NSFS Reference: 10
Issue date: 22 October 2015
Category: Reinforcement of existing requirements
Contact officers:
Baden Pearse
Field Operations Manager
07 3246 8764
Date of effect: Immediate
Review date: October 2017
Distribution categories
Central and regional office
Departmental on-plant officer(s)
Managers, export meat establishments
State/Territory regulatory authorities
1. Purpose
To confirm an amended performance criteria relating to the ongoing assessment of the effectiveness of process control on small stock slaughter floors.
To include goat abattoirs in this requirement.
To provide industry with a final version of the Meat Notice introducing performance criteria for the assessment of slaughter floor process control (MN 2014/08).
2. Scope
All export registered sheep, lamb and goat abattoirs that have a CCP on the slaughter floor for the control of ingesta, faeces and milk.
3. Background
Meat Notice 2014/08 was issued as an interim measure to introduce the concept of performance criteria on small stock slaughter floors. It provided a 90-day trial period during which time industry was to record the number of breaches of Critical Control Point (CCP) 1 (carcase contamination with faecal/ingesta/milk) in a moving window of 1000 carcases examined. While the trial was underway, the Notice provisionally allowed a maximum of 22 breaches of CCP 1 before regulatory action would be instigated.
In Tier 2 establishments, the average maximum number of detections in the 1000 carcase moving window over the 3 month trial was 2.2 with a range of 0 to 8. Now that the trial data has been analysed, the department is issuing a final version of the Notice which contains a new maximum number of detections which is consistent with the performance criteria data supplied by all participating sheep and lamb abattoirs.
Under the rules of Hazard Analysis and Critical Control Point (HACCP) systems, a CCP is deemed to have failed if the monitoring provides evidence of a breach of the Critical Limit (CL). Given the variability of incoming stock, the risk of breaching this particular CCP can temporarily increase during production runs. It is important that processors detect and react quickly to these challenges to ensure that CCP breaches do not occur and that the resultant product being packed is fully compliant. While occasional isolated breaches may be attributed to unusual events, more frequent breaches of a CCP indicate that the preventive measures in place are not adequate to manage the challenge and that the HACCP plan will need to be reviewed or reassessed.
This notice introduces the concept of nationally-derived performance criteria to assess the adequacy of those preventive measures.
4. Methods
4.1 CCP monitoring sampling frame
HACCP guidelines define monitoring as the scheduled measurement or observation of a CCP relative to its critical limits. They also state that the monitoring procedures must be able to detect loss of control at the CCP, and ideally provide this information in time to implement corrective action to prevent non-compliant product entering the market place.
Establishments must determine the monitoring frequency of the CCPs as part of their HACCP review and should determine the sampling frame according to their data.
An analysis of the performance of the industry has identified that the sample number for “normal” sampling under AS 1199.1-2003 (Sampling procedures for inspection by attributes - Sampling schemes indexed by acceptance quality limit (AQL) for lot-by-lot inspection) and modified for Meat Hygiene Assessment (MHA) is a suitable guide for CCP monitoring of carcases under Australian conditions. As a guide, the minimum expected sampling of lots for CCP monitoring is provided in Table 1 below. A company may use an alternative sampling plan to that described below, however it will need to be validated to ensure it is equally as effective as the plan below.
An establishment may define the whole shift’s production as a lot or choose to break up a shift into a number of production lots. This is particularly the case where the slaughter floor throughput greatly exceeds 1000 per day. As the definition adopted for lot size affects the overall proportion of the carcases monitored, it must be consistent with the risks outlined in the hazard analysis.
When determining a lot size it needs to be remembered that any corrective action will have to be taken on all product contained within the sampled lot.
The definition of the lot must be constant for a particular class of livestock and be documented in the Approved Arrangement (AA).
Table 1: Monitoring frequency for carcases at the slaughter floor CCP.
| Total number of carcases in the lot | Minimum number of units* to be monitored | Number detections to breach CCP |
|---|---|---|
| ≤ 90 | 13 | 1 |
| 91 – 150 | 20 | 1 |
| 151 - 280 | 32 | 1 |
| 281 – 500 | 50 | 1 |
| >500 | 80 | 1 |
| Any detection of zero tolerance defects in a sample is a breach of the CCP and must be dealt with in accordance with the Approved Arrangement. | ||
* Please note: in the above table a unit is dependent on the class of stock processed and is defined as follows:
Small stock (unsplit) – a whole carcase
Note: The facilities for monitoring this CCP must be at least as good as those at an inspection point. Facilities and procedures for the monitoring of this CCP must be suitable for the task and be documented in the AA .
CCP monitoring and MHA
The establishment will need to continue collecting MHA data which may be combined with CCP monitoring to avoid duplication of activity. It may be the case that the number of carcases subjected to MHA is less than the number examined as part of CCP monitoring in which case the extra carcases need only to be examined for zero tolerance (ZT) defects.
4.2 Performance Criteria
Establishments must continue to produce clean carcases that meet Australian and international requirements. Overall performance must be reviewed daily and also as a trend monitored over time. When carcases contaminated with faeces, ingesta or milk are detected, the operator must ensure that the normal corrective actions are implemented, the affected carcases are re-worked and inspected prior to be being allowed to leave the slaughter floor. Preventive action must also be taken to minimise or reduce the chances of a recurrence.
The expectation is that monitoring of a sample of carcases will result in no visible contamination with ZT defects. Statistically, however, it is possible that an occasional ZT defect is found.
The department is of the view that the number of ZT defects for a moving window of 1000 results of carcase CCP monitoring provides evidence of the effectiveness of process control and therefore of sustained compliance with carcase dressing standards. There may be occasional breaches for ZT defects in a lot, but if this is repeated on a number of occasions there will be an unacceptable trend that will be evident in the moving window of 1000 carcase examinations. Breach of the moving window will require a reassessment of the HACCP plan.
The maximum number of detections in a moving window of 1000 units sampled is 10. Given the results from the establishment-supplied data, all sheep/lamb and goat abattoirs should be able to perform below this trigger point.
Reassessment of the HACCP plan will be required if the number of units with ZT defects during monitoring of the slaughter floor CCP exceeds the stated maximum number per window of 1000 units examined.
4.3 Regulatory Action
If the trigger point for ZT defects in 1000 sample units is breached and the processor has failed to react appropriately to that breach, the department will issue a Corrective Action Request (CAR) directing the company to reassess the HACCP plan for that CCP due to the documented evidence that they have failed to sustainably meet the CL.
The reassessed HACCP plan will be submitted to the department for re-approval. Once approved, the window will be reset.
Ongoing breaches of the window (i.e. failures of preventive action) will adversely impact audit outcomes and may lead to further sanctions and market delisting.
5. Responsibilities
Company management
- If not already completed, review CCP monitoring frequency to ensure that it reflects the assessed risk and complies with the minimum level recommended in this notice and, where required, amend the AA.
- Amend the AA to include an ongoing assessment of the HACCP plan against the amended performance criteria.
- The department has provided a spreadsheet to support the implementation of this program by establishment QA and departmental officers.
- Maintain all HACCP documents including monitoring records for two years. These records must be readily accessible for audit purposes.
- At the weekly meeting discuss results with the On-Plant Veterinarian.
On-Plant Veterinarians
- At the weekly meeting review the HACCP performance within the moving window.
- Monitor establishment CCP records and issue a CAR when the trigger point is reached in the 1000 sample units examined and the company has not responded adequately.
- Inform the Area Technical Manager when trigger point is exceeded.
Clare Jones
Director
Export Meat Program
19 October 2015