Animals > Animal Diseases > Bovine Spongiform Encephalopathy  

Risk Assessment on Bovine Spongiform Encephalopathy in Cattle in Canada
Part A: Evaluation of Risk Factors

Table of contents | List of tables | List of figures | List of appendices | Acronyms | Acknowledgments
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5. IMPORT

5.1. Import Policies

5.1.1. Overview of Import Policies and Legislation

In the early 1980s, before the advent of animal health risk analysis, while few efforts were made to actually quantify the risk associated with importations, Canada was protective of its animal health status. The import of products that would introduce foreign diseases was not allowed. Given that the major disease of interest was foot-and-mouth disease (FMD), many animal products that had the potential to spread BSE (such as tankage and meat meal) were not allowed to be imported except from the U.S. Cattle from Europe (which was, at that time, still experiencing FMD outbreaks in certain countries) were subject to extensive testing and lengthy quarantines, an expensive process that limited the number of imports.

In the late 1980s, in response to domestic and international trade initiatives, the regulatory process was reviewed with respect to the import of animals and animal products. The resulting 1988 General Import Policy for Inedible Meats and Animal Products specifically defined the conditions under which certain animal products could be imported. The import of commercial shipments of meat meal, blood meal, bone meal, and other inedible meat products from countries other than the U.S. was prohibited. While not directed at BSE, these measures nevertheless reduced the probability of BSE entry.

However, the 1988 General Import Policy had a greater impact than originally envisaged. The clear definition of conditions and rationale for import decisions created a situation whereby all import conditions were now subject to review and challenge based on science. This ongoing review, coupled with improved health status in many European countries, led to restrictions being eased for certain countries.

Meanwhile, BSE was emerging as a significant disease in the U.K., and there was evidence of its spread to other European countries. Canadian import policies and practices were amended accordingly. In 1990, an import ban was placed on cattle from the U.K., in 1991 the import of beef products from European countries not free of BSE was banned, and in 1994 a ban was imposed on the import of cattle from countries where BSE had been diagnosed in native cattle.

All animals and most animal products originating from Europe required (and still do require) an import permit before being imported into Canada. Throughout this period and until 1998, the issuance of import permits was the responsibility of CFIA headquarters. The import specialists were aware of the growing problems with BSE, and as a result, import permits were not issued if there was concern about BSE risk. Similarly, requests for approval of meat establishments in countries considered to be at risk for BSE were deferred.

Several commodities, including feeds, live animals, animal products and by-products, veterinary pharmaceuticals and biologics, pose a BSE risk. As new scientific information became available, the CFIA made appropriate amendments to the import conditions. And the need to standardize BSE import policies with those of other BSE-free countries was accelerated when BSE was linked to human disease in the U.K.

In 1996, the CFIA undertook a formal review of all animal, animal product and veterinary biologics import policies and produced an updated integrated import policy for BSE.

Historically, exemptions have allowed travellers to import cooked canned meat for personal consumption; however, the consolidated BSE import policies implemented in 1996 revoked this exemption. Cooked canned meat of bovine, ovine or caprine origin is only permitted entry from countries recognized free from BSE. Food of European origin for travellers, athletes and armed forces personnel temporarily entering Canada is allowed under permit, with the condition that all remnants of food with beef or beef ingredients are re-exported or incinerated.

Fundamental to the policy established in 1996 and updated in April 1998, December 1998 and March 2001, is the principle that BSE-susceptible livestock or animal products should only be imported from countries Canada has designated free of BSE. Countries wishing to export these products to Canada must provide relevant information, which is used to conduct a risk assessment according to OIE standards. The countries currently designated free of BSE by Canada are Argentina, Australia, Brazil, New Zealand, the U.S., and Uruguay. A risk assessment of Mexico is close to finalization.

Although there were objections when this principle was implemented, the CFIA considers that this prevented the importation of “risk” products from countries that subsequently reported cases of BSE.

Key developments in the evolution of Canadian import policies on BSE are presented below.

5.1.2. Current BSE Import Policies

The current policy was implemented in February 2000, for conditions related to live animal and meat imports and on December 7, 2000, for conditions related to rendered animal proteins. The consolidated version of the import policies (dated March 2, 2001) is found in Appendix 7.

Live ruminants may only be imported from countries that Canada has designated free from BSE following a comprehensive risk assessment.

Bovine embryos may be imported from countries not classified free from BSE if the country of origin certifies that:

• The donor cow was born after:

  1. BSE was made a nationally notifiable disease in the country of origin;
  2. the country has implemented an acceptable eradication policy (e.g. destruction of positive and at-risk animals);
  3. the country has implemented an acceptable surveillance and monitoring program for BSE; and

  4. the country has implemented an appropriate risk management strategy for BSE.

• The donor cow was not fed ruminant meat-and-bone meal.
• The donor is not a BSE suspect or progeny of a sire or dam affected with BSE.

Embryos have not been imported from Great Britain since 1998, when embryo import conditions were suspended for that country.

Ovine and caprine embryos may only be imported from countries designated free from BSE.

Bovine, ovine, and caprine semen are exempt from import requirements specific to BSE.

Animal product and by-product exemptions from import requirements for BSE are:

• milk, milk products and derivatives (casein and lactose);
• hides, skins, hair and products derived from these tissues (including gelatin and collagen);
• gelatin and collagen derived from other tissues, providing it is not used in livestock feed;
• products produced by subjecting bones to rigorous processes of extraction and purification, such as ossein, bone ash, bone charcoal, bone oil, and dicalcium phosphate;
• products containing bovine material sourced from tissues with no detected BSE infectivity that have been subjected to rigorous processes of extraction and purification, such as glue, oleosterin, triglycerides, glycerol, and sorbitan esters; and
• pet chews.

Edible meat and meat products of ruminant origin, including edible tallow, may only be imported from countries designated free from BSE.

Rendered animal protein (all species) including tallow containing protein, pet food, and fertilizers containing animal protein may only be imported from countries designated free from BSE.

Protein-free tallow may be imported from countries not designated free from BSE if it is certified to be protein-free (maximum level of insoluble impurities of 0.15% in weight) and that measures have been taken to prevent cross-contamination.

Animal blood: sprayed dried blood may be imported only from countries designated free from BSE. Bulk fetal bovine serum may be imported under permit but may not be used for the manufacture of veterinary biologics.

