Feed Ban Enhancement
Questions and Answers

General | Slaughtering and processing beef | SRM - General | SRM Disposal | SRM-Dyeing | SRM-Rendering | Fertilizers and Supplements | Pet Food | Fish Meals, Oils and Concentrates

General

Q1 What changes were made to Canada's animal feed ban?

Feed restrictions are universally recognized as the critical measure to contain the spread of BSE.

The Canadian Food Inspection Agency (CFIA) enhanced the existing feed ban by requiring the removal and redirection of specified risk materials (SRM) from all animal feed, pet food and fertilizers. SRM are tissues that have been shown in infected cattle to contain concentrated levels of the BSE agent.

Q2 Are SRM removed from human food?

Yes. The removal of SRM from all cattle slaughtered for human consumption was the first safeguard implemented by the Government after BSE was detected in a Canadian-born cow in 2003. This measure is internationally recognized as the most effective way to protect food safety from BSE.

Q3 What tissues are defined as SRM?

SRM

include:

• the distal ileum of cattle of all ages; and
• the skull, brain, trigeminal ganglia, eyes, tonsils, spinal cord and dorsal root ganglia of cattle 30 months of age or older.

SRM

banned for use in feed, pet food and fertilizers are the same as those removed from all cattle slaughtered for human consumption.

Q4 Why did the CFIA making changes to the feed ban?

Surveillance results and investigations of cases indicate that Canada's feed ban had effectively reduced the spread of BSE since being implemented in 1997. However, even compliance with the ban's requirements left limited opportunities for contamination during manufacture, transportation and storage. In addition, the accidental misuse of feed on farms with multiple species could not be discounted. Enhancements to the ban focused on preventing potentially infective tissues from entering the feed system. By taking this action at the top of the feed chain, potential downstream risks associated with contamination and misuse are addressed. Removing SRM eliminates more than 99% of potential infectivity from the feed system.

These enhancements will accelerate Canada's progress toward eradicating BSE from the national herd. Based on risk analyses, BSE eradication, which is estimated to have taken several decades with the current feed ban, should now be achieved in approximately ten years

Canada's actions are supported by the international team of animal health experts that reviewed the Canadian situation. This team strongly endorsed the removal and redirection of SRM from the entire animal feed chain.

Q5 Why were fertilizers included in the feed ban enhancements?

Byproducts, such as meat and bone meal, have traditionally been used in feed and a variety of fertilizer and supplement products.

Restricting the use of SRM in fertilizer products is intended to ensure that ingredients derived from cattle do not accidentally re-enter the animal food chain.

As an added safeguard, fertilizers and/or supplements containing ruminant proteins other than SRM are required to be labelled with the cautionary statement that the product is not to be spread on land grazed by ruminants.

Q6 Why was pet food being included in the feed ban enhancements?

On farms where livestock and domestic pets may live together, cattle may be inadvertently or intentionally exposed to pet food. The removal of SRM from pet food addresses this risk.

Q7 What happens to SRM, dead stock and condemned cattle?

The Government has been actively collaborating with the provinces, territories and industry to identify and develop disposal and alternative-use options. The safe and sustainable disposal of waste materials is a shared responsibility of the generators of waste materials as well as federal, provincial / territorial and municipal governments.

Q8 The enhancements to the feed ban provide scope to allow for outcome-based approaches. What does that mean?

The primary goal, or outcome, of the enhancements is the elimination of more than 99% of potential infectivity from entering the feed system. The default method for achieving this objective is the removal of all SRM; however, regulated parties may develop and propose alternative approaches, with supporting scientific data, that can be shown to achieve the same level of protection as full SRM removal.

This will allow for scientific innovation and provide flexibility for industry, while maintaining a high level of animal health protection.

Q9 With SRM removed from the feed system, do cattle producers still need to use ruminant-specific feed?

Yes. The enhancements remove almost all potential known infectivity from the animal feed chain. However, producers must still only use ruminant-specific feed for their cattle. Cattle can develop BSE by eating as little as one milligram of infected tissue. Furthermore, the science surrounding BSE continues to evolve and may at some point identify other cattle tissues capable of transmitting the disease.

Q10 Prior to these enhancements, was there a BSE-related risk for pets?

