CIci, you're going to have nothing but problems with CFIA if "the plant" decides everything prior to the chiller is not food. You are going to get a CAR for this and if you continue to process this way after they tell you you can't, and they see it at subsequent audits, you will be given a 7 day notice to change it.
If you don't treat all surfaces as food contact, you are jeopardizing meeting this requirement https://inspection.c...4/1539715737915
You are aware almost ALL of chapter 19 has been incorporated by reference and is still the law right?
A licence holder cannot identify as edible any meat product that is contaminated. Possible contamination of the meat products is prevented by ensuring hygienic procedures during dressing and evisceration. When contamination inadvertently occurs, it will be promptly identified and hygienically removed by the operator, as described in the Standards to identify a meat product as edible. Please consult Dressing procedures and Preparation of edible parts to ensure that you implement the best hygienic practices to achieve this.
Equipment should be cleaned and sanitized if it comes into contact with contamination (or parts that by nature can be considered contaminated/inedible), pathological defects or any biological, chemical or physical hazards. Particular care in this matter should be taken for the following:
I suggest management actually read the regulations