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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8. FEED

8.1. Regulation of Feed

The Canadian federal government regulates the trade and commerce of feeds for livestock by controlling their manufacture, sale, and importation using the authorities provided in the federal Feeds Act. In addition, the federal Health of Animals Act may be used to make regulations prohibiting or regulating the feeding to animals of any substance that could introduce or spread disease or toxic materials to animals (Health of Animals Act, Section 64(t)).

Feed is defined in the Feeds Act as any substance or mixture of substances containing amino acids, antioxidants, carbohydrates, condiments, enzymes, fats, minerals, non-protein nitrogen products, proteins or flavouring agents, and any other substance manufactured, sold or represented for use for:

• consumption by livestock;
• provision of the nutritional requirements of livestock; or
• the purpose of preventing or correcting nutritional disorders of livestock, or any substance for use in any such substance or mixture of substances (Feeds Act, Section 2).

Animal food is defined in the Health of Animals Act as anything that is capable of being a nutriment for animals and includes any of the constituent elements of an animal ration (Health of Animals Act, Section 2).

Livestock is defined in the Feeds Act as horses, cattle, sheep, goats, swine, foxes, fish, mink, rabbits and poultry, and includes such other creatures as may be designated by regulation as livestock for the purposes of the Act (Feeds Act, Section 2). The Health of Animals Act includes as animals embryos, fertilized eggs, and ova (Health of Animals Act, Section 2).

The Feeds Act prohibits the manufacture, sale and importation into Canada of any feed unless the feed has been registered by the federal government, conforms to prescribed standards, and is packaged and labelled as prescribed.

The federal government regulates mixed feeds and feed ingredients using the Feeds Act. Most domestically manufactured mixed feeds do not need to be registered (they are, however, subject to marketplace inspection under the National Feed Inspection Program). All imported mixed feeds must be registered. A complete list of feed ingredients must be provided to the CFIA in order to register certain products, e.g. feeds manufactured outside continental North America and specialty feeds such as flavouring agents. In some other cases, the complete list need only be made available on request. Registrations expire and are renewed every three years upon application by the registrant. Ingredients must be approved by the federal government for use in livestock feeds and are described and standards given under Schedule IV (roughage, energy feeds, protein feeds, vitamins, minerals and other categories) and Schedule V (flavouring agents) of the Feeds Regulations. Part I of each Schedule lists approved ingredients that do not require further evaluation and mandatory federal government registration, while Part II lists those ingredients for which all sources must always be evaluated and registered to confirm the safety and efficacy of each specific source.

To be eligible for free sale in Canada, livestock feeds must comply with the requirements of the Feeds Regulations. Feeds must also comply with the Feed Ban (described in more detail in Section 8.1.1 under the Health of Animals Regulations).

8.1.1. Feed Ban

The incorporation of rendered ruminant-derived protein in cattle feed in countries where the disease occurs is thought to be the main factor contributing to the spread of BSE. In August 1997, in response to a WHO recommendation, the CFIA banned the feeding of specified mammalian protein to ruminants (Health of Animals Regulations, Part XIV, Sections 162–171).

The Feed Ban is described in the following terms. Any feed that is, or that contains any prohibited material originating from a mammal (with exceptions) shall not be fed to a ruminant. Feeds for equines, porcines, chickens, turkeys, ducks, geese, ratites or game birds, containing prohibited materials, must be clearly labelled with the following cautionary statement, “Do not feed to cattle, sheep, deer or other ruminants.” Labels for bulk feed are stapled to the invoice and shipping documents. Ruminants may be fed pure porcine meal, equine meat meal and non-mammalian protein meal (fish, avian), as well as milk, blood, gelatin, rendered animal fat and any products produced from these materials from all species.

Feed manufacturers must keep records regarding the composition, identity and distribution of all feeds for the species named in the regulations (i.e. ruminants, equines, porcines, chickens, turkeys, ducks, geese, ratites or game birds) (Health of Animals Regulations, Section 171).

Renderers, feed manufacturers and farmers must take steps to prevent cross-contamination of ruminant feeds with materials prohibited under the Feed Ban.

Users of livestock feed must keep labels or invoices from all purchased feeds containing prohibited material; these records must be kept for two years. Prohibited material may be fed to non-ruminant animals such as poultry and swine.