Dogs are not considered susceptible to BSE. Cats have been shown to develop a related disorder, known as feline spongiform encephalopathy, but the risk associated with pet foods sold and used in Canada is considered low.

Q11 Are blood and blood products banned from Canadian animal feed as part of the new measure?

No. Blood and blood products were exempted from the scope of the 1997 feed ban. Consistent with internationally recommended standards, cattle blood is not considered to pose a risk of BSE transmission. Blood and blood products from cattle and other ruminant animals can continue to be used as a feed ingredient for cattle and other ruminant animals, as long as they do not contain prohibited material (i.e. specified risk material).

Q12 Were regulated parties consulted during the development of the enhanced feed ban?

Yes. Since August 2003, the CFIA has been consulting widely with interested industries on proposals for an enhanced feed ban, and their concerns have been taken into account in developing the enhanced regulations. The CFIA has been, and will continue to be, flexible in its approach to meeting the objectives of the enhanced feed ban. In addition, full consideration was given to the comments received during the formal Canada Gazette comment period procedures.

Slaughtering cattle and processing beef

Q1 How do I handle deadstock inside my establishment?

Dead animals must be segregated in a designated specified risk material (SRM) area within the inedible products section for staining and disposal, in accordance with the Health of Animals Regulations. There are two options for staining:

1. If SRM is removed from the deadstock, the remaining carcass is considered non-SRM; however, the SRM removed from the carcass must be stained.
2. If SRM is not removed from the deadstock, the whole carcass is considered SRM. The carcass must be marked with a wide stripe down the back of the head and length of spine using a dye or stain which contrasts to the animal's coat colour.

Staining should be performed in common dedicated leak-proof containers, bins or trailers, or inside the auger using a spray. The stain should be applied over each layer of SRM, so that it is visible on the surface of all SRM.

Q2 What is the definition of a "designated SRM area"?

A designated SRM area is an identified area within the inedible products section of the establishment. This area is used for collecting, staining and storing SRM before shipping. SRM stored in this area must be physically separated from other inedible products in dedicated leak-proof containers to prevent cross-contamination.

Q3 What equipment within a slaughtering facility should be considered dedicated for SRM?

Any equipment that comes into direct contact with exposed SRM, such as containers for collection, segregation and staining of SRM and trailers for transporting risk material, should be dedicated for SRM only. Other equipment, such as augers, chutes, drive belts and conveyor belts, should be assessed on a case-by-case basis. A dedicated conveyor belt, chute or auger is not required if:

• the distal ileum is removed at the end of the evisceration process or in a designated area and is immediately segregated from the rest of the digestive tract;
• OTM vertebral columns are collected in dedicated SRM containers immediately after boning; or

A tray or screen is installed to catch SRM fragments in areas where there is the potential for it to fall - for example, the area where spinal cords are vacuumed.

Q4 How should dedicated SRM containers be identified?

Dedicated SRM containers must be clearly and indelibly marked with the words "Specified Risk Material / Matériel à risque spécifié" or the acronyms "SRM/ MRS", in both official languages.

Q5 What are the cleaning requirements for dedicated SRM containers and equipment?

Dedicated equipment should be routinely cleaned and sanitized. Dedicated SRM containers should be cleaned by pressure washing. In addition, the debris/solids recovered during the cleaning and disinfection process must be stained and disposed of like other SRM.

Q6 What are the cleaning requirements for transport containers or trailers carrying cattle carcasses or parts to cutting or boning facilities?

If the risk materials are still inside the carcass or in boxes or crates, and there is no direct contact between the SRM and the transport container, routine cleaning (e.g. pressure wash) is acceptable. If there is a direct contact between the SRM and the transport container, thorough cleaning and disinfection of the container with bleach or sodium hydroxide (NaOH) is required before using it to transport non-SRM material.

Q7 Why does SRM need to be stained if it is contained in a dedicated, labelled container?

Government of Canada regulations require SRM to be stained if there is no provision for on-site disposal. SRM that is contained needs to be stained in case the labelling on the container is not noticed. Furthermore, SRM cannot be transported if it is not stained and properly marked within a container.

Q8 What are the requirements for on-site destruction or permanent containment of SRM?

All inedible material from all species, including SRM and carcasses considered SRM, must be permanently contained on the premises of the establishment. Containment options, such as burial, must comply with provincial and municipal standards and requirements.

