The Canadian Food Inspection Agency's (CFIA) Policy on Domestic Use and Export of Specified Risk Material (SRM)-Removed Ruminant Meat and Bone Meal (MBM)

Background

The current feed ban (implemented in 1997) prohibits the feeding of most protein materials from mammals to ruminant animals. At the time, this was considered to be an appropriate level of risk management for a BSE-free country. However, with the 2003 finding of a domestic case of BSE and subsequent cases, Canada's BSE, situation requires an enhanced management approach. The continued presence of potentially BSE infected tissues of cattle (SRM) in feed for non-ruminant animals presents opportunities for cattle exposure that represents an unacceptable level of risk. Cattle remain at risk of developing BSE, as evidenced through CFIA investigations identifying feed cross-contamination issues which are likely responsible for BSE cases in cattle born after the introduction of the feed ban. The enhanced feed ban regulations which come into force on July 12, 2007, are intended to virtually eliminate the consequences of potential cross-contamination by completely removing SRM from animal feed, pet food and fertilizer. The new regulations will also prohibit the exportation of animals, animal products and products of rendering plants without a certificate.

The segregation of SRM at slaughter creates the opportunity to produce SRM-removed MBM at appropriately dedicated facilities or those with dedicated lines. Only SRM-removed MBM would be permitted for feeding non-ruminants domestically and would still be considered a prohibited material for ruminant feeding.

OIE Considerations

With respect to SRM-removed MBM, there is no such commodity recognized by the OIE at this time. OIE BSE standards recommend that MBM not be traded, to prevent the spread of BSE associated with high risk commodities, such as MBM. There is no distinction between SRM-removed or non SRM-removed MBM. As a result, there are no established criteria to demonstrate the effectiveness of procedures to eliminate contamination of MBM with SRM. Canada has recently petitioned the OIE (December, 2006) to examine the risk posed by MBM derived from production systems from which all SRM has been excluded, to determine if there is an opportunity to provide for safe trade of SRM-removed MBM where inspection and certification verification systems can be demonstrated.

However, it is unlikely that this can be accomplished in the near term (i.e., within 1-2 years).

Risk Context

Canada's current feed ban has been demonstrated to curtail BSE amplification and spread. The enhancements to the existing feed ban will further reduce the risk of cross-contamination by removing all SRM from animal feed, pet food and fertilizer.

The combination of the existing restrictions and the new enhancement provides a double barrier against BSE exposure for ruminants, given that SRM-removed MBM cannot be fed to ruminants as it continues to be a prohibited material for ruminant feeding.

While domestic use and/or export of MBM produced in full compliance with the enhanced feed ban regulations would not in all likelihood lead to further spread and amplification of BSE should accidental feeding occur to ruminants, there may be credibility risks associated with the certification of this product for export. In the absence of OIE support to trade ruminant MBM, Canada is at risk of receiving international criticism for disregarding OIE recommendations. Consideration of export from Canada of SRM-removed ruminant MBM will require open demonstration of animal health responsibility and appropriate control of exports of SRM- removed ruminant MBM.

Import of Ruminant MBM

Ruminant MBM currently is prohibited for importation into Canada except from Category 1 countries (i.e., negligible BSE risk). An exemption from this prohibition may currently be considered on a case-by-case basis if it can be demonstrated that the materials used in the production of ruminant derived meat-and-bone meal or greaves, or any commodities containing such products have undergone a treatment or process to eliminate the BSE agent equivalent to that applied in Canada.

Considerations regarding SRM-removed Ruminant MBM

Once the enhanced feed ban comes into effect, all SRM will be required to be removed and contained or disposed of, which will effectively result in the removal of 99 percent of BSE risk material from ruminant MBM. CFIA will support the appropriate use (i.e., feeding to non-ruminants only) of SRM-removed ruminant MBM.

Key Policy Principles

1. The approach for export certification and domestic use of SRM-removed MBM will be outcome focussed and, therefore, will be based on evidence that the system in each establishment meets all new requirements for the segregation of SRM in accordance with the enhanced feed ban regulations.
2. In federally registered establishments, the current inspection program, including compliance verification and enforcement; will serve as the basis for both domestic use and export certification.
3. In provincially licensed establishments, the evidence demonstrating that the system meets the new requirements for the segregation of SRM will be consistent with the approach taken by individual provinces for oversight of abattoirs in their respective jurisdictions. This evidence, however, must provide sufficient confidence that the requirements have been met to fulfill the requirements of the importing country and be appropriately documented to allow the CFIA official signing the certificate to be satisfied that requirements have been met.