Livestock feed may be imported provided it meets the controls on animal products listed elsewhere in the Canadian BSE Import Policies and provided that it is labelled in accordance with the Canadian Feed Ban.

Ruminant specific risk materials and products containing them may only be sourced from countries designated free from BSE. Requests for exemptions may be reviewed on a case-by-case basis.

Cell lines originating from bovine tissues may be imported under the authority of an import permit. Specific conditions are put in place according to the nature of the work.

Veterinary biologics containing bovine-, ovine- or caprine-origin material for animal administration may only be imported from countries designated free from BSE. No veterinary vaccines or bacterins containing ruminant materials sourced from BSE-affected countries are allowed. Veterinary biologics containing bovine material for laboratory diagnostic purposes may be imported from countries not designated free from BSE under the authority of an import permit specifying conditions of use and disposal. As of January 2002, there are significant new documentation requirements for materials of animal origin in veterinary biologics that strengthen previous requirements (Appendix 8).

5.1.3. Country Evaluations and Designated Countries

In late 1996, Canada implemented a policy requiring that countries be evaluated as to their BSE status and designated free of BSE before being allowed to export specified products to Canada.

The country evaluation process involves a risk assessment according to OIE recommendations, based on information provided by the country (see Appendix 9).

Canada, the U.S. and Mexico share information and work co-operatively on country evaluations for BSE.

During a period of transition, certain countries were considered of negligible risk and were designated free prior to an in-depth evaluation of their status for BSE. These included Australia, Denmark, Finland, Iceland, New Zealand, Norway, Sweden, and the U.S.

Denmark, Finland, Iceland, Norway and Sweden were later dropped from the list, and the U.S., Australia, New Zealand, Argentina, Brazil, and Uruguay were added as their country evaluations were completed.

5.1.4. Previous BSE Import Policies

Unless otherwise referenced, the following dates refer to specific documents, which have been appended:

• 1982: Animal Disease and Protection Act and Regulations (ADPA) (Appendix 10)
• 1988: Import Policy for Inedible Meat and Other Animal Products (Appendix 11)
• 1996: Rationale for Canadian Import Policies Pertaining to BSE (Appendix 12)
• 1997: Policy for Importation of Rendered Products into Canada (Appendix 13)
• 1998 (April): Canadian BSE Import Policies, April 6, 1998 (Appendix 14)
• 1998 (December): Canadian BSE Import Policies, December 1, 1998 (Appendix 15)

Live ruminants:

• 1982: Importation of live ruminants allowed from Europe under permit system with strict quarantine requirements (ADPA, Sections 10–11, 63–64).
• 1987: Certification required that the farm of origin is free from BSE for cattle imported from the U.K. (Koller 2001).
• 1990: Import ban imposed on live ruminants from the U.K. and Ireland (McElheran 1990).
• 1994: Import ban imposed on live cattle from all countries where BSE had been diagnosed in native cattle.
• 1996: Live bovines may be imported only from countries Canada has recognized free from BSE.
• 1998 (April): No change from 1996 policy.
• 1998 (December): Changed from live bovine animals to live bovine, ovine and caprine animals.

Ruminant Embryos:

• 1982: Ruminant embryos may be imported under the authority of an import permit (ADPA Section 32).
• 1996: Embryos permitted to be imported provided they were collected from donors not clinically affected by BSE, not suspected of being infected, and not the progeny of an infected animal, provided that the country of origin was adhering to the risk management practices for BSE specified by the OIE.
• 1998: Import conditions suspended for bovine embryos from Great Britain (in 1997 the European Union imposed export restriction from Great Britain).
• 1998 (April): Import conditions for bovine embryos in the April 1998 policy were equivalent to current requirements. No conditions were listed for ovine and caprine embryos.
• 1998 (December): Ovine and caprine embryos banned from countries not designated free from BSE.

Ruminant Semen:

• 1982: Ruminant semen permitted under the authority of an import permit (ADPA Section 35).
• 1996: Bovine semen permitted from BSE-infected countries with some conditions.
• 1998 (April): Bovine semen exempted from import requirements specific to BSE.
• 1998 (December): Ovine and caprine semen exempted from import requirements specific to BSE.

Animal Product and By-Product Exemptions (from BSE import requirements):

• 1996:

  1. milk, milk products, and products derived from milk (casein, lactose);
  2. hides, skins, hair, and products derived from these tissues (gelatin);

  3. products and by-products derived from bovine material of minimal risk for BSE that have been subjected to rigorous processes, such as glue, ossein, bone ash, collagen, bone oil, tallow, and oleosterin.

• 1998 (April): Blood, serum, and derivatives were added to the list of exempt products.
• 1998 (December): No changes from previous policy.

Edible Meat and Meat Products:

• 1982: Meat imports permitted from countries provided they were free of certain foreign animal diseases, subject to inspection and approval of processing facilities (ADPA Sections 40–41, 43, 48).
• 1988: Meat imports (except meat meal and blood meal) allowed from the following low-risk countries: New Zealand, Australia, Iceland, Norway, Sweden, Finland, Denmark, Ireland and Japan. Meat imports allowed without restriction from the U.S. (Policy for Edible Meat Products December 1988).
• 1996: Bovine-origin meat no longer eligible for import from countries not recognized free of BSE. (Note: with very few exceptions, bovine meat products were not being imported because of restrictions under food safety policies.)
• 1998 (April): Bovine-origin meat eligible for import from countries not recognized free of BSE provided the country of origin had implemented specified risk management practices for BSE (no beef establishments applied for approval to export beef to Canada under the amended policy). Mechanically separated meat was only permitted from countries free of BSE.
• 1998 (December): The policy was expanded to include ovine- and caprine-origin products. There were no other changes from the previous policy.