Where allowed by provincial and municipal requirements, inedible materials may be composted to reduce waste volume. However, no composted material may leave the premises without a CFIA permit to transport SRM.

Q9 Why doesn't the CFIA regulate SRM that remains on premises, such as farms and small abattoirs?

CFIA regulations and programs aim to place enforceable controls on the commercial sector, which handles the vast majority of risk tissues. SRM that is disposed of on-site represents a small portion of risk tissues in Canada.

Q10 Are animal material and debris recovered from wastewater considered SRM?

Washing effluent from beef slaughter establishments must pass through a drain or line in which the inlet has been restricted or an apparatus has been installed in the process sewer line, such that all particles in excess of 4 mm have been removed. Screened organic debris that is greater than 4 mm in size must be considered as SRM.

The floor waste and wastewater generated in beef cutting and boning areas will not be considered SRM provided the OTM vertebral columns, including those that accidentally drop onto floor, are properly segregated from other materials and placed into designated SRM bins.

Q11 How do you stain OTM carcass sides or quarters that are being sent for cutting and boning?

Edible, blue ink must be applied to the exposed surfaces of the vertebral column of each OTM carcass side following removal of the spinal cord.

Q12 If an animal is found dead on arrival or euthanized inside the trailer and the operator prefers not to unload the animal, can it be stained and transported to a deadstock operator in the same truck?

This is only allowed if the truck driver has a permit to transport SRM. If so, the truck would require adequate cleaning and disinfection before carrying healthy animals again. If there is no direct contact between the SRM and surface of the conveyance, a regular, high-pressure wash would suffice.

Q13 Will bovine blood be treated as SRM?

Slaughter establishments using penetrating stunning device (captive bolt) are considered at high risk of contaminating bovine blood with prohibited material. The CFIA's Animal Health group is drafting a national policy for the collection of bovine blood for use in animal feed under the enhanced feed ban. Exceptions would be veal-only establishments (birth certificate or breed registration certificate) or any other option, as outlined in the policy, which would prevent contamination of blood with brain tissue.

Q14 Why does the weight of OTM carcasses containing dorsal root ganglia need to be recorded if the operator already keeps track of the number of OTM carcasses shipped to cutting and boning establishments?

CFIA regulations require that both the weight and number of OTM carcasses containing SRM be recorded.

Q15 Can non-inspected slaughter facilities estimate the weight of SRM being sent for disposal?

Truck drivers who transport SRM are required to maintain complete records, including the combined weight of the SRM collected or received. Therefore, it should be expected that they will request accurate information about the weight of SRM they collect from any facility.

Scales should be available in all slaughter facilities, whether non-inspected, provincially-inspected or federally-inspected. There are no prescriptive requirements as to how this weight must be determined. CFIA area staff are available to discuss specific weight measurement proposals.

Q16 Is there a requirement to record animal tag numbers on carcasses, sides or quarters at the time of shipping?

Canadian Cattle Identification Agency (CCIA) or Agri-Tracibilite Quebec (ATQ) tag numbers must be recorded for all deadstock containing SRM. In the case of slaughtered animals, CCIA or ATQ tag numbers are only tracked to the point of final carcass inspection on the kill floor. Therefore, a meat inspection legend is available on OTM carcass sides/ quarters at the time of shipping to other establishments.

Q17 Why do SRM records need to be maintained for 10 years?

Record keeping requirements for SRM were implemented under the Health of Animals Regulations as part of the enhanced feed ban. Due to the long incubation period of bovine spongiform encephalopathy (BSE), records for SRM related activities have to be kept for a 10-year period. In addition, record-keeping requirements for renderers and feed manufacturers have also been extended to 10 years.

Q18 If the skull is considered SRM, does that mean that the jaw bone is also considered SRM?

The lower jaw or mandible of an OTM animal is not SRM, provided it is separated from the skull in a sanitary manner to the satisfaction of the veterinarian-in-charge.

Q19 Are the contents of the distal ileum (portion of the small intestine) considered SRM?

No. While the distal ileum itself is considered SRM, its contents are not. The distal ileum should be removed using dedicated tools and placed into designated SRM bins. The floor waste and wastewater generated in and around the area where the distal ileum is removed will not be considered SRM provided the segregation of distal ileum is maintained from other materials.

Q20 Is the external fat on the distal ileum considered SRM?

