Processed Egg Manual - Chapter 6 – Sampling

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Table of Contents

6.1 Objective of Activity

Processed egg products and the environment they are produced in are sampled to ensure that regulatory requirements for safety and quality are met.

6.2 References

Canada Agricultural Products Act
Processed Egg Regulations
Consumer Packaging and Labelling Act and Regulations
Food and Drugs Act and Regulations

Annual Sampling Plans and Guidelines

6.3 Required FormsFootnote 1

Lab Sampling Tracking System (LSTS) Web Submission Forms

  • Food Product Sampling Submission Form (CFIA/ACIA 5174)
  • Food Environmental Sampling Submission Form (CFIA/ACIA 5174)
  • Action Plan Poultry/Egg Programs (CFIA/ACIA 2280)

6.4 Required Equipment

Environmental Sampling Kits
Freezer Packs
Marker for sample cups
Plastic sample cups - sterile
Plastic Whirl Pack Bags - sterile
Sample spoons or triers - sterile
Scissors
Shipping Boxes
Tamper evident tape - Official Seal (CFIA/ACIA 4561)

6.4.1 Equipment for Frozen Product Sampling

  • Heavy duty electric hand drill
  • Bits: at least two per operator (one to be in use; one to be immersed in a disinfecting solution). 1.5 cm ship auger; 1 cm shank; length 40 cm; nickel plated. These are often made for a hand brace, in which case the square shank must be machined to a cylindrical shape to fit the chuck of a power drill
  • A suitable length of electrical extension cable
  • A source of active chlorine to be used as a solution with 300 ppm chlorine.
  • 70% ethanol
  • Containers for wash water, chlorine and an ethanol dispenser
  • Disposable wipes
  • Sterile plastic cups with lid
  • Corrugated styrofoam insulated shipping containers
  • Freezer packs

6.4.2 Equipment for Dried Product Sampling

  • Supply of sterile spoons and/or triers.
  • Whirl-pack bags - 456 g 14 cm x 18 cm.

6.4.3 Sample Record Log

Due to the variety and volume of products being sampled, as well as the rotation of staff, a log of samples assists in tracking the sampling program at a processed egg station.

The information should be recorded as follows:

  • Sample number
  • Sampling plan
  • Type of product
  • Lot number
  • Lot weight
  • Date product was sampled
  • Date samples were shipped
  • Results (e.g. numerical record/ detected or non-detected)
  • Satisfactory or Unsatisfactory
  • Remarks including whether the inspection was for domestic or export product, the inspection coverage and other pertinent information).

All follow-up sample numbers should be linked to the original sample numbers in the sample record book.

6.5 Processed Egg Sampling

The sampling of egg products is performed for microbiological (Salmonella spp., Listeria monocytogenes, Coliforms, and Aerobic Colony Count (ACC)); and compositional evaluation (moisture in dried products, % solids in frozen and liquid products and nutrients).

Note: For sampling plan numbers and sample sizes for the different sampling plans refer to Appendix I and Appendix II respectively.

Unpasteurized egg is not sampled since there are no standards established for this product. However, before being pasteurized and used for human consumption, the unpasteurized liquid needs to be organoleptically acceptable. Sampling is performed on heat treated (i.e. pasteurized) product to evaluate its conformity with section 5 of the Processed Egg Regulations.

Processed egg sampling plans are issued at the beginning of each fiscal year and outline the sampling procedures and sample numbers for each plan. These sampling plans may vary from year-to-year and so should be consulted on a regular basis to ensure that the correct methodologies and frequencies are being used. A list of sampling plans for processed egg can be found in Appendix I. The frequency of testing is notified on the Processed Egg Workplan Activities document and is available on Merlin (Merlin is intended for internal CFIA use).

6.5.1 Sanitary Handling

In order to prevent the contamination of samples and the product sampled, the inspector should take appropriate precautions. It is important that sanitary handling of product and proper aseptic techniques are followed during sampling.

Personal Hygiene:

  • Inspectors should wear clean smocks over their sanitary clothing and must wear a hair net.
  • Boots and helmets must be clean.

Hand Cleaning Procedures When Sampling

Prior to sampling, hands should be washed with an unscented liquid hand cleaner or soap. If dried or liquid processed egg is sampled at the point of packaging, hands should be rinsed with a sanitizing agent and dried with a paper towel immediately prior to sampling.