Rendered Animal Protein:

• 1982: Meat meal not allowed from countries other than the U.S. Bone meal permitted with certification that it was produced in an approved place and manner (ADPA Sections 40, 41, 44, 46).
• 1988: Meat meal, bone meal, blood meal imports banned except from the U.S.
• 1990: Rendered animal products allowed from countries other than the U.S. under the authority of an import permit, provided that Canada was satisfied the product did not pose a hazard for the introduction of serious disease (Appendix 4, Section 46).
• 1996: Animal and pet food or material imported as ingredients of animal and pet food containing material of ruminant origin not allowed from countries not recognized free of BSE. Meat meal, bone meal and blood meal for any use eligible to be imported from the following countries: U.S., Australia, Denmark, Finland, Iceland, New Zealand, Norway and Sweden (Appendix 16).
• 1997: In accordance with the feed ban, permits are required for the import of all rendered animal products, stating the classification of the product (prohibited or non-prohibited for use in ruminant feeds) and the restrictions associated with the classification. Ruminant-origin rendered products (with the exception of milk and blood) not allowed from countries not designated free of BSE.
• 1998 (April): No change.
• 1998 (December): Policy expanded to include ovine and caprine products. Designated countries required to certify that the animal had been slaughtered in that country.
• 2000 (December): The importation of all animal protein products, including blood meal and feather meal, from any species from any country that Canada does not recognize free of BSE was suspended (Appendix 17). (Of the import permits suspended because of this action, none had been issued for ruminant MBM. Rendered blood products for use in aquaculture were permitted from Belgium. Porcine MBM, again for use in aquaculture, was permitted from Denmark.)(Carriere, 2002).

Inedible Tallow:

• 1982: Inedible tallow may be imported from the U.S.
• 1988: Tallow may be imported only from the U.S.
• 1996: Tallow exempt (with certification) from import restrictions specific to BSE. Designated countries (Australia, Denmark, Finland, Iceland, New Zealand, Norway, and Sweden) were eligible to import tallow for any use (Appendix 16). This policy remained in effect until December 2000.

Rendered Animal Blood:

• Rendered animal blood imports were regulated identically to rendered animal protein imports, with the following exception: from April 6, 1998, to December 7, 2000, blood products were exempt from import restrictions specific to BSE.

Livestock Feed:

• 1982: The import of livestock feed restricted to countries free of foot-and-mouth disease (ADPA Section 53). Rendered animal protein only allowed to be imported from the U.S. (ADPA Section 46).
• 1996: Animal and pet food containing ruminant-origin material prohibited from countries not recognized free of BSE.
• 1998 (April): The import of mammalian protein or products containing mammalian protein (except protein derived from milk, blood or sourced exclusively from equines or swine) for use in feeding ruminants prohibited.
• 1998 (December): No change.
• 2000 (December): Feeds containing any rendered animal products of any species no longer eligible for import from BSE-infected countries.

Ruminant specific risk materials:

• 1982: Regulated as per rendered animal protein
• 1996: Products and by-products containing specific risk materials banned from countries not recognized free of BSE. This policy is still in effect.

Cell Lines Originating from Bovine Tissues:

• 1982: Cell lines assessed on a case-by-case basis and imported under the authority of a permit (ADPA Sections 40–41).
• 1996: Cell lines originating from high-risk bovine tissues prohibited from countries not recognized free of BSE. Cell lines originating from low-risk bovine tissues permitted, subject to the conditions that the cell line and its derivatives cannot be administered to animals or people and that the waste material be autoclaved or incinerated.
• 1998 (April): Cell lines may be imported under the authority of an import permit. Specific conditions are put in place according to the nature of the work. This policy is still in effect.

Veterinary Biologics:

• 1982: Veterinary biologics are imported under the authority of an import permit and assessed on a case-by-base basis (ADPA Section 121).
• 1990 (July): Import of veterinary vaccines and bacterins containing materials of bovine, ovine or caprine origin prohibited from the U.K. Restrictions placed on the import of diagnostic kits and reagents for in vitro use (Appendix 18).
• 1996: Veterinary biologics containing bovine material for animal administration banned from countries not recognized free of BSE. Veterinary biologics for laboratory diagnostic purposes allowed provided no component can be administered to animals or people, and waste material must be autoclaved or incinerated.
• 1998 (April): Veterinary biologics containing bovine material for animal administration from countries not recognized free of BSE eligible for import under the Canadian BSE Import Policies provided that the country has implemented appropriate risk management strategies for BSE. (However, no veterinary vaccines or bacterins containing ruminant materials were permitted from countries having BSE.) Veterinary biologics for laboratory diagnostic purposes permitted under authority of an import permit specifying the conditions of use and disposal.
• 1998 (December): The previous conditions remain unchanged with the exception that restrictions on veterinary biologics for animal administration are extended to products containing ovine and caprine origin material in addition to those containing bovine material.

5.2. Compliance and Enforcement

Officials of the Canada Customs and Revenue Agency (CCRA), a Canadian governmental agency, are responsible for screening all imports at Canadian ports of entry. CCRA officials have the authority to hold shipments of animals, food, feeds, animal by-products and other such products for inspection by the CFIA. The final disposition of held shipments (e.g. release, entry refused, quarantine, or further processing) is the decision of veterinary inspectors employed by the CFIA.

CCRA officers make their decisions on imports based on a manual of procedures (the “D-19"). That portion of the manual referencing animal, animal product and by-product imports is expected to be replaced with an automated system called the Automated Import Reference System (AIRS), maintained by the CFIA. Currently, the AIRS has been implemented for CCRA purposes at selected ports of entry on a pilot basis. CCRA offices receive new and amended import directives issued by the CFIA that may affect whether or not a shipment is to be held by CCRA for inspection.

Customs officers maintain detailed records of all imports, including the date, product (identified by HS codes), exporting country, amount and value, and the name and co-ordinates of the importer. These data form the basis of the trade data generated by Statistics Canada. Original transaction records are generally kept for seven years.

CFIA inspectors are notified by Customs officials when there is a shipment to inspect. Twenty-four-hour service is available, and CFIA inspectors are aware of all import policies and directives. They receive new and revised import directives by e-mail and have full access to the AIRS. They also have access to the Import Permit System, which has been in place since 1998 to issue and maintain a record of import permits. Annual national meetings are held to discuss the rationale behind and the implementation of new import directives.

The AIRS is an electronic system containing import conditions for a wide variety of animals and products regulated by the CFIA. The system is available and accessible to all CFIA and some CCRA inspectors across Canada. The system can be updated across the country in 15 minutes. An Internet version, which is updated daily, is freely available to the public. The Import Permit System is linked to AIRS so that conditions for import are automatically generated. The AIRS works well for live animal and germplasm imports; however, it is not fully updated for some animal by-products and feeds. Hence, it must be used in combination with a paper system for those products.

In the event of foreign animal disease emergencies in trading partners, all import staff are notified by e-mail. Import conditions can be quickly suspended through AIRS and warning messages posted. In addition, the CCRA issues “border lookouts” to officials to stop imports of concern at the border.