The fat on the outside of the distal ileum is not considered SRM. It can be included in non-SRM parts, provided that the distal ileum is not opened and no part of it is included in the fat.

Q21 Is it acceptable for an operator to remove and segregate all SRM from a condemned OTM carcass so that the remaining non-SRM can be disposed of using the normal process for condemned inedible material?

This is acceptable, as long as there is adequate space for the operator to perform this procedure in a manner that does not create a potential contamination hazard for edible meat products or non-SRM inedible meat products in the establishment. The veterinarian-in-charge must approve this type of activity.

Q22 Where in the establishment should an operator remove and segregate the distal ileum from the rest of the eviscerated digestive tract?

In most establishments, the area where paunch contents are separated from the rumen may be a suitable location for this activity. The veterinarian-in- charge must seek CFIA approval for this type of activity.

Q23 At what stage in gestation is a fetus separated from a cow considered as SRM?

An unborn fetus or a non-viable calf (does not breathe) recovered from a cow under veterinary supervision (at establishments with full-time veterinary inspection or single cases delivered on-farm or at clinics by veterinarians) are not considered SRM. However, any term fetus with body hair or newborn calf on the ground inside the establishment is considered SRM, unless the distal ileum has been removed.

In any establishment without full-time veterinary inspection, a non-term fetus (fetus without hair) is considered non-SRM and a term fetus (fetus with hair) is considered SRM.

Q24 What are the permit requirements when dead or condemned animals are transported intact to another?

The animal must be identified, tagged and marked with a colouring dye inside the establishment. A permit is required for transportation of the animal to the second site and the second site will require a permit to receive SRM.

Q25 If the blood from an OTM carcass passes through a 4 mm screen and then goes down a drain into a septic tank and field tile system, would the sludge that eventually accumulates in the septic tank be considered free of SRM?

Liquid waste from either UTM or OTM carcasses must pass through a filtering mechanism for particles greater than 4 mm in diameter. Filtered material is not considered SRM and the liquid and sludge are not subject to further CFIA controls.

As of May 4, 2007, the wording in the Manual of Procedures reads as follows: "Liquid effluent must pass through a drain or line in which the inlet has been restricted or an apparatus has been installed in the process sewer line, such that all particles in excess of 4 mm have been removed. The screened organic debris greater than 4 mm must be considered as SRM."

Q26 Will CFIA allow removal of excess water from SRM containers to reduce SRM volume?

Based on previous risk assessments, dedicated containers with 4 mm or less screen size can be used to remove water before staining of SRM in dedicated leak-proof containers. The water removed must pass through 4 mm pore size pre-treatment screening system. Screened material must be disposed of as SRM.

Q27 If traces of blood from the carcass of an over-30-month bovine pass through a 4 mm mesh size filter along with wastewater and then travel down a drain into a septic tank and field tile system, is the sludge that eventually accumulates in the septic tank considered non-SRM?

Liquid effluent must pass through a drain or line in which the inlet has been restricted or an apparatus has been installed in the process sewer line to remove all particles in excess of 4 mm. The screened organic debris must be considered as SRM, but the resultant liquid and sludge is not subject to further CFIA SRM controls.

Q28 Is a permit required to transport a dead bovine to a mink farm for use as mink food? If so, would this be a one-time permit or would a permit be required for each transport?

A permit is required to transport all bovine deadstock. The mink farmer also requires a permit to receive SRM in any form (including whole carcasses) and to harvest the red meat for feeding to mink. Appropriate disposal of the SRM is also required.

The issuance and duration of permits depends on the findings of the CFIA inspector and the anticipated frequency of the activities. Permits can be issued for short periods of time or longer (e.g. one year) depending on the nature of the activity, the frequency and the procedures in place at the site.

Q29 Can SRM be hauled on the same truck as other products as long as it is in a separate compartment?

In the training for transportation inspections, we describe such situations as allowable. The SRM must be stained, stored in a leak-proof container and labelled.

Q30 Do SRM containers need to be disinfected after each use?

The containers for SRM do not necessarily have to be disinfected - that would depend on whether they were dedicated to SRM use or will be used for another purpose.

Q31 Why do small abattoirs have an additional six months (until January 30, 2008) to comply with requirements of the SRM feed ban?