When sampling dried processed egg from containers, once all of the sample con­tainers have been opened, but before the liners are opened, hands should be rinsed with sanitizing agent and dried.

6.5.2 Guidelines for Aseptic Technique

Proper aseptic techniques must be followed to ensure that samples are not contaminated. The following guidelines should be followed

  • Properly wash and sanitize hands and wear sterile gloves when appropriate.
  • Use only sterilized, sealed sampling tools and containers.
  • Do not touch the inside of the sampling cups/lids or bags.
  • Do not touch the product end of sampling spoons and triers.
  • Use sanitary methods if containers must be opened for sampling. This includes selecting an appropriate room (positive filtered air and clean) as well as proper handling.
  • For gable top packages, the containers should be opened without touching the pour spout.
  • Tetra Brik packages may be opened with sanitized scissors.
  • Boxes should be opened by opening the cardboard, then re-washing and sanitizing hands, then pulling open the liner by the outside.
  • Immediately after taking samples they should be sealed with a tamper evident tape, labelled and stored in an appropriate manner.

6.5.3 Sampling Plan E200 - Product Sampling Technique

Frequency:
Throughout the year as per the Sampling Plans

Record:
Food Product Sampling Submission Form in LSTS
Sample Record Book

Distribution:
Original to Lab
Copy filed in the CFIA Inspection Office at the registered station
Copy sent to the Egg Supervisor or designate

6.5.3.1 Liquid Product Sampling

  • The samples must be collected in a sterile sample cup at appropriate intervals from the draw-off vat as pailing is in progress to spread the sampling over the entire lot. Both liquid products and products intended for freezing may be taken this way.
  • If a gable top packaging system or Tetra Brik system is being used, containers should be selected during the product run, opened in a sterile manner (without touching the spout or by using sanitized scissors) and poured into an appropriate sample cup.
  • At no time should hands come into contact with the inner portion of the sample container or touch the inside of the lid and lid is to be applied promptly after filling.
  • If small (250 ml or less) containers are being produced they may be taken as a sample and submitted to the lab in their entirety.
  • Clearly identify each sample with the appropriate sample number.
  • When sampling is completed, record the samples in the record book and complete the Food Product Sampling Submission Form in LSTS
  • If samples are to be held before shipping, place in freezer.

It is imperative that the supply of empty containers be kept sterile.

6.5.3.2 Frozen Product Sampling

On occasion it may be necessary to sample previously frozen lots of product. In this case the following procedures should be used.

  • Containers of frozen processed egg are to be selected at random from the lot. The random number table (Processed egg Chapter 4, Product Inspection Appendix VII) should be used for this purpose.
  • Assistance in selecting samples from the freezer should be provided by the station so that the entire lot is accessible for sampling.
  • The sampling of processed egg should be done in an appropriate sampling room that is clean, and supplied with positive filtered air.
  • The inspector is to wear a clean smock and wash his hands prior to sampling.
  • It may be necessary to rewash hands where the lids are loosened for sampling.
  • Remove all frost crystals and ice from the top of the processed egg with a sanitized spoon. If frost or ice crystals are included in the sample, it may result in analytical error.
  • Wash the drill bit in warm water and detergent for each lot.
  • Disinfect the drill bit by immersion in active chlorine solution (300 ppm) for no less than 3 minutes. The drill bit should be sanitized between each container
  • Remove excess chlorine solution from the bit by wiping with disposable wipes moistened with 70% ethanol and mount in drill without allowing any contact with those surfaces of the drill that will penetrate the frozen egg.
  • Remove the lid from the container with care to minimize contamination from any external source.
  • With the sterile bit, drill diagonally from top to bottom of the pail making three diagonal drillings in the frozen processed egg.
  • The drilling must not be through the hump on the surface of the container.
  • With a sterile spoon fill the required number of plastic containers with the drill shavings.
  • Shavings should be pressed into the cup to ensure adequate sample size.
  • Open the sample cup only long enough to place the shavings inside making sure that fingers do not come in contact with the inside surface and closing immediately after taking the sample. Seal the sample cups with tamper evident tape.
  • Label sample cups with sample number and place in shipping container (pack with freezer packs as necessary).
  • If samples are to be held before shipping, place in freezer.
  • When sampling is completed, record the samples in the record book and complete the Food Product Sampling Submission form in LSTS

6.5.3.3 Sampling Procedure for Dried Yellow Egg Products

Yellow egg products include whole egg, yolk and mixes. Dried yolk and whole egg products are normally sampled throughout a production run. Lots produced or partially produced in the absence of an inspector may also be sampled, if required. Select the required number of samples at random using the Random Number table (Processed Egg Chapter 4 - Product Inspection, Appendix VII).