8.2. Feed Production

8.2.1. Feed Industry Profile

Canada is a vast country spanning several distinct geographic regions. Accordingly, livestock and crop production practices vary from coast to coast, as does the feed industry. Feed ingredients vary depending on availability and the predominant type of farming industry. The CFIA maintains information on individual commercial and farm-based manufacturers, which is derived from CFIA inspection reports. General information about the feed industry in Canada can also be obtained from the Animal Nutrition Association of Canada (ANAC) at http://www.anac-anac.ca.

In 2000, there were about 600 feed mills, 1,300 feed retailers of livestock feeds and more than 100,000 farms feeding ruminants in Canada (Tolusso 2001b). Table 22 shows the geographic distribution of mills and feed production in 1997. The ANAC website reports a similar distribution of its 520 members across Canada.

Table 22: The Geographic Distribution of Feed Mills and Feed Production in Canada (1997)

Source: CFIA, 1997, Feed Mills Inspection Report

The Canadian feed industry comprises establishments that vary in size and manufacturing capacity from relatively small mills to large sophisticated and vertically integrated operations. Annual sales per operation vary from $1 million to over $150 million (ANAC). Total sales in 2000 were estimated at over CDN $3.2 billion for all livestock and poultry feed shipments (excluding pet food) (ANAC).

Approximately 13 million tonnes of complete commercial feed is manufactured every year, or about one half of the total 23–25 million tonnes of complete feed needed to feed all the livestock and poultry in Canada. Overall, about 50% of mixed complete feed is mixed on-farm (ANAC).

Two thirds of the feed mills located in Ontario and Quebec account for 66% of the total feed manufactured in Canada. Western Canada produces 29%. Given the large population of cattle in Western Canada, it is likely that many western farms are mixing their own feed. It is estimated that 80% of the feed used in beef production is mixed on-farm (Mercier 2002). In general, feed for beef cattle is formulated from forage and grains. Small amounts of commercial protein/energy supplements may be purchased from a feed mill; however, depending on price, this too may be plant in origin. Most beef feedlots are large, specialized farms. It is highly unlikely that the feed mixers used on beef feedlots would be cross-utilized to mix feeds for other species.

Commercial feed production in Canada can be broken down according to livestock sector as follows (ANAC): hogs - 37%, beef - 29%, dairy - 15%, poultry - 16%, other - 3%. Swine, dairy and poultry feeds account for approximately 85% of the complete feeds manufactured and sold by commercial manufacturers in Canada (ANAC).

Canada has abundant agricultural land suited to growing crops like corn, barley, and high-protein ingredients such as canola and soybeans. Consequently, plant-based proteins have always been an inexpensive and nutritious component of cattle feed.

The industry relies on imports from the U.S., Europe, and Asia for the majority of high-value purified micro-ingredients such as vitamins, trace minerals, amino acids, animal health pharmaceuticals and other micro feed additives. There is virtually no vitamin production in Canada, and the pharmaceutical fine chemical industry is limited (ANAC). These products must be registered and must comply with CFIA import policies for BSE.

The feed industry is represented by ANAC, the membership of which includes 200 feed companies owning 520 feed mills across Canada, responsible for 90% of the total feed produced in Canada (ANAC). Approximately 33% of the 520 feed mills (or 169 feed mills) are owned by 11 large feed corporations and carry out 70% of the total annual commercial complete feed production. Two of these corporations have policies prescribing the use of rendered animal protein meals (Mercier 2002).

As required under the Feed Ban, Good Manufacturing Practices (such as written procedures to prevent cross-contamination, maintenance of production and distribution records) are confirmed to be in place at all feed mills. In addition, 40 mills have Quality Assurance Programs (HACCP certification) in place to verify product quality and safety (including verification of ingredients for Feed Ban compliance). These mills handle 35% of the total annual commercial complete-feed production (Mercier 2002). Another 15 to 20 mills are actively seeking HACCP certification (Mercier 2002).