The additional six-month period provides more time for small abattoirs to make infrastructure changes, complete staff training and make transport and disposal arrangements to meet all the provisions of the regulations.

An exemption from the requirement to segregate and stain SRM will be allowed, provided that the SRM and other inedible material remain on the premises.

The staining and segregation of SRM, including the carcasses of cattle from which SRM has not been removed and which will leave the premises for disposal off-site, will still be required in order to prevent accidental incorporation of SRM into the animal feed chain.

Q32 Is there any procedure for disposal of bovine carcasses condemned at post-mortem inspection?

Bovine carcasses condemned at post mortem inspection must be treated as SRM unless all SRM has been removed, including the vertebral column with the dorsal root ganglia attached from over thirty month (OTM) carcasses. The rest of the carcass can be disposed of according to MIR 54 (1). It is not necessary to wash the carcass, on the kill floor, prior to disposing of the carcass.

Q33 If an animal is stunned and a head bag is used to contain the nasal drip, should the bag go into the stream of SRM waste since it may contain SRM?

Yes. The bag and contents should be discarded as SRM and should go into the SRM stream. However, bags may be discarded as regular waste if they are properly washed to remove visible contamination, to the satisfaction of the veterinarian-in-charge.

Q34 If an operator uses a non-penetrating stunning device for over thirty month (OTM) cattle and an animal has to be stunned twice, is the blood considered contaminated by SRM if they do not have a written protocol to prevent the contamination of the blood by nasal drips?

The policy states that nasal drip from an OTM carcass is considered SRM if the animal is stunned more than once by a penetrating stunning device. Establishments using non-penetrating devices for stunning OTM cattle should submit their protocols and procedures to the CFIA for evaluation of stunning efficiency and animal welfare concerns, before a decision can be made on nasal drip.

Q35 Is it acceptable to discard contaminants such as hydraulic fluids, heavy metals and other chemicals into SRM containers?

No. Contaminants, such as hydraulic fluids, heavy metals and other chemicals, should not be discarded into SRM containers since tallow extracted from rendered SRM is used in animal feeds, cosmetics, soap etc., and deliberate inclusion of such contaminants may pose animal and public health risks.

SRM - General

Q1 How does the CFIA know whether SRM is removed from products or rendered material, given that there is no test to identify SRM?

The CFIA currently conducts inspections and reviews procedures and records at meat processing plants, rendering plants, feed mills, and other facilities, to verify that operators are meeting the current SRM food and ruminant feed ban regulations. Under the enhanced feed ban, there are added requirements and inspection activities to verify that the regulations are being followed. For example, SRM removed from or contained in cattle carcasses or parts of carcasses must be stained with a conspicuous dye to identify the SRM.

Q2 Does Canada allow imports of rendered products containing SRM from the United States or other countries? Since it is not required in the United States to remove SRM from rendered material, how will we know for sure that an imported rendered product is free of SRM?

Imports of ruminant animals and materials derived from them are subject to the CFIA's BSE Import Policy for Bovine Animals and their Products (see www.inspection.gc.ca/english/anima/heasan/pol/ie-2005-9e.shtml). Ruminant animals and materials derived from them are imported or restricted entry into Canada depending on the BSE status of the country from which they originate.

Since 2003, Canada has had a general ban on imports of ruminant by-products, including rendered material from the United States. However, pet food imports from the United States have been allowed into Canada with certain conditions, including the removal of SRM from any rendered material.

SRM Disposal

Q1 What are the requirements for accepting and disposing of SRM?

A CFIA permit is required to accept and dispose of:

• Deadstock cattle containing SRM;
• Meat and bone meal (MBM) made from deadstock cattle or SRM;
• Compost made from deadstock cattle or SRM.

There are specific construction and operating requirements for facilities handling SRM. Disposal must either destroy or permanently contain SRM. Proposed disposal procedures must be assessed by the CFIA to present, at most, a very low risk of potential BSE transmission.

A CFIA permit is also required to transport any SRM, including cattle carcasses containing SRM. A visible stripe must be applied down carcasses' backs, and all SRM must be stained. Waste management facilities must not accept cattle deadstock or SRM in any form from anyone not possessing a CFIA permit.

Q2 Do cattle producers require a permit to dispose of cattle on-farm that die on-farm?