With the exception of dogs and cats, all animal imports from countries other than the U.S. are held by Customs officers for veterinary inspection by veterinarians employed by the CFIA. All livestock entering Canada must be accompanied by an import permit except for some classes of animals originating from the U.S. Veterinary inspectors check the general condition of the imported animals either at the port of entry or, in some cases, at their final destination. Details on the animals imported are recorded and maintained at the district offices. These are tallied monthly and sent to CFIA headquarters in Ottawa, where the statistics are collated and entered into a database system.

Animal by-products are held by Customs officials in accordance with instructions in the D-19. Customs notifies the CFIA Import Service Centre, where inspection staff verify that the appropriate documentation has accompanied the shipment. Some shipments of animal by-products may be pre-cleared electronically through CFIA Service Centres.

Traveller information pertaining to meat importation is covered in "What Can I Bring into Canada" and "Be Aware You Must Declare," which are available on the CFIA website and at airports. The Government of Canada Customs Declaration Card that must be filled out by every international traveller entering Canada specifically requests that travellers indicate if they are bringing meat products into the country. If importation of meat is indicated on the declaration form, the traveller is referred for secondary inspection by CFIA personnel at airports. Dogs trained to detect food and plant products are used at several of Canada's busiest international airports to screen personal luggage for the presence of food products.

The CFIA periodically conducts blitzes, involving increased inspection and screening of commercial imports to determine if there are problems with compliance of specific import policies or requirements (Greenwood 2002).

5.3. Live Ruminants from BSE-Free Countries that Subsequently Report Cases of BSE

Imports of concern are live ruminants from countries that have reported BSE in native animals or those at high risk for BSE. The following countries and years (taken from the “Update of the Opinion of the Scientific Steering Committee on the Geographical Risk of Bovine Spongiform Encephalopathy (GBR)” adopted on January 11, 2002) have been used to determine the imports of concern.

Table 4: Countries Infected with BSE

5.3.1. Imports of Live Ruminants from Countries Reporting BSE

Import data were collected and collated from several sources in order to validate the data sources and to ensure that the data were complete. Discrepancies among the data sources were investigated by seeking original documentation of individual transactions. Corrections were made in cases in which data entry errors were confirmed.

The “gold standard” data sources were the CFIA’s Import Database and quarantine station records. The data are collected by veterinary inspectors when animals are imported and collated monthly by CFIA headquarters. In trace-back situations, this system has proven to be the most accurate of the import data tracking systems currently available.

The other major data source used for live ruminant imports was Canadian Trade Data (Statistics Canada). Supplementary sources included the European Imports table, maintained by the import section of the CFIA for trace-back purposes; data included in the Canadian submission to the EU Geographic BSE Risk (GBR) process in 1999¹; a risk assessment completed in 1994 (CFIA 1994); a data base with detailed data on imports from the U.K. and Ireland for the years 1982 to 1989; and personal communication with current and previous import specialists at the CFIA. For data prior to 1982, quarantine station records and archived files on the Continental European

Cattle Program were used in conjunction with the Canadian Trade Data to confirm the numbers and origins of imported cattle.

Import statistics were reviewed for the period from 1979 to July 2001 for live cattle, sheep and goat imports from the U.K. and other countries that have reported BSE or that are at high risk for BSE. Imports of concern are found in Table 5. In addition to the countries of concern, ruminants were imported during this period from the United States, New Zealand, Mexico (one shipment in 1986), Iceland (one shipment of sheep in 1990) and Sweden (one shipment of sheep in 1995).

The Canadian Trade Data are collected by CCRA officials. As members of this group are responsible for entering a large variety and volume of transactions into an electronic system, there is potential for data entry error such as improper codes for species and countries. A number of discrepancies between the Trade Data and the CFIA Import Database were investigated by Statistics Canada by examining individual import transaction documents and contacting importers to confirm the information. The discrepancies were all determined to be errors in the Trade Data with one exception — in 1992, there were 57 sheep imported from Denmark (the CFIA data recorded 17 sheep).

Data on cattle of Japanese origin imported via the U.S. were provided by the Import Section of the CFIA. Because these cattle were resident in the U.S. and therefore identified as U.S. cattle, they were not immediately identified as an import of concern when Japan declared their first case of BSE; however, during the course of their trace-back of Japanese imports, the U.S. informed Canada that Japanese-origin cattle had been exported to Canada.

The import of Japanese cattle resident in the U.S. occurred because of differences in import policies between the two countries. The U.S. prohibits the import of ruminants from countries it considers either infected or at risk of being infected with BSE, while Canada’s policy does not permit the import of ruminants from any country until a comprehensive evaluation of the country has been completed. These differences are being addressed with the U.S. and Mexico through the Tri-Country BSE Working Group.

Table 5: Live Animal Imports of Concern

5.3.1.1. Disposition of Cattle Imported from the U.K. and Ireland (1982–1990)

• In 1990, the CFIA placed all cattle imported from the U.K. and Ireland since 1982 in a monitoring program. This was in response to a decision to ban any further cattle imports from these two countries amid growing concerns about the spread of BSE through exported cattle.

• Cattle imported prior to 1982 were not considered a hazard at the time and therefore were not traced back. From 1979 to 1981, 68 cattle were imported from the U.K. and 2 from Ireland These numbers were confirmed through an examination of quarantine station records.

• In December 1993, one imported cow showed clinical signs consistent with BSE. A tentative diagnosis of BSE based on histopathological examination of brain tissue was confirmed by the Weybridge Laboratory in Great Britain.

• All of the remaining imports were placed under quarantine. Detailed data gathered at the individual animal level (such as cattle identification, age, sex, breed, disposition, import date, owner, farm of origin) were collected on each of the imported animals from 1982. Disposition data are summarized in Table 6 for the U.K. imports and Table 7 for the imports from Ireland.

• In total, 68 cattle from the U.K. died (9) or were slaughtered (59) before December 1993, and 68 imported prior to 1982 were not traced. It is assumed that these cattle were sent for rendering. This number includes one animal that was reported stolen. Similarly, a total of 12 animals imported from Ireland (9 slaughtered and 3 dead) and 2 imported prior to 1982 that were not traced may have been rendered.

• No animal that died is known to have shown clinical signs of BSE. Birth year and cause of death (where recorded) are listed below.