8.2.2. Risk Reduction Practices for BSE in the Feed Industry

Feed manufacturers producing both ruminant and non-ruminant feeds (which may include prohibited material) in the same facility and/or with the same equipment must use specified procedures to reduce the potential for cross-contamination. These procedures are used when common equipment is used for receiving, handling, processing, transport or delivery of both the ruminant feeds and the non-ruminant feeds. Sequencing and flushing grids apply to each critical point in the manufacturing process, including ingredient receiving and storage, weighing and metering, mixing, pelleting/extrusion, packaging, finished product storage, loading, and delivery vehicles. Typical clean-out procedures include the following:

• flushing of manufacturing equipment with a specified quantity of inert material (whole grains, etc.), which is either stored for later use in non-ruminant rations or included in the previous batch containing the prohibited material;
• diverting to the previous batch of feed the initial portion of any batch of ruminant ration that has followed a feed containing prohibited material;
• sequencing of production where the manufacture of non-ruminant feeds containing prohibited material is followed by the manufacture of non-ruminant feeds not containing prohibited material, such that any residual prohibited material in the manufacturing equipment would be displaced into another non-ruminant feed manufactured later in the production sequence; and
• physical cleanout of equipment (sweeping, vacuuming), which may be combined with flushing and sequencing procedures as required.

No testing is done to detect the presence of prohibited mammalian protein in ruminant feed.

The Feed Ban imposes additional requirements on feed mills for record-keeping and prevention of cross-contamination (in addition to those required for dealing with medicated feeds), and companies have responded in a variety of ways. Some companies with multiple manufacturing facilities within a small geographic area have designated certain facilities solely for the production of ruminant feed. Other mills designated for the production of ruminant feeds do not handle any MBM. Yet other feed manufacturers have opted to use only non-prohibited protein sources in all livestock feeds, to avoid the additional burden of complicated decontamination procedures and record-keeping specifically for the Feed Ban.

In 1996, ANAC launched a voluntary national Feed Safety Program for feed manufacturers, with the goal of facilitating the implementation of GMPs and HACPP programs in feed facilities. The Canadian industry is adopting HACPP programs in feed mills, and ANAC has requested CFIA recognition of its certification program.

8.2.3. Sources of Proteins in Livestock Feeds

The protein ingredients in ruminant feeds are selected on the basis of availability, price, nutritional value and the personal preference of livestock producers. Only animal protein derived exclusively from porcine or equine animals and milk and blood proteins from all mammals are allowed to be fed to ruminants.

On December 7, 2000, the CFIA suspended the importation of rendered animal protein products, including blood meal and feather meal of all species, from any country that the CFIA does not recognize as free of BSE. Imported rendered products are subject to a permit system, wherein the importer is required to stipulate the source of the rendered product and compliance with the documentation and labelling requirements of the regulations. Importation of rendered products from the U.S. represents a significant portion of the animal proteins used by the feed and pet food manufacturers; approximately half of the rendered products used in livestock feeds are imported from the U.S. (Thompson 2002; Carrière 2002).

Prior to the Feed Ban, soybean meal was cheaper than MBM, and other rendered animal protein was more expensive than MBM and soybean protein. Given that feed represents a significant portion of the cost of livestock production, and that soybean meals were cheaper than non-prohibited meat meal, it is likely that many feed mills (which use least-cost formulations) and cattle farmers used soybean meal or other vegetable proteins instead of rendered animal protein in their cattle rations. This price trend has continued since the Feed Ban.

Some of the meal produced, which also compares favourably in price with MBM, could be used to feed cattle. For 2001 it is estimated that approximately 74% of the porcine meal (or 43,000 tonnes) produced in Canada was manufactured in a rendering facility that uses the same line to produce prohibited and non-prohibited material. Of this 74%, approximately 10% is exported and 15% is used by the pet food industry. The quantity used in cattle rations is unknown.

Although poultry meal, blood meal and feather meal may be fed to ruminants, the higher cost of these items likely discourages this practice (Table 23). Blood meal and feather meal may be used to some extent, but because of the specialized equipment used for the processing, these products are less likely to be contaminated with prohibited materials. Poultry meal is generally reserved for the production of high-quality pet food (Desnoyer 2002).

