Adding feeds to feeds containing the same medicating ingredient - Record of Decision - Request for Review of Feed Inspection Policies and Procedures
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Area of Reference
Adding feeds to feeds containing the same medicating ingredient (also known as Like-Into-Like)
Compliance Verification System (CVS) Task(s)
January 11, 2010
Section 14 (b) of the Feeds Regulations requires that only approved ingredients are used in the manufacture of feeds and that medicated feeds contain the level of medication identified in the Compendium of Medicating Ingredient Brochures (CMIB) or on a veterinary prescription while Section 20 requires that a feed have the chemical composition to ensure it is efficacious for its intended use.
While the regulatory language supports a zero-tolerance for residues, the CFIA has always allowed for flexibility in production sequencing provided the impact on animal and public health are minimized as much as possible. This risk management strategy is internationally acceptable as it is generally recognized that thorough cleaning of feed manufacturing and distribution equipment following every batch of medicated feed is impractical. Flexibilities provided for production sequences should not be extended to allow for intentional contamination through addition of ingredients contaminated with medications to feeds that are not intended to contain that medication for the following reasons:
- Feeds containing low levels of medications (sub-therapeutic and residual level) can increase the prevalence of antibiotic-resistant bacteria that can negatively impact on public and animal health; the fact that we accept this risk when it is unavoidable does not mean we need to accept this risk for all situations
- Allowing feed manufacturers to use ingredients containing unintended medications to make feeds for food-producing animals is not an internationally accepted practice
- While there is recognition that zero-tolerance for drug residues is not practically possible, the fewer feeds that contain drug residues the better. Experts from the Canadian Food Inspection Agency (CFIA), Health Canada and the Public Health Agency of Canada are in agreement that using ingredients containing unintended medications to make feeds for food-producing animals (e.g., intentional contamination) is not acceptable for reasons of public and animal health.
- The inspection protocol will remain as it is and feed manufacturers will be assessed as non-compliant when they add feeds containing medications that are not identified on the label at an approved level.
Review Decision made by
CFIA Issue Resolution Working Group
December 17, 2009
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