Sampling During Packaging:

  • Obtain the required number of sterile spoons.
  • Mark sample bag with a sample number
  • Clean hands with a sanitizing agent and dry.
  • Draw the sample from the stream of powder filling the box from the sifter.
  • Close sample, seal with tamper evident tape and store in a sanitary plastic bag.
  • Repeat sampling at the appropriate intervals until the required number of samples have been collected.
  • When sampling is completed, record the samples in the record book and complete the Food Product Sampling Submission form in LSTS

Sampling After Packaging:

  • Obtain the required number of sterile spoons.
  • Mark sample bag with a sample number
  • Isolate the number of containers required.
  • Have the containers taken to a suitable area for opening.
  • Open all the containers but leave the liners unopened.
  • Clean hands with a sanitizing solution and dry.
  • Open the liner, avoiding contact with the inside of the liner.
  • Unwrap the sterile spoon and place it in the product deep enough so that it will stand on its own.
  • Open the sample bag by tearing off the perforated strip at the top. Avoid handling the bag near the top.
  • The bag is pulled open by the small tabs on either side.
  • As the product is being spooned into the bag, the bag should be held off to one side of the open box so that if any product should be spilled it will not fall back into the box. Also, the bag should be open enough so that neither the spoon nor the product touches the edges of the opening.
  • Once the required amount is drawn, the excess air is expelled from the sample bag by gently squeezing the side together at the top of the bag.
  • The bag is then closed by holding it by both tabs and whirling it until there is no air space left.
  • Close the sample liner and draw the next sample.
  • When sampling is completed, place samples in a sanitary plastic bag pending shipment.
  • Close boxes, record samples in record book, and complete the Food Product Sampling Submission form in LSTS

6.5.3.4 Sampling Procedure for Dried Albumen

Dried Albumen is considered a finished product only after being removed from the heat treatment room after a specified time and temperature as prescribed in Schedule I, Part II of the Processed Egg Regulations.

  • Select the required number of samples at random using the random numbers table (Processed Egg Chapter 4 - Product Inspection Appendix VIII), as the lot of dried albumen is removed from the heat treatment room or held in storage.
  • Sampling procedures will be the same as for yellow products sampled after packaging except that triers are preferred over spoons to obtain a representative sample.
  • Once the sampling is completed, the samples are sealed using tamper evident tape and placed in a sanitary plastic bag pending shipment.

Note: Though the above sampling techniques (6.5.3.1 to 6.5.3.4) take into account aseptic procedures for the Plan E200, nevertheless, these can also be used to sample product under Sampling Plans E100/ E103 (Moisture) and E101 (% solids).

6.6 Sampling Plan E204 - Processed Egg Environmental Sampling

Frequency:
4/year/station
2/year/station for stand alone boiling operations

Record:
Environmental Sampling Reporting LSTS
Sample Record Log

Distribution:
Original to Lab
Copy filed in the CFIA Inspection Office at the registered station
Copy sent to the Egg Supervisor or designate

Environmental sampling is done to evaluate the effectiveness of a station's sanitation program. This is usually determined by swabbing after cleaning and sanitizing, before production begins. However, Health Canada's updated Policy on Listeria monocytogenes (Lm) in Ready-to-eat (RTE) Foods recommends that sampling be conducted three hours into production on the post-lethality side (i.e. after the kill step) of the process. Therefore, some swabs need to be taken during production on the finished product side of the process. The environmental sampling of egg processing facilities is conducted at a frequency as prescribed in the annual sampling plans. Samples are tested for Salmonella spp. or Listeria monocytogenes & Salmonella spp. depending on the time of swabbing.

Kits currently supplied for environmental sampling contains

  • prepackaged moistened sterile sponges,
  • sterile gloves,
  • sterile sample bags, and
  • insulated cooler and freezer packs; all packaged in an insulated shipping container.

The inspector must have the following equipment before commencing the sampling procedure:

  • clean coveralls or lab coat
  • clean footwear
  • permanent marking pen for sample identification
  • Food Sampling Submission Form (CFIA/ACIA 5174) from LSTS

6.6.1 SITE SELECTION

For each sample, two composites will be analyzed by the lab. Inspectors should select sample sites for each composite from one of the four boxes (as indicated in the Table on following page), such that over the course of the year, a wide variety of sites from all categories are sampled.

