CFIA allows you to pack prior to chilling? That doesn't sound right to me
To satisfy CFIA (and yourself) you need to perform a validation it will be similar to shelf life testing, where by the sealed cuts will be stored in a lab under controlled conditions, and tested for Cbot over a period of time (whatever you have set your shelf life by)
depending on the results you get back, you would then put that into a validation study summary, ideally you'd repeat that testing more than once to confirm the results
Buuuuuuuuuuut you may not win this one with CFIA
E. Chilling
The licence holder must ensure that the refrigeration and chilling procedures are carried out in accordance with the guidance documents and regulatory requirements.
To meet the performance criteria the licence holder must demonstrate the following:
- refrigeration of carcasses must begin promptly after the end of carcass dressing and product must be cooled as quickly as possible
- for carcasses and cuts (primary cuts, sub-primary cuts, cuts and trims), the operator shall ensure and demonstrate in an ongoing manner that they are achieving compliance with cooling performance standards
- carcass parts can be cooled in potable water, air chilled, packaged immediately after harvest or after partial chilling and blast frozen on site or in a remote location shortly after harvest
- using carbon dioxide in the packaging, or chilling individually vacuum packed offal in brine tunnels are also acceptable options
- the cooling of the carcass part is continuous at the level of its surface of concern
- product temperature requirements must be met at the time of shipping
https://inspection.c...0834?gf#1.1bc_5