Table 23: Price Differential Between Protein of Animal Origin and Vegetable Origin

¹ Source for Canadian market: Economic and Industry Analysis Division, Market Research and Analysis Section, Agriculture and Agri-Food Canada
² USDA Agricultural Outlook and USDA Market News.
³ Prices come from a rendering facility located in Eastern Canada, prices may be different in other areas in Canada
⁴ Prices come from a rendering facility located in Western Canada, prices may be different in other areas in Canada
⁵ Prices come from a rendering facility located in Western Canada, prices may be different in other areas in Canada

8.3. Feeding Practices

8.3.1. Dairy Cattle

High-producing dairy cattle need high quality protein, particularly in early lactation. In Canada, a variety of “bypass” protein sources are available that can be used for this purpose (such as treated soybean products, blood meal, fish meal, corn gluten meal, and non-prohibited MBM). Animal products were commonly used in dairy feeds before the Feed Ban in 1997 and are often used today to boost protein levels and/or balance specific nutrients (lysine and other amino acids, calcium and phosphorus, in particular). Tallow is also commonly used in small proportions, more as a facilitating agent in the manufacturing of feeds rather than as a source of energy.

Prior to the Feed Ban, some feed manufacturers used no MBM in dairy rations, while others used it in 20–30% of dairy formulations. The decision to use MBM depended largely on the nutritional philosophy of the feed manufacturer, the variety of economical bypass protein sources available in a particular region and the potential implications of Salmonella contamination of MBM. Before the Feed Ban was put in place, the maximum inclusion rate of MBM in dairy rations would have amounted to a consumption rate of 200–400 g/head/day.

In the Atlantic provinces, fish meal is the preferred source of animal protein used in dairy supplements beyond the vegetable proteins that make up the majority of protein in feed. Other types of protein meal are used at the customer’s request.

In Central Canada, feed companies may use porcine meal, blood meal, feather meal, and “protected” soybean meal. Animal proteins make up 1% or less of the overall diet of an animal.

In Western Canada, blood meal is commonly used in dairy feeds as a source of bypass lysine, which aids the maintenance of high milk production. Since the Feed Ban, feather and porcine meal are commonly used to boost protein levels in lieu of ruminant MBM.

Calves are removed from the cow soon after calving and fed with milk replacer (that does not contain MBM).

8.3.1.1. Use of Milk Replacers in Dairy and Veal Calves

Central Canada is the largest veal production region in Canada. The milk replacers used in white veal production typically contain bovine milk products (skim milk powder, whey protein concentrate, casein, etc.) and high quality tallow.

High-quality milk replacers provide for calf growth and performance equal to that attainable with whole milk. Milk replacers can be classified by protein source, energy content, and the presence of medication. Protein sources are generally classified as milk or alternative proteins (soy protein isolate, soy protein concentrate, modified wheat protein, plasma protein), with protein levels ranging from 18–22% and fat levels from 10–25% (Dupchak 1991; APHIS/USDA 1998). The fat content provides most of the energy in a milk replacer.

Milk replacers are regulated under the Feeds Act (if not containing colostrum) and all milk replacers, imported or made domestically, must be registered. In Canada, most milk replacers are formulated to contain 100% of their protein from milk sources (such as skim milk powder and whey protein concentrate), although other protein ingredients may be used. In recent years, the use of soy protein concentrate to replace some milk protein has become more common. The basic fats used are high quality animal fats (tallow) and some high quality vegetable fats.

Because of the Canadian tariff imposed on milk products and by-products, importation of milk replacers occurs at a very low level. Since December 2000, only protein-free tallow (maximum level of insoluble impurities 0.15% by weight) may be imported from countries not recognized as free of BSE. Domestically produced tallow or tallow imported from BSE-free countries is not required to be free of protein in order to be used in milk replacer. Milk replacer manufacturers use high-quality tallow because it is palatable, odourless, and can provide the level of energy sought. According to the American Fats & Oils Association, high quality tallow is expected to have less than 0.1% insoluble impurities (McCoy 1996). In addition to the import controls, it should be noted that veal calves are slaughtered young, thus the probability of their developing BSE, even if they were exposed, would be negligible. Beef calves remain on pasture with the cow until late fall when the calves are weaned, and it is unlikely that they would receive milk replacer.

There is no evidence that milk replacers containing milk or milk products derived from ruminant animals constitute a BSE risk (WHO 2001; SEAC 1999).

8.3.2. Beef Cattle

Producers’ revenues from beef production are more volatile than those of the dairy industry, so producers are generally more concerned about feed costs than the maintenance of a nutritionally consistent feeding regime. The decision to use MBM in beef feed formulations, before the Feed Ban, depended largely on the nutritional philosophy of the feed manufacturer and the most economical supplemental protein sources available, such as peas, lupins, lentils, canola, or soybean meal. As a result, beef cattle rations typically used low-cost, low-quality protein ingredients such as urea and grass forages. Feeding animal-based protein in beef cattle rations was and is not normal practice in Canada.

