Behind the Legend - Issue #21
Behind the Legend
Quarterly newsletter for Ontario's provincially licensed meat plant operators
Issue Number 21- Spring 2017
The meat inspection legend is the stamp that goes on meat products when they have met all regulatory requirements and are deemed safe for Ontario consumers.
In this Issue
Supporting meat inspection program delivery and training for our field staff
We are living in a time when consumers (and your customers) have greater expectaions on understanding where their meat came from, how it was made and where the animals treated properly. Since my arrival at the Meat Inspection Program, I continue to be impressed by the ongoing relationship our provincial meat inspectors have with their provincially licensed meat plants. There is a strong on going relationship between our provincial meat inspectors and our provincial plants in not just ensuring regulatory requirements are met but an active dialogue about the 'why' behind food safety and animal welfare requirements
While your primary relationship is with your inspector, there is a group of specialists behind the scenes who support meat inspection program delivery and training for our field staff.
They are led by Joe Iacobellis, Manager of our Meat Inspection Operations Program Unit who spent over 20 years managing food production plants before joining the Ontario Public Service. We also have several Food Safety Advisors – Carla Royston, Melissa Haveroen, Agnes Pawelek, Holly Sabara, Michelle Jansen, Rima Hatoum, who collectively possess a blend of solid food safety academic credentials and private sector experience in creating operational policies, delivering food safety training and providing day-to-day technical expertise to field staff across the province.
Gisselle Vanneste covering for Ashley Hammell (on leave) provides curriculum expertise and training coordination, with Alicia Allen traveling across the province to provide direct field training support for new meat inspectors and their trainers. Pat Walker coordinates our licensing processes, Lindsay Melchin administers and procures our equipment and supply needs for over 170 program staff, and Helena Brown provides administrative support.
In addition, Kristen Green, has been serving as our acting Manager of Strategic Initiatives, and leading the use of analytics to help the program better understand what the data is telling us about food safety and animal welfare risks. This work is allowing us to assess trends and determine what resources are needed to better address risks in the field. She has been working closely with Mike Eastment and Dawn Chalut who coordinate our residue and Ready-to-Eat (RTE) sampling and testing program and recently implemented changes to our water testing programs at provincial plants.
This group of dedicated and competent staff are a wonderful resource to our field staff and their managers – and in turn to you as plant operators – when we work together in addressing food safety and animal welfare risks. The articles presented in this (and past and future issues) would not be possible without our Meat Inspection Program Operations Unit.
By Jason McLean
Manager, Meat Inspection
From our Program Desk: Risk-Based approach to regulatory oversight at freestanding meat plants
Many jurisdictions around the world are applying risk-based strategies that help focus inspection resources on areas that pose a greater food safety risk. In Ontario, the Meat Inspection Program implemented a risk-based approach in 2009, when it introduced a risk classification to focus inspection resources on food safety risk. This approach was meant to achieve appropriate oversight based on the risks presented. As risks increase, so does inspection.
The risk-based approach includes factors such as the type of processes and products at the plant, physical characteristics of the plant, volume and distribution of product, level of knowledge and training of the operator and employees, process controls in place and compliance history.
Some recent considerations to the approach include:
- Describing the various processes and products in our meat plants more accurately.
- Emphasizing that the risks posed by ready-to-eat meats increase with the complexity of the processes.
- Updating the list of recognized food safety programs, and the importance of them in managing food safety risks.
- Increasing the importance of compliance history in the assessment.
By reviewing and updating the risk-based approach, OMAFRA continues to refine its inspection system to better focus resources on areas with a higher food safety risk.
From Our Program Desk: Licensing exemptions under the provincial Meat Regulation
Businesses handling meat in Ontario are regulated by the Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA), the Canadian Food Inspection Agency (CFIA) or by local Public Health Units (PHUs) that are administered by the Ministry of Health and Long-Term Care (MOHLTC).
The CFIA is responsible for regulating federally registered establishments. Only facilities that are federally registered can export meat to other provinces and countries. These businesses tend to be larger than provincially inspected plants, are designed for higher volumes and have to meet international and inter-provincial trade requirements.
OMAFRA is responsible for inspecting provincially licensed slaughter and meat processing plants. Products made in provincially inspected meat plants can only be sold and distributed within Ontario. Provincial plants tend to be smaller in comparison to federal plants and are more often geared towards servicing local communities (e.g., custom slaughter) and creating specialized markets for their products. The public health unit's role focuses on food premises, those businesses where meals or meal portions are prepared for immediate consumption, or sold or served in a form that will permit immediate consumption on the premises or elsewhere.
