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Regulatory authorities related to application of Table 4 to veterinary prescription feeds

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Summary of Memorandum

The memorandum below provides clarity on the relationship between medicated feeds, Table 4Footnote 1 of the Feeds Regulations and exemption from registration.

A medicated feed may be exempt from registration if it is made according to the CMIBFootnote 2 and it meets the requirements in Table 4. Medicated feeds that are not made according to the CMIB require a veterinary prescriptionFootnote 3 and are exempt from registration regardless of whether they meet Table 4 requirements.

It is recognized that some provinces require veterinary prescriptions prior to the sale of all medicated feeds. In situations where a veterinary prescription is written for a medicated feed made in accordance with the CMIB, the feed must meet Table 4 requirements in order to be exempt from registration. The provincial requirement does not affect the necessity for feeds made according to the CMIB to also meet Table 4 requirements.

Question/Issue

Multiple inspectors have requested clarification on whether feeds manufactured under a veterinary prescription are required to meet Table 4 guarantees for nutrients or not.

Background

Section 5(2) of the Feeds Regulations lists feeds that are not required to be registered. The subsections within this section, specifically subsections 2 (c), (d), (e) and (g), describe several types of feed and the parameters that each feed must meet. To provide a response to the question it must be determined if the requirements are additive in this section. In other words, in addition to the requirements for a veterinary prescription identified in Section 5(2)(g) does that feed also need to meet the parameters for a complete feed in Section 5(2)(d) and thus is it required to meet Table 4 nutrient guarantees?

Program Response

The requirements set out in section 5 subsections 2 (d), (e) and (g) are not additive so they must be read separately. The subsections relative to complete feeds and consultant formula feeds expressly indicate that Table 4 nutrient guarantees must be met, while the subsection specific to veterinary prescription feed is silent in this regard. As such, a veterinary prescription feed does not need to meet Table 4 nutrient guarantees.

Important Notes:

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