There is still much unknown about bovine spongiform encephalopathy (BSE); however, research strongly indicates that the disease is spread when cattle consume protein derived from BSE-infected animals. As a precautionary measure, Canada implemented a feed ban in 1997 prohibiting the feeding of ruminant animals with most mammalian proteins.

This type of feed ban provided an appropriate level of animal health protection for a BSE-free country. Now that Canada has detected an indigenous case of the disease, the Government of Canada has identified the need to reinforce feed controls to further mitigate the risk of BSE spread in Canada’s national cattle herd.

The international team of animal health experts that reviewed Canada’s BSE investigation recommended a series of actions to strengthen national animal health and food safety measures.  Canada has implemented all but one of the team’s key domestic risk management recommendations: the removal and redirection of SRM from animal feed.

Government officials have consulted extensively with industry groups and stakeholders regarding enhancements to existing feed controls.  On July 9, 2004, the Minister of Agriculture and Agri-Food announced the Government’s intention to develop and implement enhanced feed controls consistent with the recommendations from the international team.  The United States Food and Drug Administration also announced its preliminary intention to strengthen feed controls.

The existing framework of the 1997 feed ban will be maintained and enhanced by amendments to the Meat Inspection Regulations, Feed Regulations, Fertilizer Regulations and Health of Animals Regulations to prohibit specified risk material (SRM) from use in animal feed, pet food and fertilizer.  The Government of Canada already requires the removal of SRM from the human food supply.  SRM are cattle tissues that may contain the agent that causes BSE.  The proposed amendments would define the scope of SRM as including proteins derived from the complete list of SRM already being removed from the human food supply; dead stock and condemned cattle containing SRM; plus any other ruminant dead stock and condemned ruminant animals. 

Preventing SRM from entering the feed production chain enhances the existing feed ban by diminishing the effects of potential cross-contamination of animal feeds that could occur as feed is produced and distributed, as well as any inappropriate on-farm use.  The provision to prohibit the use of SRM in fertilizers is intended to prevent the potential accidental or intentional misuse of fertilizers as feed.  As well, it addresses the possibility that contaminated grazing pastures could spread BSE, although the current science surrounding the environmental behaviour of the disease is incomplete.

The primary mechanism for controlling SRM removal through to its disposal would be a requirement to obtain a CFIA permit to receive, remove from the premises, use convey, treat, export or destroy SRM in any form.  The overriding consideration in establishing permit conditions would be to induce effective segregation of SRM from the animal feed chain and to prevent its subsequent re-entry.  Permits would only be issued for disposal of SRM if it were through incineration or another method that would ensure the SRM or carcass would not be used as food for humans or animals and would not enter the environment in such a way that it could contaminate any water or food supply.

Permits would not be required for SRM or dead stock if they are destroyed or disposed of on the farms where they originate.  However, the disposition of these materials on farms would still be subject to any provincial agricultural, environmental or public health control measures in effect.  This approach addresses the practical difficulties that would be faced by the CFIA in enforcing compliance on such a large number of individual farms.  It also recognizes provincial and municipal responsibilities for environmental and waste management on farms.

Renderers would be required to use processing controls designed to assure a minimum 90% reduction in infectivity in non-SRM ruminant ingredients, to dedicate production lines and equipment within facilities and to stain meat and bone meal used for animal feed.

Commercial feed mills would be required to apply more direct warning labels, to provide complete ingredient lists and to stain feeds containing non-SRM ruminant material to enhance producer awareness.    In order to export a rendered product, or a feed or fertilizer from a rendered product, it would be necessary to obtain an export certificate from the CFIA to prevent Canada from spreading BSE to other countries.

The proposed regulations have been placed in the Canada Gazette Part 1. A 75-day comment period ending February 24, 2005 is being provided to give regulated industries, trading partners and other interested parties the opportunity to review the proposed amendments and provide the CFIA with written comments. 

Copies of the proposed amendments can be obtained from the CFIA website or the Canada Gazette website or by phoning the CFIA at 613-225-2342.
 

References:
CFIA. New Regulations Proposed for BSE-Related Feed Controls. News Release: December 10, 2004.
CFIA. Backgrounder on New Regulations Proposed for BSE-Related Feed Controls. News Release: December 2004.