In Western Canada, breeding cattle are typically on range or pasture, with stocking rates as low as one cow per four hectares. Under this management system, neither the breeding animals nor their offspring receive a supplemental protein source. Accordingly, they would not have consumed MBM before or after the Feed Ban. Historically, in Western Canada, animal protein has seldom been used in beef production. At the present time in the West, urea, forages and cereal grains make up the bulk of feedlot beef cattle rations as well; however, it is becoming more common for feedlot operators to store tallow in bulk on the feedlot and use it in the final rations consumed by cattle. Consumption of tallow at 0.5 kg/head/day is normal. Calving typically occurs in March and April, and the calves are normally weaned in the fall at approximately six months of age.

In the Atlantic provinces, as in Western Canada, beef cattle, either in cow/calf or in feedlot operations, commonly receive no animal protein in their diets. An emerging “home-grown” beef production industry in Atlantic Canada (currently estimated at about 30,000 head) uses urea, locally produced cereal grains and potato by-products as the principal feed ingredients. Commercial feed manufacturers principally supply mineral feed supplements to these beef producers.

In Eastern Canada, breeding cattle are housed in barns in the winter months, with access to the outside for exercise and consumption of conserved forages. Calving typically occurs in March and April (inside or outside depending on weather conditions). Cows and calves are on pasture in the spring and remain there until late fall when the calves are weaned. Under this management system, the breeding animals would not normally receive a supplemental protein source. However, calves may have access to supplemental feeds via creep feeders, and some of these feeds could have contained MBM before the Feed Ban.

After weaning, calves are sent to feedlots where they are grouped by age, weight, and sex. Feedlot rations for younger animals may contain supplemental protein, and this was typically the stage at which MBM might have been fed before the Ban. Feeds vary in composition from company to company, but typical usage rates for MBM (occasionally porcine meal and blood meal) at this stage would have been 100–400 g/head/day. As protein quality is not an important factor for heavier feeders (e.g. >300 kg), rations for these animals typically contain urea or other low-cost protein sources of supplemental nitrogen.

8.3.3. Alternative Feed Sources

Poultry Litter

Processed poultry manure was removed from the list of approved feed ingredients in the Feeds Regulations in May 2000. Registration has always been mandatory in relation to the incorporation of poultry manure litter in livestock feeds; however, no commercial source has ever been registered for poultry litter in Canada. CFIA officials have worked with producer organizations, such as the Canadian Cattlemen’s Association, to advise members not to use poultry manure in feeds. If cattle producers feed raw or processed poultry manure to their animals, it is a contravention of the Feeds Act. The CFIA investigated five reports of this practice in the province of Quebec in 1999–2000, and to date has prosecuted and fined producers in three cases. The use of poultry litter as cattle bedding has been identified as a potential risk. This practice occurs uncommonly, and the CFIA is working with industry to further discourage it.

Edible Residual Material and Plate Waste

Edible residual material (ERM) means edible material that remains after, or is not used in, the processing, manufacturing, preparing, serving, or sale of food (Health of Animals Regulations, Section 111). The ERM Program is regulated under the Health of Animals Act and Regulations, and controls the feeding of waste food, including meat, to swine and poultry. The feeding of ERM to cattle and other species not identified in the Health of Animals Regulations is prohibited unless the product is registered or approved under the Feeds Act. It is required that the producer hold an annual permit (Class A or B), that the ERM be cooked before feeding and that swine that have been on the premises be slaughtered at an establishment registered under the federal Meat Inspection Act. Since the Feed Ban in 1997, edible residual materials and "plate waste" are considered as prohibited material. Plate waste means any edible material originating from kitchens, restaurants, catering facilities or the household of the farmer or person tending the animals.

In 2001, the CFIA prohibited the feeding of ERM containing meat to pigs, and effective January 1, 2002, the feeding of ERM containing meat and meat products (formerly permit Class A) to swine and poultry is no longer permitted unless the products are registered under the Feeds Act. Other waste foods (bakery, vegetables, dairy, etc.) that do not contain meat may be fed under a single class of permit for waste feeding.

The change of the ERM policy does not affect current policies on BSE, in which there is an existing prohibition on feeding products derived from ruminants (which includes plate waste or waste food) to cattle.