No. CFIA regulations and programs aim to place enforceable controls on SRM that could potentially end up in the commercial sector, which handles the vast majority of risk tissues. Deadstock that are disposed of on-farm represent a small portion of risk tissues in Canada.

Q3 Where can I get an application for a SRM disposal permit?

Applications for SRM disposal permits are available online at www.inspection.gc.ca/bse.

Q4 How long are SRM disposal permits valid?

Disposal permits for commercial operations who frequently handle SRM may be valid for up to one year. Other permits, for isolated SRM disposal needs, may be valid for periods of 30 or 60 days.

Q5 How much does a permit cost?

CFIA permits to transport, accept and dispose of SRM are free.

Q6 Do I need to submit any other documents other than the application itself?

Yes. Applications for a permit from the CFIA must be accompanied with:

• All relevant municipal and provincial licences and inspection reports
• Detailed site plans
• Normal operating procedures and any additional applicable quality assurance programs pertaining to the containment of SRM landfills
• The results of any recent analyses or verifications relevant to SRM containment

A CFIA inspector will review the documentation, and arrange for a site inspection at the disposal facility. Permits will only be issued after the inspector has determined that all requirements for disposing or permanently containing SRM have been met.

Note: As requirements may differ on a case-by-case basis, applicants should verify requirements with the nearest CFIA office.

Q7 Where do I submit my application for permit?

The application for a permit, along with the required documentation, should be submitted to the nearest CFIA office. For a list of CFIA offices, check the blue pages in the phone book or visit www.inspection.gc.ca.

Q8 What is the recommended method for on-farm disposal of SRM?

For information and requirements concerning on-farm disposal of SRM, the CFIA recommends that producers contact their provincial agricultural authority.

Q9 Is composting seen as an acceptable method of disposing of SRM?

Since composting has not proven to destroy the presence of prion in SRM, composted SRM is still considered SRM. If carcasses or SRM are composted, the compost should not be spread on land grazed by ruminant livestock for the following five years.

Off-farm composting of SRM is subject to SRM disposal permitting requirements. Mass composting is only permitted if the CFIA has control of the end site of the SRM. The use of the end product of mass SRM composting (i.e. spreading on land not grazed by ruminant livestock for the following five years) will be permitted by the CFIA on a case-by-case basis.

Q10 If an animal dies in transit, can the carcass be brought back to the premises of origin for disposal?

SRM and carcasses containing SRM may go back to the premises or origin under a SRM transportation permit. Once returned the premises of origin, carcasses may be disposed of without a CFIA permit.

Q11 If a producer buries an animal on their own land, do they have to report it?

On-site disposal of animals does not have to be reported to the CFIA under the enhanced feed ban. However, there may be other requirements to report the death and disposal of an animal, such as reporting the ID number to the Canadian Cattle Identification Agency or similar ID programs or reportable disease obligations. There may also be municipal or environmental regulations that apply.

Q12 When transporting cattle carcasses, is the SRM permit number required on the outside of the conveyance?

If the carcass is being transported in a truck, vehicle or trailer, then the license plate on the vehicle (which appears on the permit application form) will suffice. However, if the carcass is being transported in another type of conveyance, such as a tarp or bucket, then the permit number must be clearly marked (i.e. spray-painted) on the outside of that conveyance.

SRM-Dyeing

Q1 How does a carcass or part of a carcass containing SRM and segregated SRM need to be stained?

All SRM requires staining so that the SRM is identified and segregated from inedible material.

At registered meat establishments, all segregated SRM and part of carcasses containing SRM (e.g., OTM carcasses with dorsal root ganglia still attached) must be conspicuously stained with a meat-marking dye approved by the CFIA (e.g., blue meat-marking dye).

The stain should be applied to each layer of segregated SRM so that the stain is visible on all surfaces i.e., every time the SRM is transferred to a common SRM staining container or trailer, it has to be stained by spraying.

At all locations, all deadstock or condemned carcasses from which SRM has not been removed must be marked with a wide stripe down the back of the head and length of the spine using a dye or crayon colour that must contrast with the animal's coat colour and is safe for animal consumption. For suggestions of some suitable dyes or crayons and their effect on hides for tanning, contact your local CFIAoffice.

SRM-Rendering

Q1 Once SRM is rendered, does it still need to be stained? Would the stain or dye still have to be safe for animals to eat? Can charcoal be used for staining?