Sites are categorized as either finished or raw and either contact surface or non-contact surface. An inspector should ensure that at least one of the composites is for finished product sites and collected during production. The swabs for the other composite are to be collected after cleaning but before the start of production (pre-op). The composite of swabs taken during production will be analyzed for both Listeria monocytogenes (Lm) and Salmonella spp. while those sampled at pre-op will only be analysed for Salmonella spp.

List of suggested sampling sites:

Finished Product Contact Surfaces

  • product tank spout
  • finished product filling head
  • inside of product pail
  • inside of totes
  • holding tank
  • silos
  • inside of product pipes
  • pasteurizer cooling plate product side (if open)
  • flex hoses to fill tankers

Raw Product Contact Surfaces

  • loader suction cups
  • transfer room roller conveyors
  • breaking machine cups and knives
  • inside of mixing churn
  • flex hoses in processing or breaking room
  • inside of balance tank
  • filters
  • breaking machine product trays
  • inside of product pipes
  • inspection cup

Finished Product Non-Contact Surfaces

  • packing room sink
  • outside of pasteuriser
  • yellow powder room scale
  • carton conveyor
  • packing room door handles
  • mallet handle
  • pail rollers
  • air vents
  • packers hands or boots
  • lunchrooms (if there are separate facilities for finished product employees)
  • locker rooms (if there are separate facilities for finished product employees)

Raw Product Non-Contact Surfaces

  • outside of homogeniser
  • parts rack
  • ladder rungs
  • air vent
  • breaking room sink
  • hose handle
  • floor squeegee handle
  • clean out of place sinks
  • lunchrooms
  • locker rooms

Please note: The sites listed in the above list are suggested sites. Other sites may still be sampled based on individual station layout and other factors affecting sampling (e.g. compliance).

Important: Do Not mix food contact and non-food contact as well as raw and finished under the same composite.

6.6.2 Sampling Procedure

Every effort must be made to avoid the possibility of contamination of the samples.

Inspectors must wear clean coveralls or lab coats and wash and sanitize their hands before beginning. Rings and watches should be removed.

Under this program, 10 swabs are to be collected from the processed egg station. Normally, 5 swabs are collected for each composite. However, in some stations, sampling sites for a particular composite may be limited. For example, finished product contact surfaces may be limited to the interior of the transfer tank, the filling head and interior of a pail when the station is in production.

If this is the case, it is recommended that at least 3 swabs for the composite be collected. The extra swabs can then be used for sites under the other chosen category.

Reminder: At least one composite should consist of swabs from the finished product area (either contact or non-contact) and be sampled during production.

Note: If a food contact surface is swabbed during production, a E200 sample should also be taken for the product being produced at the time of sampling.

Sampling Methodology for Environmental Swabs

Boiled egg operations are also subject to environmental sampling.

Preparation for Sampling

  • Select all sites to be sampled based on the table in section 6.6.1
  • Plan the order of sampling and record the sites
  • One sample number is assigned for all 10 samples. Identify each swab by using a permanent marker to write the sample number, its composite and sample site on each sample bag.
  • For consistency and ease of identification of analyses for each composite, mark all swabs taken during pre-op as 01 and those taken during production as 02.

Sampling technique

  • Carefully remove cellulose sponge from foil pouch with gloved hand touching only the handle. Rub the surface to be sampled as shown in the diagram.
    • Place the sponge aseptically into the appropriate labelled whirlpack bag.
    • Seal the bag using tamper evident tape, removing excess moisture and air. Ensure that it cannot leak and the contents cannot become contaminated during shipping.

Rub the surface to be sampled

Submitting the Sample to the Lab

A Food Environmental Sampling Form (CFIA/ACIA 5174) is to be completed in the LSTS System:

  • Complete the mandatory details on the submission page that are denoted by Footnote 2. The load per plan will indicate analyses for both Salmonella spp. and Listeria monocytogenes. It is a good idea to use the submission page comment field to provide direction for the lab. In bold letters, indicate the composite number and for what we wish it analyzed. As an Example, swabs for composite -01 are taken pre-operationally and composite -02 are taken during production so an inspector may write C2011EPM0001-01 to be analyzed for Salmonella spp. only and C2011EPM0001-02 to be analyzed for both Listeria monocytogenes and Salmonella spp. As this is instruction to the lab, the inspector should click Do not Display on ROA.
  • select save and add samples
  • enter 2 in the sample box and click on add
  • click on the edit icon for the first sample. Enter the sample number followed by -01 for the first composite.
  • select swab from the drop down menu
  • add the appropriate number of sites sampled including a brief description of each
  • use the sample comments field to detail the nature of the composite (raw or finished and contact or non contact). Again, in the sample comment field clearly indicate if the composite is to be tested for Salmonella spp. only (pre-op) or both Salmonella spp. and Listeria monocytogenes (during production).
  • repeat the steps for the second composite using the designation -02 after the sample number.
  • Samples should be refrigerated as soon as possible after sampling and during transport to laboratory.
  • Ship all samples to the laboratory in the cooler with the freezer packs on top. Samples must not be frozen (protect the samples from direct contact with the freezer packs). The completed laboratory report should also be sent in the cooler.

6.6.3 Follow-ups

If Listeria monocytogenes (Lm) and/or Salmonella spp. are identified in the processed egg station, steps must be taken to eliminate or control the hazard.

  • The station must be immediately notified that one or both of the composites have tested positive for Listeria monocytogenes (Lm) and/or Salmonella spp.
  • The Station manager or designate, should carry out an investigation to determine the problem, including a review of the sanitation program, traffic patterns, ventilation system
  • If the positive is found on a finished product contact surface or on non-contact surfaces in a finished product packaging room, an assessment should be done by the inspector and station personnel to determine if the product packaged at that time was affected. This may be done by reviewing lab results or assessments of product within the company's control. For Category 1 products, Health Canada's policy recommends products produced on the positive line be held pending satisfactory results from follow up testing.
  • The follow-up sampling will consist of 5-10 samples, depending on whether one or both composites tested positive. Each of the sites in the original positive composite is to be swabbed. Swabs are not to be composited.
  • Where a positive was found in the finished product packing room, 5 swabs should be taken on contact surfaces and an additional 5 swabs on non-contact surfaces. Product being produced that day should also be sampled and submitted to the lab for Listeria monocytogenes (Lm) and/or Salmonella spp.analysis (E200D).
  • Where a salmonella positive was found in the raw product area, each location identified in the original sample is swabbed again after corrective actions have been implemented. Additional sites may be sampled (focusing on contact surfaces) to use up any remaining swabs in the kit. Swabs are not to be composited.
  • These follow up samples will be analysed individually by the lab to determine if the corrective action has been effective.
  • The follow-up should be done as soon as possible after the corrective actions have been implemented.
  • Follow-up sampling should not be carried out using a number from the original list of sample numbers. A special follow-up number is to be obtained through the Regional Program Officer or Area Egg Specialist.

If the follow-up is found to be positive:

  • The station must be immediately notified that one or more of the swabs have tested positive for Listeria monocytogenes (Lm) and/or Salmonella spp.
  • The station is expected to carry out their own environmental sampling as per their Quality Assurance Program.
  • A second follow-up sampling is to be done. The follow-up should be done as soon as possible after the corrective actions have been implemented.
  • If the follow-up positive was found in the finished product packing room:
    • a more intensive investigation is conducted
    • The site of the positive is evaluated to determine if the product should be held or a piece of equipment should be removed from production.
    • An assessment should be done by the inspector and station personnel to determine if the product packaged since the original positive was affected.
    • 5 swabs should be taken on contact surfaces and an additional 5 swabs on non-contact surfaces. Product being produced that day should be sampled and submitted to the lab for Listeria monocytogenes (Lm) and/or Salmonella spp. analysis (E200D).

Note: In the case of Lm positives, it is recommended that follow-ups be conducted in accordance with Health Canada's policy on Listeria monocytogenes in Ready-to-Eat foods.

6.7 Sampling Plan E202 - Wash water Sampling

The purpose of the wash water sampling program is to determine if a processed egg station has an acceptable method for controlling the quality of the water used for washing eggs. An acceptable method is one where the washer is clean, and the eggs are being washed in water that will effectively clean off any adhering dirt without causing contamination in the process. This is achieved by keeping the microbial counts in the wash water below 100,000 ACC per ml. Generally this is achieved by maintaining a clean washer, maintaining a wash water temperature of 43°C (109°F) or more, and a pH level of at least 10.5.

