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Consultation paper

Revising the Canadian Food Inspection Agency's TSE import policy for small ruminants and their products

The Canadian Food Inspection Agency (CFIA) is proposing to revise its TSE import policy for small ruminants (sheep and goats and their exotic relatives) and their products. After having established a clear domestic regulatory response to the detection of BSE in Canada and publishing a revised BSE import policy, and after having implemented major modifications to the domestic national scrapie program it is appropriate to now update the import policy for small ruminants.

This consultation paper and the associated draft import conditions are being provided to Canadians and to our trading partners for comment. The CFIA intends to finalize this policy and begin taking the steps necessary to implement it as soon as possible after taking into account any comments received.

Comments are requested by November 30, 2006 and may be addressed to the Director of Animal Health (see details at the end of this paper).

Background

Canada's TSE Safeguards

Over the past two decades, Canada adopted ever expanding import restrictions in order to prevent the importation of TSEs. Import restrictions continue to prevent additional infectivity from entering Canada. In 1997 a mammalian (other than porcine and equine) to ruminant feed ban was implemented in order to limit the distribution of the TSE agents. To further augment its BSE safeguards, the Government of Canada has published regulatory amendments that require the removal of bovine SRM from the animal feed chain. This measure will add an additional level of security to the feed ban by preventing these potentially infectious materials from entering the entire feed production chain. This will minimize opportunities for potential cross-contamination of ruminant animal feeds that could occur as feed is produced and distributed, as well as any inappropriate on-farm use.

Unlike BSE in cattle, horizontal transmission from excretion of large amounts of the scrapie agent into the birthing environment is recognized as the primary route of transmission for scrapie. Transmission studies of BSE in sheep determined that the BSE agent may be spread in small ruminants in a similar horizontal manner as scrapie, although at a lower frequency.

To date, no case of BSE in small ruminants has been diagnosed in Canada by discriminatory testing of scrapie positive animals. When scrapie is diagnosed in Canada, the national scrapie program requires high risk animals to be destroyed and definitively tested for scrapie. If additional cases are found, additional risk groups of animals are destroyed and tested for scrapie. A recently validated live animal test has been implemented for use in screening all potential source flocks and herds. All premises subject to the disease control actions are required to conduct ongoing deadstock surveillance.

Canada's Current Import Policy

Canada's existing BSE import policy for small ruminants, which was established in 1997, prescribes conditions for commodities considered to present a risk for BSE and for which the Canadian Food Inspection Agency (CFIA) has legislative responsibility. Those commodities included in the existing policy are: live ruminant animals; embryos from sheep and goats; edible meat and meat products derived from ruminant animals; inedible rendered protein and products containing such protein from all regulated animal species; inedible tallow; animal blood; livestock feed; products and by-products containing specified risk materials; cell lines originating from bovine tissues; and, veterinary biologics.

In summary, the current policy permits the importation of live small ruminants and most products derived from them only after the exporting country has been assessed and officially recognized by the CFIA as BSE-free. A limited range of commodities are exempt from BSE-specific conditions regardless of the BSE disease status of the exporting country.

This policy reflects North American thinking at the time the policy was developed.

Relationship with International Standards

The draft revised import policy incorporates the current the World Organisation for Animal Health, formerly known as OIE, guidelines for recognition of a scrapie free country and a scrapie free establishment. However the World Organisation for Animal Health, formerly known as OIE guidelines are currently silent on the issue of BSE in small ruminants as well as the application of genetic screening for mitigation of risk of TSEs in sheep.

Scope of the proposed revised policy

As the scientific understanding of the transmissible spongiform encephalopathies (TSEs) has evolved, significant differences in the pathogenesis and associated risks of these diseases within the different species have been clarified. In order to appropriately address these differences, Canada's import policies, conditions and procedures pertaining to bovines, small ruminants and cervids are being separated. The attached document outlines policies, conditions and procedures that are meant to address TSE risks of both BSE and scrapie in importing small ruminants (sheep and goats) and associated products.

Framework of Proposed Import Policy

Canada's draft revised TSE import policy for small ruminants can be summarized into 4 major categories of importations:

• Importation from a country recognized free or negligible risk for TSEs in small ruminants;
• Importation from a premises free from TSEs in small ruminants;
• Animals that will be slaughtered prior to an age where they would pose a significant disease risk;
• Products harvested from animals in the above described categories.

An additional category:

• Importation of genetically resistant breeding sheep or embryos was originally proposed but due to the recent discoveries of atypical TSE's, it has been decided that it is premature to add this category at this time.

Next Steps

This consultation paper and the associated draft import conditions will be provided to Canadians and to our trading partners for comment. The CFIA intends to finalize and begin implementing a revised import policy as soon as possible after this comment period and after taking into account comments received and after any necessary regulatory amendments.

Comments are requested by November 30, 2006. They should be addressed to:

Dr. Francine Lord
Director of Animal Health and Production Division
Canadian Food Inspection Agency
Floor 2, Room 237 W
59 Camelot Dr.
Ottawa ON K1A 0Y9

Technical questions may be addressed to:

Dr. Penny Greenwood / Dr. Samira Belaissaoui
Animal Health and Production Division
Telephone: 613-221-4612 / 613-221-4005
Fax: 613-228-6144

September 2006

• Proposed Import Conditions for TSE in Small Ruminants