If SRM is rendered, it may still need to be dyed or stained to enable distinguishing it from other rendered material that do not contain SRM. The need for more staining after rendering will be decided on a case-by-case basis, depending on the SRM controls used at each facility. The requirement to use dye or stain that is safe for animals to eat may not necessarily apply to rendered SRM if the SRM is immediately dispatched for disposal or destruction. If charcoal meets the requirements of being conspicuous and indelible, then it is a possible staining material for rendered SRM.

Q2 Will the status of tallow derived from SRM change after July 12, 2007? Can tallow be used in animal feed?

As long as tallow derived from SRM meets the limit of no more than 0.15% insoluble impurities, as set out in the revised Health of Animals and Feeds Regulations, tallow can be used in any animal feed, including in feed for ruminants. This standard applies to all tallow derived from ruminant sources, whether it is tallow from SRM specifically or from ruminant material.

Q3 In a facility that renders SRM, any solids (sludge) recovered from the treatment of waste water will have to be treated as SRM as well. This being the case, could processing aids that are not approved by the CFIA for use in the production of feeds be used to assist in recovering solids from waste water?

The answer depends on how the sludge is to be handled or used. If there is no recovery of tallow during the rendering of SRM, the answer is yes. If the recovered sludge is to be directly disposed of along with rendered SRM, then again the answer is yes. However, if there is to be recovery of tallow from rendered SRM and the recovered sludge is to be reprocessed along with raw SRM, then the answer is no, unless it can be demonstrated that the processing aid product(s) would not affect, or be included with, the tallow that is recovered.

Fertilizers and Supplements

Q1 I understand that if my product contains prohibited material, I have to put warning statements on the product label in both official languages. Does that also mean that the whole label has to be in both French and English?

Yes. The Fertilizers Regulations state that if part of a product label is in both official languages, then the entire product label must be in both languages. Thus, since the warning statements regarding prohibited material must be in both official languages, then the entire product label must be in English and French.

Q2 If a compost facility were to process only municipal organic waste, would the product be exempt from the labelling and record keeping requirements?

Yes. Compost that contains food-grade animal protein in the form of household organic waste will not be subject to the prohibited material warning statements, recall procedures and record keeping requirements.

Q3 How will individuals using material from rendering plants as a component of fertilizer know if the rendered product contains SRM?

Specified risk materials (SRM) are controlled by permits and remain segregated and tracked after removal. SRM should not be a component of any animal product sold by a rendering plant in Canada.

Q4 Are there requirements for fertilizers and supplements containing non-prohibited material (i.e. feathermeal) from a rendering plant?

If the product is to be sold domestically, the warning statements, record-keeping and recall requirements do not apply, unless the product also contains prohibited material. If the product is to be exported, a Canadian Food Inspection Agency (CFIA) export permit is required.

Q5 Are there requirements for on-farm composting of SRM?

On-farm composting of SRM is not regulated by the CFIA, provided that the components of the compost are produced on the same farm and the finished compost does not leave the premises. Therefore, the enhanced requirements do not apply to compost made and kept on farm.

Q5 Some potash producers use tallow derivatives (specifically tallow amines) as a potash flotation agent in preparing feed potash. Are tallow amines, or other tallow derivatives, subject to the same requirements as tallow, i.e., do they have to meet the 0.15% insoluble impurities limit, or are they exempt?

The most prudent approach to making tallow derivatives that will comply within the scope of this new definition would be to use tallow that meets or exceeds this impurities standard as a starting material. Otherwise, you would have to demonstrate that the derivative does not contain prohibited protein to enable use in any feed for livestock.

Tallow derivatives (along with tallow itself) were originally exempted from the requirements for ruminant by-products under the feed ban. Under the enhanced feed ban regulations, however, tallow derivatives will be covered by the same requirements as tallow itself. If the tallow used as a starting material to produce the derivatives meets the new ingredient standard (less than 0.15% insoluble impurities), any derivatives are automatically considered free of prohibited material (PM) and can be used in producing livestock feed with no restrictions. Seeking certificates of analysis from your tallow and tallow derivative supplier(s) to support the compliance of your own products with the new requirements would be a reasonable approach.

Pet Food

Q1 If there is a pet food manufacturer that has pet food containing material with SRM, produced before July 12, 2007, still in stock after this date, what can they do with it? Is a permit required to move it?