8.4. Compliance and Enforcement

8.4.1. Inspection Program

Under the CFIA’s National Feed Inspection Program, feed manufacturers (both commercial and on-farm) and feed retailers are inspected to confirm that feeds are being manufactured, distributed, handled, and used in compliance with the Feeds Regulations and Health of Animals Regulations. Canada has administered a formal feed mill inspection program since 1982 that has continued to evolve since its implementation. Factors such as process controls, record keeping, sanitation and other manufacturing practices have been evaluated as a means of assessing the compliance of feed products with the safety and compositional standards prescribed in federal regulations. Following implementation of the Feed Ban in 1997, compliance components of these regulations have been incorporated into the inspection program for these premises. A copy of the feed mill inspection form is found in Appendix 27. The form clarifies what is required to ensure that cross-contamination does not occur.

Prior to 2002, feed mills underwent a comprehensive inspection every three years. Partial inspections may occur more than once every three years, however, as these inspections, which are carried out between the comprehensive inspections, may be used, for example, to take samples (e.g. for antibiotic residues), verify labelling compliance, follow up on complaints, and trace back residues. Given the importance of compliance with the Feed Ban, as of 2002 the CFIA increased the frequency of comprehensive feed mill inspections to one per facility every year.

The inspection program requires that compliance issues identified during the course of feed mill and on-farm inspections be resolved in a timely manner. Some compliance issues, such as mislabelling of feeds, result in immediate enforcement action. The feed is placed under detention and may not be used for any purpose until it is brought into compliance. Upon completion of the follow-up inspection, an inspection report detailing the results of the follow-up inspection and any recommended actions is submitted to the feed section of the CFIA.

In light of the Feed Ban, a specific inspection component was added to the National Feed Inspection Program. The results of inspections specific to the Feed Ban are provided in Section 8.4.2.

8.4.2. Results of the Inspection Program

Feed Mills:

In the first 18 months after the Ban, nearly all feed mills in Canada were inspected to specifically assess compliance with the Ban. Of those not inspected, 2 produced feeds exclusively for the aquaculture industry and 5 others were low-volume mills in remote areas that were scheduled for comprehensive inspection shortly thereafter.

Table 24 details the feed mill inspections and Feed Ban compliance information from April 1999 to March 2001. A total of 173 mills were inspected during this period.

For each year, the initial level of compliance was in the mid-to-upper 60% range, and faults were immediately corrected. All mills were in compliance after re-inspection. Inspections did not indicate that any prohibited material was being formulated into ruminant feeds; most of the non-compliance issues related to incomplete production and distribution records. Based on immediate correction, the level of compliance reached 80%. The remaining 20% required re-inspection, at which time 100% compliance was achieved (Table 24).

In early 2000, a revised feed mill inspection form was introduced. The form combined compliance activities in respect of the Feeds Regulations, the Feed Ban regulations and feed industry Good Manufacturing Practices. This form currently serves as the basis for recording and compiling compliance information.

The third round of the triennial inspection program (April 2001–March 2002) has been completed. Over 360 feed mills were inspected, the results of which are in the process of being tabulated. In addition, there have been over 160 feed mill inspections from April 2002 to October 2002. All feed mills operating in Canada have now been subject to a comprehensive inspection at least twice since the implementation of the Feed Ban in 1997.

A recent revision to the feed mill inspection program has amended the requirement for triennial inspections. In accordance with this amendment, feed mills will be subject to an annual inspection beginning in the fiscal year 2002–2003.

Feed Retailers:

About 50 retailers have been inspected since 1999 for compliance with the Feed Ban. Retail outlets are required to maintain sales records for animal feeds for two years.

Farms:

About 100 farms have been inspected since 1999 for compliance with the Feed Ban. A copy of the on-farm feed mill inspection form is found in Appendix 28. The farms inspected to date are complying with the applicable requirements of the Health of Animals Regulations to:

• remove prohibited material from their formulae for ruminant feeds;
• maintain the applicable records and copies of invoices as required; and
• have processes in place to prevent cross-contamination.