Frequency:
One machine/station/quarter

Distribution:
Original to Lab
Copy filed in the CFIA Inspection Office
Copy sent to the Egg Supervisor or designate (optional)

Sampling Method

  • Take the 3 samples at well spaced intervals during one shift. Water temperature and pH measurements should be recorded on the lab submission form.
  • Using an 8 oz. sterile sample cup, collect the egg wash water from the re-circulating tank by ladling the wash water into the sample cup and filling to the 6 oz. mark. If the operator has a spigot on the tank for drawing samples flush it out well prior to taking the sample.
  • Note: Record the temperature and pH of the wash-water on the Sample Submission Form.
  • The samples must be cooled as quickly as possible to temperatures between 2°C and 4°C (35 - 40°F) and maintained at this temperature until received by the laboratory. The lab will discard samples received above 10°C.
  • Ship all samples to the laboratory in the cooler with the freezer packs on top. Samples must not be frozen. The completed laboratory report should also be sent in the cooler.
  • Note: To avoid unnecessary re-sampling, additional cooler packs (hard plastic packs are more effective than foam packs) need to be added during warm weather to ensure that the samples do not arrive at the lab temperature compromised.

Follow-up

  • Notify station manager or relevant station designate of the results
  • Ask the station to take corrective actions
  • Obtain E202D sample numbers for follow-up sampling
  • Re-sample as soon as possible after corrective actions have been completed
  • Remove points for washwater on the Processed Egg Station Sanitation and Operation Report (CFIA/ACIA 1082) when results are over 1,000,000.

6.8 Sampling Plan E104 - Composition Sampling Program (Fatty Acid Profile, Cholesterol, DHA, Lutein, and Vitamin E)

Frequency:
According to dates in the annual sampling plan

Record:
Food Product Sampling Submission Form CFIA/ACIA 5174

Distribution:
Original to Lab
Copy filed in the CFIA Inspection Office at the registered station
Copy sent to the Egg Supervisor or designate (optional)

Sampling Instructions for Processed Egg - Monitoring- E104

Processed egg products that have Omega-3, DHA, Vitamin E, lutein or cholesterol claims should be sampled under this sampling plan. (DHA is Docosahexaenoic acid which is an omega-3 essential fatty acid).

  1. In order to ensure random sampling, the following procedure should be followed:
    • From the lot of processed eggs to be sampled, select three (3) cartons of product (250 or 500 ml cartons). It is recommended that the cartons are sent to the laboratory intact.
    • Where the product is packed in larger containers, take 250 ml from each of three containers, and combine the product in a suitable container (plastic sample cups or screw cup Mason jars are both acceptable). Seal the sample with tamper evident tape. Freeze samples immediately and ship in a frozen state.
  2. Ensure that the LSTS sample submission form has been accurately filled out. For monitoring samples, the sampling plan number is E104. Include the expiry date, the correct brand name and any quantitative claims made outside the Nutrition Facts Table (e.g. 0.085g DHA per serving).

    Important: Send a copy of the label to the laboratory with the sample.

  3. Ship the samples with freezer packs using overnight delivery to:

    Canadian Food Inspection Agency
    Longueuil Laboratory - Chemistry (Food)
    1001 rue Saint-Laurent Ouest
    Longueuil
    QC J4K 1C7

  4. At the laboratory, the sample will be analysed for total fat (triglycerides), cis-Monounsaturated fatty acids, cis-Polyunsaturated fatty acids, saturated fatty acids, Omega-3 fatty acids, Omega-6 fatty acids, Vitamin E and trans fatty acids, based on Association of Analytical Communities (AOAC) 996.06, for cholesterol based on AOAC 994.10. The levels of DHA istested using the method “Laboratoire Chimie Alimentaire du Québec” LCAQ-094 based on the Journal of Food Composition and Analysis. Lutein will also be analysed if required.

Sampling instructions for Processed Egg- Directed (follow-up) E104D

When laboratory results are found to be unsatisfactory for any tests in the fatty acid profile other than cholesterol, Omega-3 fatty acids, DHA, & Vitamin E a follow-up sample should not be taken. The inspector notifies the station operator of the unsatisfactory result and asks them to take corrective action. The station's own composition testing should be reviewed. The station is responsible for labelling their products accurately.

Where laboratory results are found to be unsatisfactory for cholesterol, Omega-3 fatty acids, DHA, lutein or Vitamin E, a follow- up sample should be taken.