  United Kingdom:
  Birth Year	Cause of Death
  1978	not recorded
  1980	acute frothy bloat
  1981	not recorded
  1984	not recorded
  1985	not recorded
  1985	not recorded
  1985	uterine prolapse
  1986	died at calving
  1988	died after caesarean section
  Ireland:
  Birth Year	Cause of Death
  1977	euthanised - broken leg
  1987	choked in cattle chute
  1989	shipping fever (pneumonia)

• Information was received from the U.K. and Ireland on the BSE status of the farms of origin for the cattle imported after 1982. This information is summarized in Table 8 for the U.K. and Table 9 for Ireland.

• Of the 68 cattle imported since 1982 from the U.K. that were potentially rendered, the majority (58) came from farms that have never recorded a case of BSE, and 10 were sourced from farms that had had at least one case of BSE diagnosed in cattle born on the farm. Of those 10, 2 originated from an infected birth cohort. The farm of origin was not identified for 1 animal and therefore its status is unknown. For the purposes of this report, it is assumed to have been infected with BSE. The status of the farms of origin for the 68 cattle imported prior to 1982 was not determined.

• The 2 cattle originating from an infected birth cohort were herdmates of the imported cow that was diagnosed with BSE in Canada. Both of these animals were slaughtered prior to the diagnosis of the case.

• Of the 12 cattle imported from Ireland that were potentially rendered, none were sourced from farms with a case of BSE diagnosed in cattle born on the farm. The status of the farms of origin for the 2 cattle imported prior to 1982 was not determined.

Table 6: Disposition of Cattle Imported from the U.K. (1982–1990)

Table 7: Disposition of Cattle Imported from Ireland (1982–1990)

Table 8: Infection Status of Farms of Origin and Birth Cohorts of Cattle Imported from the U.K. (1982 –1990) that were Slaughtered or Died

Table 9: Infection Status of Farms of Origin and Birth Cohorts of Cattle Imported from Ireland (1982–1990) that were Slaughtered or Died

5.3.1.2. Disposition of Ruminants Imported from BSE-Infected Countries Other Than the U.K. and Ireland

Japan:

• Japanese-origin cattle were imported into Canada from the U.S. from 1994 to 1998. Canada did not import the cattle directly from Japan, given that Canada has never designated Japan as free of BSE.
• There were 22 cattle imported from Japan. Four bulls stood at stud for 4 years before being re-exported to the U.S. Of the remaining 18 of concern, 14 are still alive and have been placed under quarantine pending a decision on their disposition. Four cattle had been culled due to reproductive failure.
• The 4 Japanese-origin cattle that were slaughtered and potentially rendered were born in 1993(1) and 1994(3). They were originally imported into the United States, where they remained for an undetermined period of time prior to their export to Canada as part of two lots in 1997 and 1998. The cattle were slaughtered due to reproductive failure. Given the high cost of these animals, it is likely that they remained with the purchasing company for at least several months prior to their destruction. In any case, they would have been destroyed after the Feed Ban was in place, and therefore would not have entered the ruminant feed system.
• The CFIA has ordered that the 14 quarantined animals be disposed of and the owners compensated.

Denmark:

• Of the 9 cattle imported from Denmark in 1993, 1 was ordered destroyed and 1 had been exported to the U.S. The 7 remaining cattle are assumed to have been rendered.
• Based on the outcome of a risk assessment, 18 water buffalo imported in 2000 have been ordered destroyed. The brains of these animals will be examined for evidence of BSE, and if all test negative, progeny of these animals born in Canada over 5 months of age will be released from quarantine. One imported animal died in quarantine of causes unrelated to BSE and was incinerated.
• There were 16 sheep ordered destroyed; 1 sheep remains in quarantine pending the outcome of risk assessment review.

Cattle Imports from Europe:

• Until 1985, the CFIA operated the Continental European Cattle Program, which was designed to assist Canadian producers in importing new cattle genetics. Due to the foot-and-mouth disease situation in Europe, these cattle were subjected to lengthy quarantine periods both in Europe and in Canada.
• From 1979 to 1985, a total of 405 cattle were imported from continental Europe to Canada via the Grosse Ile Quarantine Station (countries of origin, where records still exist, are found in Table 5). These numbers were validated through a search of archived files containing documentation on the imports including, in some cases, listings of the individually identified cattle imported along with their destinations in Canada.

France:

• In 1980, 36 Romanov sheep were imported from France via the Grosse Ile Quarantine Station. These animals were sent to the Lennoxville Research Station of Agriculture Canada for breeding purposes and were maintained in quarantine until their first offspring were 60 months of age.

Germany:

• A permit was issued for the importation of 2 goats from Germany; however, they were refused entry into Canada.
• According to Canadian trade data, 120 sheep were imported from Germany in 1984. No documentation validating these numbers was found in a search of CFIA archived files.

5.3.1.3. Imports and Disposition of Other Ruminants from BSE-Affected Countries

• In 1989, 377 farmed deer were imported from Great Britain to Canada. The deer were sold into one herd, which has since been dispersed, with most of the deer having been sold to the U.S. and the remainder sent to slaughter. A shipment of 105 deer to Canada from Great Britain was “in transit,” and hence the deer did not stay in Canada. The U.K. has not reported BSE in any ruminants other than cattle and zoo animals, including farmed deer (Moreau 2002).
• There were 6 sheep imported from the U.K. in 1990, 28 in 1989 and 48 in 1980. The disposition of these sheep is unknown. The Canadian Trade Data show 180 sheep imports from the U.K. in 1986. There is no trace-back information on these sheep, and no documentation validating the number was found in a search of CFIA archived files.

5.3.2. Imports of Sheep from Countries Reporting Scrapie

Imports of sheep from countries other than the U.S. require an import permit and a certificate signed by an official veterinarian of the country of origin that:

• the sheep were inspected and found to be free of scrapie;
• no case of scrapie has been diagnosed in the flock of origin for the previous 3 years; and,
• the animal is not the progeny of a dam or sire that was affected with scrapie.

These requirements have been in place since 1982 (Appendix 10, Section 12) (Appendix 4, Section 12).

The importation of sheep from the U.S. does not require a permit; however, certification for scrapie has been required since 1982 as for all other countries. As of 1990, scrapie certification is no longer required for sheep in transit for the re-entry of animals into Canada from the U.S. within 60 days and for feeder sheep destined for immediate slaughter (Appendix 10, Section 24) (Appendix 4, Section 22).