Table 24: Feed Mill Compliance with the Health of Animals Regulations, Part XIV- Mammalian-to-Ruminant Feeding Ban

Source: CFIA, Feed Mills Annual Inspection Reports
¹ Inspections by Area (% of inspections): ATL = 12 (18) QUE = 13 (20) ONT = 23 (35) WEST=17 (26)
² Inspections by Area (% of inspections): ATL = 12 (11) QUE = 32 (30) ONT = 37 (34) WEST = 27 (25)

8.5. Education and Awareness

Following the linkage of BSE with human disease, and upon the recommendation of the WHO, the inclusion of ruminant protein in ruminant feeds was banned. An extensive consultative process followed to develop the Feed Ban regulations with provincial governments; major national livestock, rendering and feed associations; and other stakeholders. This also served the purpose of ensuring that these groups and their members were well aware of the Feed Ban and its implications.

When the Ban came in force, the CFIA took a number of steps to ensure that feed manufacturers, renderers, feed retailers and producers were aware of the new rules, including the following:

• posting the new regulation on the CFIA Web site;
• preparing and delivering an information bulletin on the Feed Ban for national associations, feed companies, livestock producer associations, agricultural publications, farms, and CFIA regional offices (CFIA inspectors distributed these bulletins when they visited farms);
• issuing press releases (media coverage, newspapers, journals, etc.); and
• asking large animal veterinary practitioners to advise producers (through the Canadian Veterinary Journal).

The information bulletin developed by the CFIA was widely distributed by associations, feed companies and others. In addition, associations provided information to members in their publications. Provincial governments and veterinary associations also circulated information, such as the following, with respect to the Feed Ban (see Appendix 29):

• An article describing the implementation and rationale for the Feed Ban was published in 1997 by major newspapers across Canada.
• ANAC, a national trade association representing more than 200 livestock and poultry feed manufacturing firms, was proactive in updating its membership about the regulations. ANAC distributed information to members as early as six months before the implementation of the Feed Ban in August 1997. Before the implementation of the new regulations, it published and distributed to members a document explaining the requirements. The CFIA bulletin “Check Your Livestock Feed” was distributed to ANAC members, reaching essentially all feed mills in Canada. Since the Feed Ban, ANAC has circulated new information on BSE that could affect members’ operations, thereby reinforcing the importance of complying with the Feed Ban.
• Other national producer associations (dairy, beef, sheep, nutritionists, etc.) or stakeholders distributed information to their members. Newspapers, websites such as the official site of the Canada Gazette, association websites, magazines, bulletins, and other media provided information when the Feed Ban was implemented.

8.6. SUMMARY - FEED

Regulations and Policies for Feed Ban

• The manufacture, sale and importation of feed is regulated by the CFIA.
• All imported mixed feeds and certain categories of feed ingredients must be registered by the CFIA and comply with Canadian standards and regulations.

• A feed ban prohibiting the feeding of protein derived from certain mammalian sources to ruminants has been in effect since August 1997. Under the feed ban, feed manufacturers must maintain complete separation of feed containing specified ruminant-derived protein including by: - maintaining records,
  - labelling feed containing prohibited material, and
  - adopting measures to prevent cross-contamination.

Industry Profile and Feed Mill Practices

• Canada is a large producer of grains and has abundant supplies of vegetable protein meals that can economically and nutritionally replace MBM in feed.
• About 600 feed mills manufacture about 13 million tonnes of feed. About 35% of the total feed is produced in mills that are HACCP certified by the Animal Nutrition Association of Canada.
• Eleven feed corporations own 169 feed mills which are responsible for 70% of the total annual commercial feed production.
• Feed mills have established processes to prevent cross-contamination.
• With the exception of micro-ingredients, all feed ingredients are sourced in Canada or the U.S.

Feeding Practices

• MBM is not normally fed to beef cattle. Dairy cattle need high-quality bypass protein and may receive supplemental feed. Accordingly, this is and has been a target population for BSE surveillance.
• Little milk replacer is imported. Tallow is only imported from BSE-free countries (protein-free tallow can be imported from non-BSE free countries with additional certification).
• No registration has ever been issued for the commercial use of poultry manure.
• “Edible residual materials” and "plate waste" or similar wastes generated by restaurants, cafeterias, and other food-serving establishments are treated as “prohibited material.”

Compliance and Enforcement

• Under the National Feeds Inspection Program, feed mills, retailers and farms have been inspected. Recent changes to the program will increase the intensity of inspection.
• Inspections have shown a high level of compliance. Most deficiencies found relate to minor infractions in record-keeping.

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