Where a follow up is required, the following steps should be taken:

  1. A follow-up sample number should be obtained from the Regional Program Officer or Area Egg Specialist.
  2. In order to ensure random sampling, the following procedure should be followed:
    • From the lot of processed eggs to be sampled, select twelve (12) cartons of product (250 or 500 ml cartons). It is recommended that the cartons are sent to the laboratory intact.
    • Where the product is packed in larger containers, take 250 ml from each of twelve containers, and combine the product into three (3) suitable containers (plastic sample cups or screw cup Mason jars are both acceptable) by grouping four (4) 250 ml sub-samples into each container. Seal the sample with tamper evident tape. Freeze samples immediately and ship in a frozen state.
  3. The inspector is responsible for the sample continuity from the time of the selection of the samples to the time that the samples are shipped.
  4. Ensure that the LSTS sample submission form has been accurately filled out. For follow-up samples, the sampling plan number is E104D. Include the expiry date and the correct brand name and any quantitative claims made outside the Nutrition Facts Table (e.g. 0.085g DHA per serving). The original sample number that triggered the follow-up sample should be included in the comments section of the lab submission form. Send a copy of the label to the laboratory with the sample.
  5. Notify the laboratory that a follow-up sample will be arriving under the E104D sampling plan. Ship the samples with freezer packs using overnight delivery to:

    Canadian Food Inspection Agency
    Longueuil Laboratory - Chemistry (Food)
    1001 rue Saint-Laurent Ouest
    Longueuil QC J4K 1C7

  6. The laboratory Report of Analysis for E104D follow-up samples will show individual results for each of the three sub-samples, as well as the mean. The assessment will be made based on the Nutrition Labelling Compliance Test.

    When results from the follow-up sample are unsatisfactory for Cholesterol, Lutein, Omega-3, vitamin E, or DHA, appropriate enforcement action should be taken. Refer to the Minimum enforcement guidelines (MEGS) - (Internal access only).

    Cholesterol, Lutein, Omega-3, vitamin E or DHA follow-ups are subject to cost recovery charges. See Chapter 12- Processed Egg -Cost recovery for additional information.

    Note: All samples must be shipped to the lab in the first week of the month.

6.9 Packaging and Securing of Samples

Because samples must be shipped to laboratories off premises, care must be taken to secure and package them properly.

Important: All samples and secondary containers (shipping boxes) must be sealed prior to being sent to the lab (CFIA or 3rd party labs) for analyses. These should be sealed using tamper evident tape (CFIA/ACIA 4561- Yellow tape-Official approved seal).

Procedures:

  • Inspectors should secure the cup lids with tamper evident tape before shipping.
  • Once the lid is taped, the inspector is to initial the tape over top of where the tape ends.
  • Frozen samples should be packed upright in an insulated container with as many freezer packs as necessary to maintain their frozen state.
  • A box lined with Styrofoam insulation is the usual method used to ship samples.
  • If a partial box is filled, newspaper or other soft packaging material can be used to prevent cups from shifting during transport.
  • Dried samples can be shipped in a sturdy box.
  • Enclosed samples in a sanitary plastic bag and use tamper evident seal before placing in the shipping container.
  • Dried samples may be shipped with frozen samples and/or environmentals as long as segregation between samples is maintained (use sanitary plastic bags).

6.10 Shipping of Samples

Samples should be shipped by the quickest method practical (usually a same day or overnight courier with person to person delivery). Care should be taken to verify that all shipping information is correct and that any information regarding shipping times or conditions is properly marked on the box. This will help retrieve lost shipments and prevent damage or overheating of contents.

6.11 Non Compliant Product

Product that fails to meet the requirements of any laboratory test, whether conducted by a CFIA lab or any other lab accredited by the Standards Council of Canada (SCC) must be handled in such a manner to ensure that human health and/or product quality is not compromised.