In 2014, OMAFRA changed regulatory requirements to reflect OMAFRA's role in the inspection of slaughter plants and higher risk meat processing plants These are businesses that require the ministry's focus as they slaughter food animals, distribute a significant portion of their meat products through wholesale markets, or perform higher risk processing activities. The changes granted exemptions from the regulation for businesses conducting certain activities.These businesses no longer require a provincial meat plant licence but are subject to oversight by local public health units. A business does not require a provincial meat plant licence if they meet one of three exemptions under the provincial Meat Regulation.
Food Product Exemption
A provincial licence is not required if a business only prepares:
- Sandwiches that contain meat as an ingredient;
- Pizzas that include meat as an ingredient;
- Edible oil or fat;
- Bouillon; or
- Any other meat product, if the amount of meat contained in it is 25 per cent or less by weight of the product's total ingredients.
Volume Distribution Exemption
Businesses may wholesale a small portion of meat products without requiring a provincial licence. A business is exempt from licensing if the business;
- Only performs lower risk activities (Category 1 activities); and
- Sales to wholesale markets do not exceed the greater of:
- 25 per cent of meat products sold in a fiscal year; or
- 20,000 kg of meat products sold in a fiscal year
Food Service Exemption
Businesses are exempt fromlicensing if the majority of the business' sales are meals or meal portions prepared for immediate consumption on the premises or elsewhere. This means that a restaurant or caterer would not require a provincial licence if more than 50 per cent of their business is preparing meals. In future editions, we will discuss each of the exemptions in more detail.
Do you Operate a Provincial Meat Plant?
OMAFRA's Decision Tree (Do You Operate a Provincial Meat Plant?), may help you in better understanding the licensing exemptions under the provincial Meat Regulation. The tree can be found online at OMAFRA's website.
For more information, you can also speak with your inspector or area manager.
From Our Food Safety Desk:Provincial labelling requirement
The purpose of a label is to provide basic product information to consumers. Provicial meat plants are subject to both federal and provincial labelling requirements. The requirements can be found in the following legislation:
- Food and Drugs Act and Regulations
- Consumer Packageing and Labelling Act and Regulations
- Weights and Measures Act and Regulations
- Canada Agricultural Products Act and the Livestock and Poultry Carcass Grading Regulations
- Food Safety and Quality Act, 2001
- Ontario Regulation 31/05 Meat
- Ontario Regulation 266/09 Livestock and Poultry Carcasses - Grades and Sales
The provincial Meat Regulation (O.Reg. 31/05) requires pre-packaged meat products and bulk containers to have:
- The meat inspection legend.
- A production date or code, unless meat product is a carcass or half carcass. All required information is easily legible and in characters not less than 1.6mm in height (unless the principal display area is 10cm2 or less in which case the information may be in characters not less than 0.8mm in height).
- Storage instructions ("Keep Refrigerated/Garder au Froid" or "Keep Frozen/Garder Congélé") if the meat product is not shelf-stable or does not meet any conditions specified in the legislation.
- Appropriate use statements ("ready to cook", "uncooked", "ready to cook/prêt à cuire" or "uncooked/non cuit" or an equivalent term) and cooking instructions when the product is not ready-to-eat but appears to be ready-to-eat.
- The words "May contain kidneys" or "May contain kidneys/Peut contenir des reins" for young chickens or young ducks.
- The words "clean, green" or "clean, green/lavé, vert" if the meat product is a part of an alimentary tract that has not been scalded or bleached but cleaned in another manner.
- Where there is a standard set out in Table 1 Meat Product Standards of O.Reg.31/05, the product conforms to the standards set out by the table and the related common name is used on the label.
- Species is included where a carcass, cut, organ or tissue is described on the label. When a word or phrase from the table in section 119 (Labelling Restrictions Based on Process of Meat Products) is shown on the label of a meat product, the meat product has met the related requirements of this table.
- You must also meet all federal labelling requirements.
For more information on provincial labelling requirements, please speak to your inspector or Area Manager.
Federal labelling requirements are under the jurisdiction of the Canadian Food Inspection Agency (CFIA). For information on federal requirements, please visit CFIA's Food Labelling for Industry website or contact CFIA directly.
From Our Food Safety Desk: Pest control at your meat plant
No one wants pests in their meat plant. The presence of unwanted rodents, flies and insects can put your business in jeopardy. Uncontrolled pests can cause contamination of food contact surfaces, equipment and food products at your meat plant. By putting a pest control program in place, and following it, you will ensure you have met the requirements of the Meat Regulation (O. Reg. 31/05) and keep pests out of your plant.
To meet the regulatory requirements for pest control you need to:
- Have a written pest control program that details the pest control
methods, procedures and schedules in place
that will prevent the incidence of pests at your meat plant. This includes:
- Records of any pest control chemicals used at the plant, the concentrations, the location of use, and frequency of application should be kept.
