Enhancements to Canada’s Ruminant Feed Ban P ermitting Under the New Regulatory Amendments

1. Enhancements to Canada’s Ruminant Feed Ban Permitting Under the New Regulatory Amendments Natalie Bragg , DVM, MSc Veterinary Program Specialist – BSE September 2006

2. Moving Forward Following Detection of BSE in May 2003 • International Panel recommendations: • Enhanced cattle identification • Increased surveillance testing for BSE • Complete removal and redirection of cattle SRM from entire human food chain • Complete removal and redirection of cattle SRM from animal feed chain

3. Enhancements - Intent • Further protect the health of Canada’s national cattle herd and accelerate the time to eradicate BSE in Canada • Strengthen current ban by addressing risks associated with the adulteration or cross-contamination of ruminant feeds with prohibited animal proteins during manufacture and distribution and use of feed on farm, by: • Removing SRM from feed, pet food and fertilizer supply chains; • Controlling SRM to prevent exposure to BSE from other pathways

4. Outcome Based Regulations • Regulations are outcome based • Demonstrate equivalence of alternative implementation systems • Responsibility rests with regulated parties • Removal or inactivation of BSE infectivity takes place at the top of the feed chain • CFIA will consider such alternative systems (e.g. destruction) where they can be scientifically supported as achieving the same level of protection as full SRM removal and are verifiable in practice

5. Enhancements - Implementation • Amendments will take effect on July 12, 2007 • announced on June 26, 2006; • published in the Canada Gazette, Part II on July 12, 2006 (SOR/2006-147) • provide affected industries and governments time to prepare for new measures • Delayed Implementation • the requirement to stain, segregate and identify SRM will not apply to establishments which are not required to be registered under the Meat Inspection Act until January 30, 2008

6. Enhancements – Scope of Authorities Amended • Amendments are being be made to: • Meat Inspection Regulations • Health of Animals Regulations • Feeds Regulations • Fertilizers Regulations • Consequently, enhancements will affect: • Products and production practices subject to these Regulations • Compliance and enforcement programs and activities that support each of these regulations. • Removal of SRM from animal feed, pet food and fertilizer chains • New permit system administered by CFIA will control the segregation and disposal or alternative use of SRM

7. Enhancements Health of Animals Regulations 6.21 (1) Every person who slaughters, cuts up or debones cattle for human consumption as food shall ensure that, immediately after removal of the specified risk material, the specified risk material is stained with a conspicuous and indelible dye and collected in a dedicated container that is marked with a statement in both official languages indicating that the contents are specified risk material. Does Not Apply in the case of: • Cattle that are slaughter, cut up or deboned on a farm or ranch, if the SRM from the carcasses of those cattle are not removed from the farm or ranch; • Cattle that are slaughtered, cut up or deboned at an abattoir if not parts of the carcass of any animal, other then those that are for human consumption as food, are removed from the premises of the abattoir; or • Samples of SRM or carcasses – or parts of carcasses of cattle which the SRM has not been removed, that are submitted to a level 2 containment labatory.

8. Enhancements Health of Animals Regulations 6.22 (1) Every person who removes the specified risk material from the carcasses of cattle that died or were condemned before they otherwise would have been slaughtered for human consumption as food shall ensure that the specified risk material is stained with a conspicuous and indelible dye and collected in a dedicated container that is marked with a statement in both official languages indicating that the contents are specified risk material. Does Not Apply in the case of: • The carcasses of cattle if the SRM from each of the carcasses and each of the carcasses that contains SRM are not removed from the premises on which the cattle were determined to be dead… • Samples of SRM or carcasses – or parts of carcasses of cattle which the SRM has not been removed, that are submitted to a level 2 containment labatory.

9. Enhancements Amendments will prohibit SRM from use in animal feed, pet food and Fertilizer chains Scope of SRM = complete list of SRM prohibited from food in July, 2003 (“full SRM feed ban”) • From cattle of all ages - distal ileum (portion of small intestine) • From cattle 30 Months and Older (OTM) - skull, brain, trigeminal ganglia, eyes, tonsils, spinal cord and dorsal root ganglia • Amendments apply to SRM removed from healthy slaughter cattle + cattle dead stock + condemned carcasses (whole carcass if SRM not removed)