After July 12, 2007, the sale or feeding of any animal food containing SRM will be prohibited. A permit would be required to move or dispose of any left-over pet food containing SRM, since this would come under provisions in the enhanced regulations prohibiting the movement, disposal, etc., of material containing SRM without a permit from the CFIA.

Q2 Are pet foods from other countries, such as the United States, allowed to be imported into Canada?

Imports of ruminant animals and materials derived from them are subject to the CFIA's BSE Import Policy for Bovine Animals and their Products (see www.inspection.gc.ca/english/anima/heasan/pol/ie-2005-9e.shtml). Ruminant animals and materials derived from them are imported or restricted entry into Canada depending on the BSE status of the country from which they originate.

Fish Meals, Oils and Concentrates

Q1 Why were fish rendered products being included in the feed ban enhancements?

The CFIA extended the regulatory controls to manufacturing and importation of fish meal to conform to the conditions required for all other products of rendering plants. Regulations administered by the CFIA have previously not applied to products and by-products that are derived from fish that could be used in animal food. However, it is possible that BSE could be spread via the adulteration or contamination of domestic or imported sources of fish meal with materials of cattle origin. The regulations were amended to allow for the control of domestic and imported fish meal.

Q2 What are the requirements for rendered meal from non-negligible BSE risk countries, i.e. Category 2 & 3 (other than the U.S.)?

As of October 1, 2007, rendered products from Category 2 & 3 countries, are not allowed entry into Canada without a case-by-case evaluation, at full cost to the importer. A full risk assessment may be required, as well as on-site inspections by the CFIA.

Q3 Why must the product's destination be listed on the permit?

The initial destination of a product imported to Canada is required so that audits may be carried out as required, and to help to focus any recall procedures that may become necessary.

Another benefit of these amendments will be enhanced traceability of fish meal and fish oil from both domestic and import sources through the feed system. Identifying the locations and origin of primary ingredients, such as fish meal and fish oil, allows the CFIA to more effectively direct its resources to monitoring and sampling activities related to the safety of these products. Sampling and testing these ingredients directly, rather than the finished feed products, provides a more accurate picture of the safety of the ingredients.

Q4 Why must records of distribution (any transfer or sale) be maintained for 10 years?

Due to the long incubation period of bovine spongiform encephalopathy (BSE), regulations require records of distribution (any transfer or sale) of meals and other products of rendering plants to be kept for at least 10 years.

Q5 If the final destinations are not known at the time of importation, what must be included for information on the permit?

While the final destination of a product may not be known at the time of import, the name(s) and address(es) of the destination where it will be initially handled/unloaded in Canada must be provided to the CFIA for traceability purposes. The responsibility to track the product from that point forward rests with the subsequent owners of the product. The CFIA should ultimately be able to trace the product to its final destination.

Q6 How do I apply for a permit, where do I send the application and what information is required?

Contact the Import Coordinator at your area CFIA office for further instructions on conditions for import of fish meal. The Import Coordinator will be able to guide you through the application process, the required fees, the length of the permit and any additional certification or documents which may be required, depending on the commodity you wish to import.

ATLANTIC AREA
P.O. Box 6199
33 Weldon Street, Suite 100
Moncton, New Brunswick
EIC 0N5
Telephone: 506-851-7651
Facsimile: 506-851-3700

QUÉBEC AREA
Room 746-S, 2001 University Avenue
Montreal, Quebec
H3A 3N2
Telephone: 514-283-8888
Facsimile: 514-283-6214

ONTARIO AREA
174 Stone Road West
Guelph, Ontario
N1G 4S9
Telephone: 519-826-2810
Facsimile: 519-837-9771

WESTERN AREA
1115 - 57 Avenue North East Calgary, Alberta
T2G 4X3
Telephone: 403-292-5825
Facsimile: 403-292-6629

Q7 I only want to import products from the USA. Is this allowed?

Yes. However, certain conditions must be met. You must apply for a permit and complete a facility questionnaire. If your application is approved, official veterinary certification must accompany each shipment.

Q8 Are there any restrictions on the end use of imported fish products?

There are no restrictions on legally imported rendered fish products accompanied by a valid permit and all the necessary documentation, from either the U.S. or Category 1 countries.