Feed Regulatory Renewal Consolidated Modernized Framework Proposal – November 2015
Support for Small Businesses
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The CFIA is sensitive to the needs of small businesses and aware of the importance of finding the right balance between maximizing feed safety and minimizing administrative burden.
The following three elements of the proposed regulatory framework are deemed essential elements of the feed safety framework, regardless of organizational size:
- Permissions: So the CFIA knows who is doing what with feed for the purpose of oversight and, if necessary, enforcement. In addition, the CFIA would be able to reach out to small and medium businesses to ensure they are aware of their regulatory obligations, and to share compliance promotion information.
- Feed safety requirements: The proposed regulations would establish basic requirements for feed safety (e.g. sanitation, hygiene, pest control) with which everyone who manufactures, sells or imports feed would be required to comply.
- Traceability: The ability to trace a feed's path one step forward and one step back – to reduce the time it takes to locate and remove unsafe products from the market.
A "Small Business" is defined as …
… any business with fewer than 100 employees or between $30,000 and $5 million in annual gross revenues.
Given that the scope of the "small business" definition could still result in significant administrative burden on very small business with respect to the three (3) essential food safety framework elements identified above, a "micro-business" is further defined as follows for the purpose of this proposal:
"Any business with fewer than 5 employees and less than $30,000 in annual gross revenues" .
It is proposed that micro-businesses, at the time of application for a permission, be exempt from preparing a written PCP. The exemption would reflect the fact that these micro-businesses are generally less complex. However, the proposal is that this exemption will not be available for permission holders manufacturing feeds that are internationally recognized as having feed safety risks which require appropriate controls (i.e. medicated feeds, handling prohibited material). As risk ranking tools evolve, additional feeds could be excluded from the exemption through regulatory amendment.
In addition, the vast majority of small and micro-businesses would be given additional time to comply with certain requirements of the proposed regulations.
The CFIA will also develop a comprehensive compliance promotion strategy for small and medium businesses. Using the licensing information CFIA will be able to identify and reach out specifically to these businesses with plain language guidance material on how to comply with their regulatory obligations.
Finally, the CFIA will work with industry leaders and academic institutions to encourage a culture of feed safety, sharing of best practices in Canada and new opportunities for training.
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