10. Enhancements Amendments will control SRM from source to end points (disposal, destruction or alternative use) so that these tissues do not re-enter either the human or animal food chain. • CFIA permits will be required for the collection, conveyance, receipt, processing, use, export, containment or destruction of abattoir SRM and the carcasses of cattle that die or that are condemned before slaughter for human consumption by (for example): • Renderers • Dead stock collectors • Landfills • Incinerators • Permits will not be required for on-site disposal of SRM or dead stock

11. Volume • Annual aggregate of raw bovine waste (non-SRM and SRM) • 642 509 tonnes • Abattoirs: 92 % (589, 075 tonnes) • Dead Stock: 8 % (53, 434 tonnes) • 264 140 tonnes (up to 41 %) raw bovine waste collected and treated as though it were SRM • Dead stock: 8 % of cattle waste volume (53, 434 tonnes) • Provincial Abattoirs: 19 % of cattle waste volume (123, 484 tonnes) • Federal Abattoirs: 14 % of cattle waste volume (87, 222 tonnes)

12. Meat Inspection Program • CFIA staff presently oversee removal of SRM from human food products in federally-registered establishments • Once amendments take effect, will oversee: • segregation, identification and recordkeeping of SRM removed during slaughter/beef processing • identification and recordkeeping of SRM removed from or contained in carcasses of dead or condemned cattle carcasses at abattoirs

13. SRM Control or Destruction New methodology for control or destruction • Proposal overview submitted to CFIA • Initial review will determine if additional data would be required for submission or if methodology is unlikely to be deemed acceptable • Full submission • CFIA risk assessment • Negligible to very low = accepted method of SRM destruction • Assessment at higher levels necessitated risk management decisions

14. SRM Control or Destruction SRM may be • Destroyed • Method must have been approved by CFIA as “destruction” • Controlled • Permanent containment e.g. landfill • Intermediate treatment such as rendering or composting with controlled end use / destination under CFIA permit

15. SRM Destruction • Methods of destruction for SRM will include: • Methods of that have been assessed by CFIA science branch to present negligible to very low risk of transmission of BSE to domestic ruminants

16. SRM Destruction – Currently Acceptable Methods Incineration Gasification followed by Incineration Cement Kiln Alkaline Hydrolysis Thermal Hydrolysis

17. SRM Destruction Submit application to CFIA (Area TSE Disposal Program officer) • All relevant municipal and provincial licenses and inspection reports • Detail site plans • Normal operating procedures and QA pertaining to destruction of SRM • Results of recent analyses or verifications Inspection by CFIA staff (TSE Disposal Program officer plus engineer) • CFIA will verify facility operating parameters Permit to receive and destroy SRM may be issued by CFIA to the facility Permits for end products (e.g.. ash) not required

18. SRM Destruction Operating parameters assessed against those used in risk assessment. CFIA assessment / inspection will determine if variation from baseline parameters is major or minor. Minor variation • Permit may be issued • Major variation • Risk assessment required • Permit may be issued based on result of risk assessment

19. SRM Control Mass burial Land fill

20. Landfill Submit application to CFIA (Area TSE Disposal Program officer) • All relevant municipal and provincial licenses and inspection reports • Detail site plans • Normal operating procedures and QA pertaining to destruction of SRM • Results of recent analyses or verifications

21. Landfill Site Inspection Separation Signage Operation pertaining to SRM containment (manuals, trained personnel) Liner: • hydraulic conductivity is < 1 x 10-7 cm / s; Bottom slope > 2%; others > 0.5% Cap • Soil (60cm +) or geomembrane and soil / Saturated hydraulic conductivity is < 1 x 10-7 cm / s Groundwater protection • 500 mm below lowest point of liner (seasonal high) Surface water management Leachate control • Functions year round, Means of monitoring flow (to ensure no blockages), Adequate storage capacity, Access for inspection and monitoring Cover material availability Equipment • Dedicated or/ Clean of all organic material by pressure washing prior to alternate use Notification of integrity breeches Records (NB weights)

22. Mass Composting

23. Mass Composting Worst case assumption of “no reduction in infectivity” used in assessment • current lack of scientific data • results in mass composting being considered as an intermediate process for SRM, similar to rendering • Mass centralized facility vs on farm • permanent facility • containment parameters controlled and monitored • control over end use and exposure risk • end product remains SRM and must be disposed of under permit

24. Mass Composting • Mass composting facility must apply for permit to receive SRM • Must be accompanied by application or letter of intent to apply of final receiving site for the SRM • Final receiving sites must be • Non commercial use • Single site • not used for livestock