Based on a review of information provided by those countries, Canada has recognized Australia and New Zealand free of scrapie. In the absence of specific assessments, all other countries are considered to be infected with scrapie (Greenwood, 2002). Table 10 lists the imports of sheep from countries not recognized free of scrapie.

Table 10: Imports of Breeding Sheep from Countries not Recognized Free of Scrapie (1988–July 2001)

5.3.3. Imports of Cervids from Countries Reporting Chronic Wasting Disease

A permit specifying the conditions for import is required to import cervids into Canada from all countries. The conditions vary according to the species of cervid and the exporting country.

Imports of cervids from the U.S. (the only other country that reports CWD) are found in Table 11.

Table 11: Imports of Cervids from the United States

5.4. Ruminant Embryos

Import data for ruminant embryos are provided in Tables 12, 13 and 14 for the years 1990 to 2000 (Barr 2001).

In response to research evidence, the 2002 OIE Animal Health Code has been revised and recognizes that bovine embryos pose a negligible risk in the transmission of BSE. Canada permits the import (with certain conditions) of bovine embryos from countries that have reported BSE.

The importation of ovine and caprine embryos is currently permitted only from countries evaluated by Canada as free of BSE.

Table 12: Imports of Bovine Embryos from European Countries

Table 13: Imports of Ovine Embryos from European Countries

Table 14: Imports of Caprine Embryos from European Countries

5.5 Meat and Bone Meal (MBM)

In review of the risk factors associated with MBM imports, the following considerations contribute to the conclusion that Canada has primarily imported MBM for livestock feed from the United States, Australia and New Zealand. The considerations are;

• quantities of animal by-products from risk countries were minimal because of other OIE List A diseases in Europe,
• economic pressures disadvantage sourcing MBM from outside of North America,
• the imprecise nature of the Harmonized Commodity Description and Coding System (HS coding) used to record international shipments, resulted in inaccuracies with respect to identifying the nature of animal by-products.

In the 1980s and early 1990s Canada had significant concerns regarding the prevalence of reportable diseases occurring in European countries, including those of the European Union. During this period OIE reports show occurrences of foot and mouth disease (FMD) in Switzerland (reported in 1980), the United Kingdom, Austria and France (reported in 1981), Denmark (reported in 1983), Portugal and the Netherlands (reported in 1984), Spain (reported in 1986) and Germany (reported 1988). At that time, Canada considered that the countries of Eastern Europe were less reliable in regard to disease reporting. Thus, while they may not have reported foot and mouth disease or other significant diseases, these countries were thought to present an even greater risk than those of Western Europe.

In view of North America’s long term freedom from FMD and other serious diseases of livestock, the CFIA and its predecessors were keenly aware of the risks presented by imports of MBM and other animal products. The OIE List A swine diseases presented almost as significant a concern as FMD, as there was no domestic segregation between ruminant and hog feed in Canada at that time.

On animal health grounds, MBM could have been imported from countries of Scandinavia or the Pacific Rim, including Japan. However, for economic and commercial reasons, these countries were not highly competitive suppliers of MBM. The USA was the only country from which significant quantities of MBM for use in livestock feed were imported into Canada. Smaller amounts were imported from Australia and New Zealand.

Since 1978, the Animal Disease and Protection Regulations, and Health of Animals Regulations (1991) prohibited the importation of MBM from countries other than the United States. Low risk materials could be imported by special provision of the legislation, under conditions equivalent to the current import permit system and small quantities of low risk materials were in fact imported.

Beginning in 1997, when the CFIA prohibited the feeding of mammalian-derived proteins (with exceptions) to ruminant species, Canada has required that all rendered animal products entering the country be accompanied by an import permit. MBM may only be imported from countries that the CFIA has assessed to be BSE free, based on a CFIA risk assessment conducted according to OIE standards. Under permit conditions, the CFIA requires a description of the product, its source and its intended end use; and specifies labelling requirements. In addition, the Feed Ban requires that the importer keep records of the sale and distribution of rendered animal products. These records are subject to periodic review by CFIA inspectors.

In 2001, Canada completed a review of MBM and related commodities imported from Europe in 1990-2000 (Appendix 19). The report covers potential imports from countries of the European Union, Scandinavia and Eastern Europe.

For the period 1990-1994 the review was based on original documents (Restricted Commodity Reports) held by CFIA veterinary inspectors at ports of entry. These reports contain product description and volume, and a classification of the product as a low, medium or high risk import according to the country of origin. The review concluded that MBM, for use in ruminant feeds, had only been imported from the U.S. (Tracey, 2002).

For imports during the period 1995 to December 2000, transaction records, obtained from the Canada Customs and Revenue Agency (CCRA), were examined. Of the 4000 entries examined, 400 required further investigation. This was based on whether the company was known to trade in livestock feed ingredients; whether import permits had been issued to the company for products of concern; or, whether any imports of MBM had occurred. To address these 400 entries the CFIA requested additional documentation from the CCRA, which formed the basis of an in depth review. The report indicates that all the transactions relating to ruminant feed were either mis-classified or the end use was not correctly identified. No potentially hazardous imports were detected during the course of this examination.

In response to a request from a trading partner, the CFIA investigated Eurostat data (Table 17) which describe imports of MBM from Europe during the period 1980 - 2000.

The first reports of MBM exports to Canada appear in Eurostat figures for 1993 (30 metric tonnes reported as imported from the UK). Import trade data provided by Statistics Canada (Tables 15 and 16) indicate that MBM was not imported from the UK during the period 1988 - 2001. A detailed examination of CCRA transaction reports confirm that highly processed inedible products have been imported periodically from the UK since 1995, in the form of dog biscuits, bone ash and bone charcoal. The discrepancy between the data sources is attributed to the broad categories used to specify commodities which results in inaccuracy not evident in the absence of a detailed examination.

Canada has imported approximately 11,000 metric tonnes of materials declared as “flour, meals and pellets, of meat or meat offal, nes, unfit for human consumption; greaves” from Denmark. Canadian records confirm that MBM was imported in certain years during this period (1994 - 2000). CCRA transaction records indicate that this material was of porcine or poultry origin and that it was imported by a maker of aquaculture feed products.

