the difficulty in adequately disinfecting some receptacle canopies used during transporting, and because of the nature of concurrent wear and tear which makes disinfection procedures more difficult, it may be considered following inspection of the canopy that it be disposed of when a category change occurs which results in a lower risk animal by-product being transported. Evidence must be provided to DAFF of the safe disposal of the old canopy.
Meat Hygiene Section
24th May 2010.
[1] Reference Meat Hygiene, JF Gracey, Balliere Tindall