25. Mass Composting Site Inspection Separation Signage Operation pertaining to SRM containment (manuals, trained personnel) Site • Provincial requirements or suitable alternative Groundwater protection • Runoff collection system Surface water management Leachate control • Composting process formulated to prevent leachate formation Carbon material availability Equipment • Dedicated or/ Clean of all organic material by pressure washing prior to alternate use (exit) Notification of integrity breeches • Control of visitors Records (NB weights)

26. On- Premises Composting Provincial decision if mortalities remaining on premises can be composted • Must adhere to provincial environmental, agriculture and public health guidelines If composting undertaken, CFIA recommends • end product is not used on land directly grazed by ruminants Permits would be required if end product left premises, as it is still considered to be SRM

27. H of A and Feed Regs still permit • Salvage for uses including feed • Under permit - bovine tissues proteins other than SRM • non bovine ruminant deadstock • Prohibited material can be fed to non ruminants e.g.. pet food / zoo animals

28. Salvage • Submit application to CFIA • Detailed description of: • Tissues to be salvaged • Intended end use • Site where salvaging to take place • Procedures • Plan for SRM disposal • No further CFIA controls on salvaged non-SRM tissues

29. Salvage Site Inspection Separation • Prevent contamination of salvaged nonSRM tissues with SRM including: • Penetrating head wounds in OTM cattle • Spinal column separation in OTM during salvage (e.g.. hide stripping) • Severing of the distal ileum • Risks / appropriate procedures site specific Operating procedures • Accidental contamination Cleaning • Prevention of SRM contamination SRM disposal OTM / UTM – verification • Procedures • Staff training Records (NB weights)

30. Transportation • Except in accordance with a permit no person shall… remove from any premises, convey (other than from one area to another on the same premises),

31. Conveyance Site Inspection Conveyance • structure in which SRM is contained for transport • Trucks, containers, buckets, tarps Designed and operated to prevent contamination of animals, animal feed and / or food with SRM • dedication; OR • segregation and containment to address specific risks • E.g. whole deadstock – dividers, compartmentalize vehicle • Raw SRM / Offal – leak proof containers Cleaning • non dedicated containers must be cleaned by pressure washing • + disinfection (Bleach, NaOH if going to be used for animals, animal products, animal feeds, food)

32. Conveyance Site Inspection Staining Labelling of conveyance • License plate for trailers • Permit # on conveyance Records (NB daily weights or numbers of carcasses)

33. H of A Regs – Staining SRM • All SRM / bovine deadstock (with SRM) must be stained • Stripe down head and spine • Conspicuous = contrasting with coat colour • SRM-MBM must be stained

34. Permit Exemptions – on premises • SRM and bovine deadstock that do not leave premises • Provincial / municipal requirements apply

35. Mobile Abattoirs / On Farm SlaughterCut Up / Wrap Off Premises On farm slaughter exempt from permit if all SRM remains on premises Partial OTM carcass containing SRM sent off premise for cutting • Will need permit • Compartmentalization during transport may be done using waterproof tarp

36. Records • Every person who is required to remove or stain SRM; or who receives SRM shall keep records (10 year retention) • Person’s name, address and the date of the removal, staining or collection or reception; • Combined weight of the SRM, as well as the number of carcasses • Numbers of approved tags • If the person treated, confined or destroyed the SRM, the date and manner of destruction • If the person did not confine or destroy • Name and address of the person who • received, • transferred • destroyed or confined

37. Permit Application

38. Compliance and Enforcement • Conduct new inspection activities and verify compliance with the permit conditions at various types of establishments including: • Meat slaughter and processing establishments where SRM are removed • Collectors of ruminant dead stock • Conveyances and enterprises that operate conveyances used to transport SRM, dead stock, processed animals proteins, other feed ingredients and prepared feeds • Receivers of SRM and dead stock for pre-treatment, disposal or any other alternatives use • Quarterly; for renders joint inspection with feeds at 2 inspections • CFIA will continue and expand inspection activities for feeds and fertilizers under the Health of Animals Regulations, Feeds Regulations, and Fertilizers Regulations • Feeds will review these during their inspection

39. Additional Information • Additional information regarding BSE and the proposed enhanced feed ban is available at the CFIA website: • www.inspection.gc.ca • Contact: Dr. Natalie Bragg, D.V.M., M.Sc. braggn@inspection.gc.ca Tel: (780) 495-3957 cell: (780) 499-8284 Fax: (780) 495-7022