Imports from Germany appear in Canadian import data for the years 1995 and 1999 but do not appear in the Eurostat data. The CFIA has determined that poultry meal was imported in 1999 for inclusion into aquaculture feed, but was not successful in obtaining specific information relative to the 1995 importation.

A total of 13 metric tonnes of MBM from France appear in the Eurostat data for the years 1999 and 2000. An examination of CCRA transaction records indicate that less than 2 metric tonnes of feather meal were imported from France, under permit, for use in animal feed. The discrepancy in data is attributed to errors in the Harmonized Commodity Description and Coding System that is used to identify commodities for the purposes of freight tariffs and statistics, but which fails to provide the detail required to track specific import commodities.

Eurostat indicates that 25 metric tonnes of MBM were imported into Canada from Belgium in 1998 - 1999. Canada has no record of these transactions; however, it has been confirmed that several shipments of spray-dried hemoglobin, imported under permit from France to Canada, were shipped via Belgian ports. Belgium was listed as the country of origin several times, despite there being clear evidence that this material came from France. In the absence of Canadian transaction records identifying a Belgian exporter, the CFIA concludes that Eurostat data incorrectly attributed to Belgium, on the basis of a declared Belgian port of exit, consignments that originated in France. Noting that no detectable infectivity has been found in blood or blood components of cattle infect with BSE (Wells et al 1998, Wells et al 1999, Bradley 1999) the CFIA considers that these imports do not compromise Canada’s BSE status.

The CFIA has investigated the references to MBM importations from Japan in the years 1994, 1996 and 1997 which appear in the import trade data tables provided by Statistics Canada. A detailed examination of CCRA transaction records for Japanese imports during this period indicate that there were no importations of MBM during 1994 and significantly smaller amounts than indicated by the import trade data in both 1996 and 1997. The importer, identified by the CCRA transaction records, is not associated with the livestock industry. Discrepancies are attributed to either a misclassification of goods, or a failure to adjust the import trade data when adjustments occur after the final accounting of the goods.

A second review of import documents (restricted commodity reports and CCRA transaction records) was conducted for the period January 1, 2001 to October 19, 2001, for potential imports from the EU, Russia and Japan (Appendix 20). A total of 2707 transactions were examined, based on a coded description of the commodity (Harmonized Commodity Description and Coding System of the World Customs Organization). CFIA requested additional information on 193 of the 2707 transactions in order to verify that the commodities were in fact approved for import. The majority were found to be dried hog casings, pet supplies, supplements and food, bull pizzels, pigs ears and bone charcoal, all of which are approved commodities. On the basis of this evaluation, the CFIA confirms that no MBM was imported into Canada for use in livestock feeds from these countries during the period in question.

The CFIA periodically reviews import data to determine whether MBM for use in livestock feeds has been inadvertently imported from BSE-infected countries. The Agency has also considered the possibility of MBM being substituted for fish meal, which can be imported into Canada from any country regardless of BSE status. While fish meal is not known to present a BSE risk, substitution by MBM could be of concern if the mis-described product was used in the production of ruminant feed.

Canada is a major producer of farmed salmonids, surpassed only by Norway, Chile and Scotland in the production of salmonid products for human consumption. Aquaculture production has been growing steadily in Canada for the last 20 years, with a concurrently increasing demand for protein of appropriate quality to produce fish feed. Canada produces fish meal (from herring and scrap fish), but domestic production consistently lags behind demand, creating a market for imported fish meal. Most of the imported fish meal comes from South America, particularly Peru, a low-cost source. Lesser amounts are imported from Europe (primarily countries of Scandinavia) and the United States.

For nutritional reasons, fish meal is the most important ingredient for salmonid feed; it is also one of the most costly ingredients. Fish feed manufacturers must incorporate an adequate percentage of fish meal in their product to ensure the feed meets producers’ needs. Researchers have evaluated the use of MBM as a lower cost replacement for fish meal in salmonid feed, but results have been disappointing due to the inadequate nutritional profile of this product relative to fish meal (MBM contains a much higher ash content than fish meal). The production of salmonid feed is a specialized industry, with only seven major producers in Canada, and failures in feed quality can be readily traced back to the manufacturer. Thus, the inadvertent or deliberate incorporation of MBM in salmonid feed would be unlikely to occur in any systematic manner and the CFIA considers that there would be little commercial demand for the importation of MBM mislabelled as fish meal.

Because there is a demand for fish meal in the manufacture of salmonid feed and the value of the product is high compared to other protein sources, the CFIA considers that imported product described as fish meal is unlikely to be used in the production of ruminant feed.

In summary, the CFIA has made a thorough investigation of import records from available sources, augmented by periodic spot checks of current activity. On the basis of this assessment, Canada has imported MBM for livestock feed-associated uses from the United States, Australia and New Zealand but not from other countries. The CFIA further considers that importation of MBM from these sources does not compromise Canada’s BSE status.

Table 16: Canadian Imports (all countries) of Bone Meal for the Manufacture of Livestock Feeds (HS code 0506.90010), for the Period 1988–2001 (Source: Statistics Canada)

Table 17: MBM Imports (tonnes). Shading indicates period of different risk that exports carried the agent, 1986–1990 being the period of highest risk for U.K. imports, while 1994–1999 U.K. exports are assumed to have been safer than exports from other BSE-affected countries. Sources: C = Completed country questionnaire, E = Eurostat

MBM Imports into Canada from BSE-Affected Countries

5.6. Other Products

Livestock Feeds and Feed Supplements:

Feeds for cattle, sheep and goats must comply with the Health of Animals Act and Regulations and the Feeds Act and Regulations (see Section 8 for further details). All mixed livestock feeds and supplements must be evaluated and registered before importation, manufacture, or sale in Canada. Manufacturers must provide a complete formulation of all ingredients that may be included in the feed in order to be evaluated for registration. Except for specialty feeds, formulations are not required from the United States due to the high degree of harmonization of feed ingredients between the two countries. Many feed ingredients and additives are not subject to mandatory registration. Rendered animal products and by-products may only be imported into Canada from countries that are recognized as free of BSE by Canada, and any mixed feeds containing these products would not be registered. Registrations are granted for a three-year period.

Canada has an abundance of inexpensive, raw materials for livestock feed; it is not economical to import livestock feeds from BSE-infected countries because of the distance and the lack of low-priced livestock feed relative to Canadian sources. Historically, only small amounts of complete feeds have been imported from offshore (these feeds must be in compliance with the Health of Animals Act and Regulations and the Feeds Acts and Regulations).

