EU ANIMAL BY-PRODUCTS REGULATION (EC 1774/2002)

laying down health rules concerning animal by-products not intended

for human consumption

enforced by

ANIMAL BY-PRODUCTS REGULATIONS (NI) 2003

(SR No. 495)

DRAFT GUIDELINES

FOR THE SEPARATION OF CATEGORY 1, 2 AND 3

MATERIAL AT RENDERING PLANTS IN NORTHERN
IRELAND

Please note: The information contained herein is to assist with the

understanding of the above legislation. It is not a definite interpretation
of the law which only the courts can provide.

Department of Agriculture and Rural Development

Animal Welfare and Trade Branch

Version 1: May 2004

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ANIMAL BY-PRODUCTS REGULATION DRAFT GUIDELINES FOR THE

SEPARATION OF CATEGORY 1, 2 AND 3 MATERIAL AT RENDERING
PLANTS IN NORTHERN IRELAND

These guidelines are not definitive, as each rendering plant is different and
will need to be assessed on an individual basis. However, we hope that the
following will provide an indication of the issues that should be addressed.

1. The provisions relating to the structure and operation of rendering plants

are set down in Annexes V (all plants), VI (Category 1 and 2 plants) and VII
(Category 3 plants) of the Regulation.

Annex V, Chapter I requires that

Premises for the processing of animal by-products must not be at the

same site as slaughterhouses unless in a completely separate building.
Unauthorised persons and animals must not have access to the plant.

Annex VI, Chapter I requires that

The layout of Category 1 and Category 2 processing plants must

ensure the total separation of Category 1 material from Category 2
material from reception of the raw material until despatch of the
resulting processed product.

Annex VII, Chapter I requires that -

Premises for the processing of category 3 material must not be at the

same site as premises processing category 1 or category 2 material,
unless in a completely separate building.

2. We consider that, ideally, different categories of animal by-products should

be rendered on separate sites. In particular, we would wish to see Category 3
animal by-products rendered on separate sites from any other animal by-
products. However, we recognise that it will not always be reasonable to
require this in practice and that some rendering plants will wish to render
more than one type of material on the same site.

3. Within each category, separation between lines processing different

species may also be desirable. Currently, the outputs of mammalian, fish and
poultry lines may all have different uses if they are guaranteed free of
crosscontamination. Separation between clean and dirty areas in all
categories will continue to be regarded as critical.

4. There is therefore a need to consider how the risk of crosscontamination

between the different categories and species of animal byproducts can be
minimised on such sites. This is necessary to ensure that material derived
from Category 3 by-products and intended for use in livestock feed or petfood

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is not contaminated by other animal by-products (processed or not). It is also

necessary to ensure that all Specified Risk Material is fully accounted for and
does not contaminate any other category of animal by-products.

5. To minimise the risk of cross-contamination, adequate physical separation

will be needed between the areas dealing with the various categories of
animal by-products. Suitable operating procedures will also be needed to
ensure that equipment, staff, etc. do not cross-contaminate the material.

6. The separation, which must be guaranteed at all times, will apply to at least
the following

reception bays;
pre-processing operations eg pre-breakers;
processing operations;
use of mobile equipment;
personnel movements;
maintenance procedures;
post-processing eg separation of tallow and greaves, and milling of
the meat and bone meal; and
storage and despatch of processed products.

Physical separation

7. The requirements of the Regulation suggest that three issues need to be

clarified

What is a separate building?

What is a separate part of the building?
What is total separation?

Separate building

8. It is not possible to give an interpretation that will cover every case but
generally speaking, we will interpret building as meaning one or more
buildings which are operated as a single operation.

9. At one end of the scale this could include a large factory site with a number
of production lines and with shared areas, staff and equipment. That site
would be a single premises. At the other end of the scale would be an
individual building among other buildings, but which was run as a completely
separate operation. That building would also be a separate premises.

10. Where a site has more than one building, the individual buildings can be
treated as being separate if they are operated completely separately, ie they
have separate entrances, reception bays, equipment, exits and personnel. It
is recognised that there may be some common facilities, eg canteen, offices,
waste water treatment systems and boilers, but these must not represent a

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source of cross-contamination. There must be no sharing of equipment,

personnel, etc. and operating procedures must be in place to ensure that they
are only used on the dedicated lines. The only exception should be
maintenance and management staff who should follow the procedures in the
SOP.

11. Some buildings have been divided by a solid wall, from floor to ceiling,
such that there is no access between the two parts of the building and no
shared air space. We do not consider that such semi-detached buildings
should also be considered as separate buildings even if they are run as
separate operations, because the risk of material being accidentally sent into
the wrong side of the building is too great to permit such operations. Although
this differs from our usual interpretation of premises, we think it clear that the
Regulation intends to distinguish a building that has been divided in some way
from one that has not. We would therefore not approve the use of a divided
building to render category 3 material unless both or all parts were used to
process the same category and species of material.

