2012 Review of the Enhanced Feed Ban
Context of the Enhanced Feed Ban 2012 Review
Following the implementation of the 2007 Enhanced Feed Ban (EFB), an initial review was undertaken by the EFB Preliminary Implementation Review Working Group, to investigate opportunities to reduce costs in the packing sector. The working group included government and industry stakeholders. In December 2007, this working group recommended to carry out and complete a full review of the enhancements to the feed ban regulations five years post-implementation in 2012, including an assessment of the merits of continuing to exclude the full list of specified risk materials (SRMs) from feed. To accomplish this task, the Canadian Food Inspection Agency (CFIA) proposed a two-step approach, which included undertaking the EFB 2012 Review in the short term and developing Canada's Bovine Spongiform Encephalopathy (BSE) Roadmap in the long term.
The EFB 2012 Review has been developed to fulfill this commitment using the best-available data and scientific knowledge. Stakeholders' views were also considered as essential to the review. To seek these views, a short-term basis committee, the Ad Hoc Advisory Committee on the EFB 2012 Review, was created in January 2013. Membership of that committee included representatives from government departments, as well as other organizations. The Committee met four times from February 2013 to June 2013. In addition, during the fall of 2013, a broader consultation with stakeholders was undertaken through the Beef Value Chain Round Table and the Canadian Council of Chief Veterinary Officers.
The CFIA began enforcing an initial set of feed ban regulations in 1997. However, the focus of this review is the enhanced feed ban regulatory framework that took effect in 2007, following the detection of BSE cases in Canada. The EFB addressed the prevention of opportunities for cross-contamination or cross-feeding of ruminants with prohibited proteins. To provide further animal health protection, SRM was also banned from all animal feeds, pet foods, and fertilizers. The main objective of the EFB was to accelerate Canada's progress in BSE management by preventing more than 99% of potential infectivity from entering the feed system and by enhancing risk management of transmission of BSE in the cattle herd. These efforts and many other BSE-related initiatives contributed to Canada obtaining the World Organisation for Animal Health (OIE) classification of a "controlled BSE risk" country.
Analysis of the number of Canadian BSE cases in the context of birth year shows that the situation has generally improved since 2004, as no case born after that year has been detected. However, the disease is known for its long incubation period; therefore, information accumulated for cattle born after 2004 has not yet been finalized. The earliest year for Canada to qualify as an OIE "negligible risk" country for BSE is determined, in part, by the youngest cohort in which BSE was found. For Canada, this is 2016. However, this outcome must be considered as the best case scenario. If Canada were to scale back from a full to a partial SRM ban at this time, it would be when insufficient evidence has been accumulated through ongoing surveillance to convincingly demonstrate that the SRM ban has achieved its intended objective.
The CFIA has increased inspection capacity and frequency throughout the feed supply and use chain since the implementation of the feed ban and the EFB. The Agency has also implemented and administered a system of control permits and inspection activities at dead stock collectors, landfills, and other processing and disposal sites regarding the collection, transport, treatment, and disposition of cattle SRM tissues. Different strategies are used to assess compliance and action is taken on any identified non-compliance.
SRM use in Canada remains in the early stages of market development. Currently, over 90% of total SRM is being confined in Canadian landfills, with no conversion into valuable product. This results in increased costs to cattlemen and a decrease in international competitiveness. Since the EFB, many initiatives that aim at reducing SRM confinement have been explored. Canada's current effort to support the SRM disposal initiatives is beginning to show tangible benefits to the beef industry. While these projects have clearly demonstrated the capacity to divert the majority of SRM from landfills, two of the locations are in Eastern Canada where only 33% of the national SRM is generated. To note, these technologies require a minimum volume of organic material to operate at an optimum level of profitability. This situation is identified as a potential project risk, as the net savings would be significantly reduced due to low volume of SRM for processing.
Given the nature of Canada's feed ban, which does not lend itself to permit definitive testing with currently available methodologies, surveillance becomes the only tool available to confirm that Canada has an effective feed ban. For this reason, maintaining an adequate surveillance program is crucial and is why the federal government and other stakeholders have invested heavily in surveillance within the last two decades. However, relying on surveillance to confirm that Canada has an effective feed ban leads to a time lag, which is a direct result of the length of time from when an animal is exposed and becomes infected with BSE, to when it can be detected using currently available tests. On average, this takes about five to six years. As a result, monitoring the cattle population for BSE, at a level of sufficient intensity to gather the evidence required, is a long-term commitment.
To address a recent downward trend in the number of cattle tested, the federal government and various stakeholders have put in place an integrated and collaborative surveillance approach through various collaborative forums.
Over the next couple of years and considering current trading partners, Canada could be one of the few in the top 10 beef exporting countries that remain in the OIE "controlled risk" category for BSE.
The incremental costs of the EFB (post-2006), borne by the industry, are an important aspect of the EFB that should be considered in the review. Information from the Canadian Meat Council (CMC) clarified certain costs borne by the industry; however, determining whether these costs relate directly and only to the EFB requirements and/or to other aspects of the feed ban or SRM removal for food requires further analysis. Therefore, it is suggested to include a complete analysis of the incremental costs of the EFB (post-2006) as part of the recommendations in this review.
It is premature to assess the achievement of longer-term outcomes related to the EFB (i.e. its effectiveness), due to the long incubation period; that is, the time from an animal becoming infected until it first shows symptoms of the disease.
Alternative SRM Uses
This review has identified possible considerations for alternative SRM uses that require further investigation. A few of these originate from the 2007 EFB Working Group and are at various stages of implementation, and include the skull pilot project, modified backbone saw project, dorsal root ganglia (DRG) project (harvesting more meat from the vertebral column), and blood exports to the U.S. Other considerations, such as SRM compost for both land application and in road construction, have not been fully explored.
Outcome and Recommendations
Recommendation #1: Use the criteria that were developed during the review to analyze any potential alternative SRM uses and/or potential changes to the BSE programming, such as the ones discussed in the following recommendations. Criteria:
- Minimize existing risk pathways and avoid the creation of new risk pathways, including spill over into other susceptible species.
- Enhance Canada's OIE BSE status.
- Enhance domestic and international confidence, including market access into the U.S. and beyond.
- Be economically sustainable.
- Maximize harmonization with U.S. SRM regulations.
- Reduce regulatory burden.
- Be environmentally sustainable.
- Ensure that funding is available through the current Government of Canada budget for the BSE Program. If new funding from the Government of Canada is required, identify a new source of funding.
Recommendation #2: Analyze further the possibility of harmonizing the SRM list with that of the U.S., and move to a shorter SRM list through the BSE Roadmap process within the coming year.
Recommendation #3: Conduct various analyses on the impacts of the EFB within the coming year by possibly updating the BSE risks and economic and trade analyses. To provide the required input into any updated analyses, working groups, comprising government and industry representatives, could be created to manage this project. There is a need to include the greater context of risk tolerance and risk management for BSE in the results of these reviews, which could perhaps be done in the context of the BSE Roadmap exercise. Funding sources would need to be discussed.
Recommendation #4: Further investigate how certain elements related to the EFB could be moved from various regulations to policy instruments to streamline the process for updating these elements without incurring extended waiting periods. This investigation could also be realized in the context of the BSE Roadmap expected to be completed in 2014.
In terms of the next EFB review, the committee recommends another review of the EFB post-2016, after the first opportunity for an adjustment to Canada's BSE OIE risk status.
The complete report is available on request.
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