Products registered by the CFIA for import from Europe consist of feed supplements, vitamins, minerals, acidifiers and flavouring agents. Europe is the major vitamin-mineral supplier to the world, and as a result there are several products of this class that are imported into Canada from BSE-infected countries. All ingredients of such products are scrutinized for compliance with both Acts — the Health of Animals Act and the Feeds Act — with respect to BSE risk. A review of feed registrations and trade data revealed few imports of complete feeds for livestock.

The CFIA is considering the risk potential associated with imported fat-soluble vitamins coated with gelatin, which may be sourced from bovines. There is some uncertainty regarding the potential infectivity of gelatin, as evidenced by the European Community Scientific Steering Committee’s ongoing investigations in this area. Health Canada is conducting a risk assessment on gelatin, and any changes to current import policies would be based on the results of that risk assessment.

Veterinary Biologics:

All veterinary biologics imported into Canada must be accompanied by an import permit specifying conditions designed to minimize the risk associated with the import.

As of January 14, 2002, manufacturers are now required to sign a “Declaration of Compliance” stating that the “animal species, supplier’s sources, countries of origin, and supporting documentation for all materials of animal origin used in the preparation of the product have been examined by the manufacturer...,” and that the “materials originated from sources considered to be safe from animal TSE infection or contamination.” This declaration is in addition to requirements for manufacturers to list all materials of animal origin used in the preparation of or which may have come in contact with any vaccine constituents during preparation and to indicate actions taken by the manufacturer to minimize the risk for contamination of their product by TSE agents. A record of purchase and use for each lot of material of animal origin must be maintained by the manufacturer and is subject to inspection by the CFIA during facility inspection.

A review of all licenced products undertaken in the mid-1990s verified that these products did not contain and had not been exposed to material potentially contaminated with BSE.

Veterinary vaccines for use in ruminants are not imported from BSE-infected countries. Vaccines from non-BSE-infected countries may be imported provided the company meets high standards of manufacturing practices and is able to demonstrate the purity, potency, safety, and efficacy of their product. Each product must be licenced in Canada and is assessed on a case-by-case basis. Materials of ruminant origin used in the production of the vaccine must be certified by the manufacturer and the government regulatory agency in the country of origin to be from a non-BSE-infected source. Risk assessments of the country and product are conducted as required.

Most licenced veterinary diagnostic kits are produced in Canada or imported from the U.S. Veterinary diagnostic kits may also be imported from BSE-infected countries subject to stringent requirements similar to veterinary vaccines (and this would be permitted only where the particular product could not be sourced elsewhere). The company must be able to demonstrate high standards of manufacturing practices and assure the purity, potency, safety and efficacy of its product. Manufacturers and government agencies must certify that materials of ruminant origin used in the production of the kit are from a non-BSE- infected source, and risk assessments of the country and product may be undertaken. Import permits and labels for veterinary diagnostic kits specify that these products are for in vitro use only. Currently, there are no licenced in vitro diagnostic kits in Canada originating from BSE-infected countries. The new documentation and certification requirements, as described above, will be applied to all new licencing applications for in vitro diagnostic kits.

Unlicenced veterinary diagnostic kits and laboratory reagents are imported from several countries for use in biomedical research and quality control testing. Upon receipt of an import permit application, a qualitative risk assessment is conducted, taking into consideration the potential hazards associated with the product and its end use. Import permit conditions are specified to minimize risks.

Veterinary Pharmaceuticals:

Veterinary pharmaceuticals are regulated by the Veterinary Drugs Directorate (VDD) of Health Canada under the Food and Drugs Act and Regulations. The VDD applies a BSE exclusion policy developed by Health Canada to its approval process for new veterinary drugs.

5.7 SUMMARY - IMPORT

Import Policies

• In the early 1980s, trade policies in Canada and elsewhere served to limit exposure to commodities potentially contaminated with BSE. While import policies were liberalized later in this decade, import permits, which provided science-based controls, coupled with a conservative approach to risk management, helped to exclude BSE from Canada.

• Since December 31, 1996, Canada has not allowed the importation of cattle and bovine products from countries that have not been evaluated by Canada and recognized free of BSE. A small number of bovine products and by products are exempted as specified in the Canadian BSE Import Policies and in accordance with international guidelines. This has effectively prevented the introduction and establishment of BSE.

• Current import policies provide a high level of protection given current scientific knowledge of BSE. Although some imports that occurred historically are now considered to have presented a risk, CFIA analysis indicates that Canada did not import significant quantities of potentially infective materials.

MBM Imports

• Restrictions on imports based on general disease concerns precluded the importation of rendered animal products into Canada during the 1980s.

• Canada has not imported any MBM from Europe for use in livestock feeds.

• The majority of imported fish meal is derived from countries in South America. Smaller amounts have been imported from Europe (primarily Scandinavia). The salmon aquaculture industry would be the major market for fish meal for the manufacture of complete fish feeds.

Livestock Feeds and Feed Supplements

• Small quantities of vegetable-origin complete feed, of which an insignificant amount is ruminant feed products, are imported from BSE-infected countries. No rendered animal-origin MBM from any species (with the exception of fish meal) may be incorporated into these products.

• Specialized animal products, mainly vitamin and mineral supplements, are imported from Europe.

• There is some scientific uncertainty regarding the risks associated with gelatin-coated products. Health Canada is conducting a risk assessment on gelatin, and any changes in Canadian policies will be based on the results of that assessment.

Veterinary Biologics and Pharmaceuticals

• Imports of veterinary biologics have always been reviewed on a case-by-case basis. Because of their potential to introduce pathogens, the materials used in their production and manufacturing processes are closely scrutinized.

• Imported veterinary biologics are strictly evaluated for BSE/TSE risk and are therefore unlikely to pose a hazard for the introduction of BSE.

• The CFIA is working in co-operation with Health Canada, which has the mandate to regulate veterinary pharmaceuticals.

¹ The import data submitted by Canada in 1999 for the GBR process were compared with all other data sources, and where there were discrepancies, original transaction data were examined and errors corrected.

Introduction | Assumptions and methods | Demographics and industry characteristics | Legislative authority
and veterinary infrastructure | Import | Slaughter and disposition | Rendering | Feed | References