Canadian Food Inspection Agency Policy:
Permits for Landfill Sites Receiving Specified Risk Material
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Specified risk material (SRM) refers to cattle tissues that potentially contain bovine spongiform encephalopathy (BSE) infectivity. The Canadian Food Inspection Agency (CFIA) can minimize the risk associated with SRM to the environment, domestic and wild animals, and Canadians, in general, by regulating, through the issuance of permits, the burial of SRM. It is necessary for individuals or businesses wishing to receive SRM for burial to meet the specific operational and site requirements to ensure its safe handling and confinement.
General Landfill Site Requirements
The best handling practices for SRM have been established through scientific assessments to ensure safety and confinement. The practices include establishing adequate signage, fencing, and specific operating procedures, as well as reporting integrity breaches and retaining detailed records.
Adequate signage installed at all access points around the perimeter, consisting of information on ownership, nature of operation, hours of operation, accepted types of fill and emergency contact information, is necessary. The use of fencing or other barriers to separate the landfill site from adjacent properties should prevent domestic ruminants and wildlife, including wild ruminants, scavengers, and birds from gaining access to SRM and raw leachate.
Daily cover material should be available, with all SRM covered before the end of the shift during which it is delivered. The nature and depth of coverage must be adequate enough to deter scavengers.
Personnel who receive and handle the SRM must be trained in standard SRM confinement operating procedures and have easy access to the on-site landfill's operating procedure manuals. The equipment that handles SRM can either be designated for SRM handling only or must be cleaned on-site by pressure washing to ensure that all organic material is removed from the interior and exterior surfaces prior to alternative use. All organic material greater than 4 mm in size in wash water must be confined within the SRM area or directed to the leachate containment system.
All breaches in the integrity of confinement, including access by scavengers, domestic or wild ruminants, leachate escape, or movement of SRM or landfill contents out of the area previously approved by permit, must be reported to the CFIA. Detailed monitoring logs (including, but not limited to, well logs, leachate treatment records, gas management records, stormwater management records, and disposal records) must be kept on-site for a period of 10 years. The detailed records may be instrumental in assessing future disease occurrences in animals or for public heath concerns.
Specific details for the records are as follows:
A record must be kept for each day on which SRM is removed, stained, or received, or when carcasses are collected or received. Records must include the following:
- name and address of the person transporting SRM to the landfill site;
- date received;
- combined weight of the SRM and carcasses or parts of carcasses received;
- date of landfill (if different from reception);
- location of SRM within the landfill site (applicable to large landfills), as identified by methods such as surveying, GPS; and
- if applicable, numbers of approved tags on the carcasses or, in the case of carcasses not bearing approved tags, name and address of the owner, or farm or other place from which the carcass was removed.
Limits to Amount of Material a Site Receives
Scientific risk assessments have been done to establish limits regarding the total volume of slaughter waste and deadstock that can be confined safely, depending on the specific parameters of a site. Specific technical requirements must be met to ensure the protection of the surrounding environment, including the region's surface and groundwater supply. The CFIA recognizes three basic types of disposal sites: 1) engineered landfill, 2) natural landfill, and 3) non-contiguous burial. A non-contiguous burial site refers to a producer or small business owner who wishes to bury a limited quantity of SRM that has been generated on-site, on a premises that they own, but not contiguous with the farm or premises of origin of the SRM.
- Sites meeting the requirements for an engineered landfill have no limits imposed by the CFIA with respect to the volume of SRM or the deadstock containing SRM that they may receive. (Refer to Technical Requirements for an Engineered Landfill Site Permit: Specified Risk Material Confinement.)
- The CFIA limits those sites meeting the requirements for a natural landfill to receive a maximum of 4000 tonnes/year of slaughter waste and deadstock, of which a maximum of 2000 tonnes/year may originate from over-30-month-old (OTM) cattle. (Refer to Technical Requirements for a Natural Landfill Site Permit: Specified Risk Material Confinement.)
- It is permissible to have a specific cell within a landfill designated for SRM, in which case, specific requirements would apply, rather than to the entire landfill.
- Sites meeting the requirements for non-contiguous burial are limited by the CFIA to receive not over 350 kg of material per week (equivalent to SRM from seven mature bovine carcasses) or 18,200 kg of material per year (equivalent to approximately 30 mature bovine carcasses or SRM only from 360 mature carcasses). (Refer to Technical Requirements for a Non-Contiguous Burial Site Permit: Specified Risk Material Confinement.)
Individuals or businesses may contact the local district CFIA Animal Health Office for a permit application Form CFIA/ACIA 5405 - Application for Permit to Remove, Use, Convey, Treat, Store, Sell, Distribute, Confine, or Destroy Specified Risk Material (SRM) under the Health of Animals Act.
Include the following documents with the submission to the local district CFIA Animal Health Office:
- completed form CFIA/ACIA 5405;
- all relevant municipal and provincial licences and inspection reports;
- detailed site plans, including (where applicable) scale, north indication, relevant elevations, location of entrances, buildings, roads, fences, stormwater ditches, surface runoff drainage systems, leachate containment system, leachate treatment system, retention ponds, measuring wells, manholes, an indication of where within the landfill the SRM will be deposited;
- standard operating procedures and any additional proposed procedures, and quality assurance programs pertaining to the confinement of SRM for landfills; and
- results of any recent analyses or verifications relevant to SRM confinement.
Upon receipt and review of the completed application for permit, the operator of the landfill site or owner will be contacted and an inspection visit scheduled.
Subsequent to completing the landfill site inspection, the owner of the site will receive an inspection report. Any deficiencies will be outlined in the summary. The deficiencies should be addressed by preparing and submitting a corrective action plan to the CFIA district office. Implementation and effectiveness of this plan will be verified by an on-site follow-up inspection prior to issuing a permit.
Permit Issuance and Compliance Monitoring
For landfill sites that meet all the requirements, a Form CFIA/ACIA 5406 – SRM Permit to confine SRM under the Health of Animals Act will be issued. The original copy of the permit will be forwarded to the applicant. Permits will be renewed annually, provided there is ongoing compliance with the standard operating procedures of the site. CFIA inspectors conduct compliance monitoring via random quarterly inspections. Provincial or municipal inspections may take the place of CFIA compliance inspections.
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