Veterinary Prescription Feeds - Record of Decision - Request for Review of Feed Inspection Policies and Procedures

Excerpt from Task Standard Prior to January 11, 2010

• A copy of the veterinary prescription is in the possession of the manufacturer of the feed prior to the manufacture of the feed
• Copies of veterinary prescriptions and the formula for the manufacture of veterinary prescription feed, together with a list of each date on which the feed was manufactured are kept for a period of at least one year from the last date of manufacture of that feed

Analysis

Section 15 (1) of the Feeds Regulations requires that manufacturers of veterinary prescription feeds have a signed, written veterinary prescription in the manufacturer's possession during the manufacture of that feed.

Section 5 (g) (v) of the Feeds Regulations requires that a signed, written veterinary prescription is in the possession of the manufacturer prior to delivery of the feed.

It is our position that both sections of the regulations apply and the manufacturer is required to have the signed veterinary prescription in hand during the manufacturing process in its entirety (i.e., before manufacturing starts).  There was recognition, however, that there may be emergency situations which preclude the veterinarian getting a signed prescription to the feed mill before manufacturing starts. 

To accommodate bona fide emergency situations, the final 2 bullets of the verification task standards for Task 1107 have been revised as follows:

• A copy of the veterinary prescription is in the possession of the manufacturer of the feed prior to the manufacture of the feed except in the case of an emergency
  • Where an emergency existed that precludes following normal procedures, the veterinary prescription must be in the possession of the manufacturer of the feed prior to the delivery of the feed along with a brief written description of the emergency which is signed by the veterinarian who issued the prescription
• Copies of veterinary prescriptions (along with written description of emergency situation where applicable) and the formula for the manufacture of veterinary prescription feed, together with a list of each date on which the feed was manufactured are kept for a period of at least one year from the last date of manufacture of that feed

Decision

• Corrective Action Requests (CARs) related to this issue will remain in effect
• The facility must develop and implement effective corrective actions to prevent future occurrences of the non-compliance identified on the CAR

Review Decision made by

Canadian Food Inspection Agency (CFIA) Issue Resolution Working Group
December 17, 2009