Separate part of building

12. Similar considerations would apply. However, we consider that rendering

lines for category 1 and 2 material could be adequately separated within a
building ie by a dividing wall from floor to ceiling (such that there is no shared
airspace) or by dividing partitions (where there may be shared air space).
Provided the operations remain separate, as above, and there is no access
from one operation to another through the partition, we could consider the two
parts of the building to be separate.

13. However, where a slaughterhouse and a rendering plant are on the same
site, the operations must be in completely separate buildings. [NB The UK has
asked for a transition period in respect of Category 3 rendering plants on the
same site as a slaughterhouse.]

Total separation

14. The requirement for total separation relates to Category 1 and 2 rendering
plants. The above requirements imply that this means that category 1 and 2
material must be processed in a separate part of the building. We would
consider that this should be interpreted in the same way as separate part of
the building.

Operational separation

Mixing of materials

15. Specified risk material must be kept separate from other animal
byproducts until both types of material have been weighed. It may then be
mixed with the other animal by-products and rendered as SRM (Category 1
material). Other categories of material may be treated similarly, and treated as

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the higher risk category (ie a mix of Category 2 and 3 material must be
rendered as Category 2 material).

Standard Operating Procedures

16. All rendering plants must have a Standard Operating Procedure (SOP)
based on Hazard Analysis and Critical Control Points (HACCP) principles to
guarantee the separation of the different categories of animal by-products. An
adequate SOP will need to be in place, and followed, before approval is
granted.

The SOP must address

Common and shared areas

The SOP must specifically address how common and shared areas will
be policed and clearly indicate the procedures to be adopted if cross
contamination occurs.

We consider that common areas are those areas which are on the site
but where no animal by-products are handled eg canteens, offices,
waste water treatment plants and boilers. Cross-contamination can be
avoided through operating procedures eg staff must remove their outer
clothing and change their footwear before going to the common area.

Shared areas are those areas on the site where animal by-products are
handled or transported. For category 1 and 2 lines, shared areas may
occur inside the building eg

raw material intake and storage within the same airspace;

two or more cookers in the same airspace;
common control point for cookers, augers, presses and other
equipment; and
post-processing storage areas in the same airspace

or outside the building eg

weighbridge;
entrances from the public highway;
lorry parking and washing.

Spillages of any animal by-products and/or processed products in the

shared areas must be reprocessed as the highest risk category. Solid
material recovered from drains must also be treated as material in the
highest risk category.

Where the site renders Category 3 material or any category of

nonmammalian material, we would not approve the site to also operate
a SRM collection centre. SRM collection centres could, however,

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operate on sites which rendered Category 1 or 2 material. Where the

site does not have a Category 1 rendering line, processing or
reprocessing of spillages and solid material must take place at another
premises.

Storage

Unprocessed animal by-products must be stored separately unless

they are to be mixed and rendered as the higher risk category.

Processed products must also be stored separately unless they have

been processed to the standards applicable to the higher risk category
material and are to be disposed of in the same way as that material.
(For example, if category 3 material is to be stored with category 1
material and then landfilled, all the material must have been pressure
cooked (133oC, 3 bar pressure, 20 minutes).)

Processed animal protein derived from Category 3 material which could

be used in feedingstuffs or petfood must be stored in new or sterilised
bins or in properly constructed bulk bins, kept dry and prevented from
casual contamination. The storage facilities must be emptied and
cleaned regularly, as production requirements require. Handling
equipment must also be kept clean and dry, and inspected regularly.

Equipment

Equipment must be dedicated to one class of animal by-product. This is

relatively easy to guarantee for fixed equipment eg cookers, grinders
and presses. However, the SOP must address this issue for mobile
equipment eg containers, shovels, etc., for example by colour-coding or
labelling them.

Maintenance and emergency repairs

Routine or scheduled maintenance should normally be carried out

while the premises are not working. Emergency repairs may be
required at any time and equipment may need to be replaced or
repaired. The SOP must address the procedures to be followed in the
following circumstances

fully enclosed lines which must be opened;

spillages of animal by-products (raw, part-processed or fully
processed);
leakages from equipment.

Maintenance staff must ensure that their routine work does not result in
different classes of animal by-products contaminating each other. This
may necessitate change of clothing and footwear when working in
different parts of the premises. The SOP must address this issue.

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Clear procedures must be specified in the SOP for dealing with any
failures or breakdowns in equipment or machinery.

Staff

A member of staff must be nominated and be made responsible for

each critical control point. This person must take all reasonable steps
to ensure that the SOP is adhered to by all staff and visitors.

All staff working in the premises must be adequately trained for their
job(s). The training must include the SOP and any critical control points
within their areas of responsibility. A written record of such training must
be maintained.