Domestic Policy for use of SRM-Removed Ruminant MBM (after July 12, 2007)

The CFIA will not "certify" this material. The inspection program for the enhanced feed ban is designed to demonstrate compliance at all levels of the industry.

In order to facilitate making this information public, the CFIA will consider publishing a list of permitted establishments (i.e., renderers and veterinary practices) and indicate what the permit allows them to do (this is a current practice under the Meat Inspection Act for meat establishments). Further consultation with industry will be needed in order to publish such a list.

Implementation

1. Abattoirs Supplying Inedible Bovine Material from which SRM is Segregated

   Federally Registered: MCAP tasks for SRM in federally registered abattoirs will be used to verify removal and control of SRM in those establishments. These establishments have inspectors present whenever the establishment slaughters animals. Documentation will be used to demonstrate that SRM and inedibles are properly segregated.

   Non-Federally Registered: In Canada, abattoirs from which product is limited to intra-provincial movement are not subject to federal registration. These plants account for 5% of red meat and poultry production in Canada. Inspection standards and frequencies in non-federally registered abattoirs vary from province to province. It is the responsibility of each province to develop and implement inspection programs for abattoirs under license by that province. Under the new regulatory program, CFIA has a responsibility to ensure that SRM is segregated in accordance with the requirements of the enhanced feed ban regulations. CFIA inspectors will ensure that the requirements of the new feed ban regulation are being met through audit. Provinces are encouraged to submit their inspection programs to the CFIA for review and approval to ensure that they are meeting the new regulatory requirements.

   Where SRM is removed from the premise, the establishment requires a permit to move the SRM to another location for destruction, containment or disposal. The enhanced feed ban regulations require the abattoir to maintain a record for each day that SRM is removed, stained or received or the carcasses are collected or received (for a period of 10 years). If a non-federally registered plant chooses to segregate SRM, then the records and documentation previously mentioned and the provincial oversight/inspection of the facilities will serve as the evidence of proper segregation. This information will be subject to CFIA audit as noted above.

   In order for CFIA to issue an export certificate for SRM-removed MBM which includes bovine inedibles collected from provincially licensed abattoirs, it will be necessary for the abattoirs to provide auditable evidence to demonstrate that segregation is being done in accordance with the new enhanced feed ban regulations, including documentation of the provincial oversight/inspection.

2. Renderers

   Renderers have been required to have permits since the implementation of the 1997 ruminant to ruminant feed ban regulations. In order for renderers to process and sell SRM-removed MBM, it will be their responsibility to ensure that they receive material only from abattoirs which have documented records demonstrating compliance with the new feed ban regulations.

   SRM processing activities in a dedicated/non-dedicated SRM rendering facility will be subject to inspection criteria outlined in the daily SRM checklist for rendering facilities. For dedicated facilities processing non-SRM ruminant MBM, a quarterly inspection will be required, however a higher frequency will be considered at the outset of the new regulations coming into effect on July 12, 2007. For non-dedicated facilities (i.e., those facilities processing both SRM-removed ruminant MBM and SRM material), inspectors must be present whenever the establishment is operating.

Export Policy for SRM-Removed Ruminant MBM

MBM produced prior to July 12, 2007: Currently, ruminant MBM is exported without CFIA certification to countries which have no import requirements for this product. These countries use MBM as a poultry feed supplement.

MBM produced after July 12, 2007: When the new regulations take effect on July 12, 2007, export certification of MBM will be required. For emerging markets, the exporter must demonstrate that they meet import requirements (where appropriate) of the country to which the product is exported. The CFIA will issue permits to establishments which demonstrate that they meet the requirements of the enhanced feed ban regulations. The issuance of a certificate will be based on the possession of a valid permit and demonstration that the import requirements have been met. This certification will be performed on a case-by-case basis depending on the importing requirements of the country. The label on the product must indicate that it will only be used to feed swine, fish and poultry.

The CFIA will not actively promote MBM as an export commodity until such time as the OIE has examined the risk posed by MBM derived from production systems from which all SRM has been excluded to determine if there is an opportunity to provide for safe trade of SRM-removed ruminant MBM. Once the OIE has concluded its considerations around the safe trade of SRM-removed ruminant MBM, CFIA's position may be revisited. In the interim, the CFIA will respond to countries expressing market needs for this product by issuing certificates once it has been demonstrated that the regulatory requirements of the enhanced feed ban and any importing country requirements have been met.