- Procedures outlining the employee or company responsible for monitoring for pests, how frequently the monitoring takes place and what actions will be taken if pests are found on the premises.
- Documentation. For example, a map of all pest control devices on the premises and the storage location of any pest control chemicals.
- Ensuring that the licence of your pest control operator is current.
- Follow the details of the pest control program as it is written.
- Ensure all pest control devices are regularly monitored, as written in the schedule, and records are made.
- Ensure that all pest control records are made on the same day they are monitored and kept for at least one year.
- Ensure that the pest control program is kept up-to-date and performed as written.
Your compliance with the pest control requirements of the Meat Regulation helps to keep your food and your consumers safe. Effective plant sanitation is a critical component in eliminating opportunities for pests to find residence in your premises. Clearing outside areas where pests might seek shelter, such as piles of debris, bricks, metal and long grass, will remove any dwellings that pests may have inhabited. By sealing up all entry points into your meat plant, and installing bait stations outside, you can eliminate pest access to the premises.
From Our Food Safety Desk: How well do you separate incompatible activities?
By being mindful and taking deliberate actions to separate incompatible activities you are protecting the safety of the food you produce.
As a meat plant operator, you need to separate incompatible activities in order to reduce the potential for contamination of meat products.
Examples of incompatible activities include:
- Processing ready-to eat (RTE) on the same surface as raw meat products
- Processing allergen-containing products before allergen-free products
- Handling fish and meat products on the same surface
The Meat Regulation (Ontario Regulation 31/05) requires meat plants to be laid out and designed in a in a way that effectively separates incompatible activities. If physical separation is not possible, meat plant operators may use operational controls to create separation (e.g., separation in time with effective cleaning and sanitation in between activities). Such procedures should be documented, reviewed and approved by your Inspector or Area Manager and followed by all personnel and visitors. If you are using these procedures, it is important that you and your staff follow them at all times to reduce food safety risks.
Examples of effective means of separation of incompatible activities include:
- Complete full sanitation activities between incompatible activities.
- Produce RTE meat products before raw meat products.
- Sequence your production so that allergen-free products are processed before allergen-containing products.
- Dedicate separate times for shipping and receiving when physical separation cannot be achieved.
- When fish is present in a meat plant, implement Fish Handling Protocols to control hazards and prevent contamination of meat products.
From Our Food Safety Desk:Ready-To-Eat (RTE) meat testing results summary
As part of our surveillance and monitoring program, OMAFRA tests samples of RTE meat produced at provincially licensed plants. Occasionally these tests will come back with an adverse result. When the adverse result is a pathogen, in addition to a review of practices/protocols/procedures, the meat inspector will ensure that there is no risk to the public and assist the plant operator to complete a root cause analysis to aid in the identification of the potential source of contamination (e.g., environmental testing).
|Number of Adverse Results, by Type||Indicator Organisms|
|Year||# of Sampled Lots Tested (1)||# of Sampled Lots with Adverse Results (2)||% of Lots with Adverse Results||Aerobic Colony Count (ACC) >10,000||Coliforms >1,000||E. coli >Heath Canada limits (3)|
|Number of Adverse Results, by Type||Pathogens/toxins|
|Year||# of Sampled Lots Tested (1)||# of Sampled Lots with Adverse Results (2)||% of Lots with Adverse Results||Listeria mono-cytogenes||Verocyto-toxigenic E .coli||Staphylo-coccus aureus > HC limits(4)||S. aureus toxin||Salmonella|
(1) Five sub-samples collected and tested per sampled lot.
(2) When levels of indicator organisms and/or pathogens are unsatisfactory (i.e. when levels found in the sample exceed Health Canada Limits). There could be more than one type of adverse result per lot.
(3) Health Canada limits for Generic E.coli are any of the following: Heat treated Fermented Sausage >103/g in 1 subsample or >101/g in more than 1 subsample Raw Fermented Sausage >103/g in 1 subsample or >102/g in more than 1 subsample Non-Fermented products >103/g in 1 subsample or >102/g in more then 2 subsamples.
(4) Health Canada limits for S. aureus are any of the following: FCC,FCNC & Dried: if any subsample has >104/g or >102/g in more than 2 subsamples Heat Treated Fermented Meats: if any subsample has >104/g or >50/g in more than 1 subsample. Raw Fermented: >104/g or >250/g in more than 1 subsample. FCC – Fully Cooked Comminuted FCNC – Fully Cooked Non-Comminuted (5) From January 1, 2017 to April 30, 2017.
From our Training Desk: Upcoming Training Sessions
|Event||Date and Time||Location||Contacts|
|Food Handler Training Workshop||June 7 & 8, 2017||Guelph||www.oimp.ca|
|Meat Industry Expo||
October 20 & 21, 2017