Solids/Moisture

  • If a product fails to meet the standards set out in the regulations for solids/moisture, the lot fails and is detained. Averaging with previous lots is not permitted.
  • An 0.1% lab tolerance will be applied on all solids and moisture results. For example, the inspector does not take action if the result for whole egg is greater than or equal to 24.1%.
  • The station should be notified of the non-compliant result so that they may take appropriate action.
  • The inspector reviews the station's refractometry reading, from their production records, of the lot in question and discusses any concerns with a quality control or designated representative from the station.
  • If the lot is not in compliance, the lot must be held and reworked or otherwise handled to meet the regulatory standards.
  • No recall will be initiated as this is not a health and safety issue.
  • The next three lots of the same product are held pending lab analysis for solids/moisture using approved methodology.
  • The analysis is to be performed by the station using an approved methodology at their expense.
  • If the three lots are within the standard no further lots are held.
  • If one of the lots is not in compliance, further lots are held pending analysis (until three consecutive lots are within compliance) and an action plan to correct the problem is to be submitted by the station operator to the CFIA.
  • If further problems persist the station's registration status may be subject to review.
  • As an option, prior to reviewing the status of the station's registration, the operator may identify the product in question as Egg Product until they can prove they have corrected the problem. To achieve this they will need to submit 10 consecutive lots of the product in question for testing using approved methodology with no violations.
  • All resulting actions and communications with the station operator are to be documented in form CFIA/ACIA 5109 and filed.

Salmonella/Listeria monocytogenes

Because of the pathogenic nature of Salmonella spp. and Listeria monocytogenes, contamination of a product with one of these organisms is a serious issue. Whether the sample result comes from a CFIA lab or any other lab accredited by the Standards Council of Canada, the following steps must be followed:

  • The inspector should contact the Area Egg Specialist
  • Immediately notify the station management to initiate their recall program.
  • If the lot was tested by a lab accredited by the SCC, the company must notify CFIA staff immediately upon receiving the results.
  • Where the lot can be located it is immediately detained.
  • If some or all of the lot has left the direct control of the processing facility, the Office of Food Safety and Recall (OFSR) is to be contacted immediately and they will classify and direct any recall.
  • The affected lot must be reprocessed.
  • Accurate records are to be kept by the station, available to CFIA detailing the reworking, including number of containers reworked at a time and the lot number and product type of the lot the affected containers were added to.

Follow-up

  • Ten consecutive lots from the same product line are to be held pending lab analysis for salmonella or Listeria monocytogenes at a SCC accredited lab using approved methodology at their own expense.
  • If all ten lots pass, no further lots need to be held.
  • If a lot fails, more lots are held until ten consecutive lots pass analysis.
  • Stations should review their sanitation program and product handling practices in all cases of positive Salmonella spp. or Listeria monocytogenes. Pasteurizer should be tested for pin holes and thermometer accuracy.
  • An environmental sample of the finished product packing room must be taken by CFIA staff using a surveillance sampling plan number
  • If a follow-up lot or environmental sample is positive, an action plan regarding station sanitation and product handling must be submitted to the CFIA.
  • Continual problems with either Salmonella spp. or Listeria monocytogenes contamination may result in a review of registration status.
  • All resulting actions and communications with the operator are to be documented on CFIA/ACIA 5109 and filed.

SPC/Coliform

  • If a product fails for high Standard Plate Counts (SPC) or coliforms, it is detained and reprocessed and the Area Egg Specialist is notified of the failure.
  • The next five lots of the same product line are sampled but not held pending lab analysis. Obtain E200D sampling number for these lots.
  • If the five lots are within standard, resume normal sampling schedule.
  • If one of the lots is out of compliance, further lots are detained until five consecutive lots meet the regulatory standard and the station must submit an action plan to CFIA in order to correct the problem and prevent re-occurrences.
  • If the problem persists, the station's registration may be subject to review. (For any suspension or cancellation of registration or process related to thereof, please refer to Chapter 11 - Compliance and Enforcement, Appendix I).
  • All resulting actions and communications with the operator are to be documented on aCFIA/ACIA 5109 and filed.

6.12 Detentions

All lots that fail analysis for salmonella, listeria, SPC or coliforms or organoleptic evaluation must be detained. Stations maybe permitted to use their own hold tags however, if securing the lots is an issue, a CFIA detention tag should be placed on the lot. See the Enforcement and Compliance chapter of this manual for instruction on completing the detention correctly.

6.13 Station Quality Assurance Program

Every federally registered processed egg station is required to have products analysed for microbiological and compositional analysis, as outlined in their quality assurance program.

The lab must be accredited for the specific test used. Information on Scope of Accreditation of each lab accredited can be found through the Standards Council of Canada.

A station may wish to take samples from every lot and hold them in case analysis is required at a later date.

In-house testing is encouraged. On a regular basis samples should be sent to a lab accredited by the Standards Council of Canada, to confirm in-house results.

It is recommended that environmental sampling be conducted by the station in order to monitor the effectiveness of the sanitation program.

The inspector is to review these results on a quarterly basis to monitor continued compliance with regulatory standards.

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