Importation of Integumentary Tissue

TAHD-DSAT-IE-2001-1-2
January 8, 2013

Amendments: This policy replaces all previous policies on this subject.

Industry notice: Clarification about importing hunting trophies

Introduction

This policy deals with the importation of integumentary tissues of mammals and avian species. The importation of integumentary tissues from reptiles and amphibians is not regulated by the Canadian Food Inspection Agency (CFIA).

This policy relates to Animal Import/Export Division import requirements only and does not remove any obligations from the Canadian importer to comply with the import requirements of other CFIA programs and/or other federal, provincial, or municipal government departments. Integumentary tissues imported as pet chews and treats are regulated under the CFIA's Animal Health Import Requirements for Rendered and Inedible Products and the directive, Import of Pet Food, Treats and Chews Containing Animal Products and By-Products.

The importation of many commodities in this policy requires approval from the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The Canadian Wildlife Service of Environment Canada implements and administers CITES for the federal government of Canada. Importers are therefore strongly encouraged to contact CITES prior to importation to ensure that trade in each commodity is permitted.

Hides and skins are commonly traded as wet salted (also termed "green salted hides"), dry salted, pickled, air dried, or in the blue (or wet blue). Several of these preparation procedures may decrease the pathogen load on hides and skins, but do not necessarily eliminate all microorganisms. In the past, there has been much confusion about how to handle these imported tissues. Certificates of disinfection produced in many foreign countries have been shown to be widely fraudulent. As a result, a system of post-arrival disinfection has been created for the handling of these items when they are not clean or when they originate from non-designated countries.

Trophies containing skulls and horns originating from mature animals of the Bos taurus or Bos indicus species are considered specified risk material, if the originating country is of controlled or undetermined risk for bovine spongiform encephalopathy (BSE), as defined by the World Organisation for Animal Health (WOAH; founded as Office International des Épizooties (OIE)). For this reason, trophies originating from these countries from animals of these species require an import permit for import into Canada.

Appendix 1 provides the Guidelines for Approval of Disinfection Premises for Hides, Skins, and Trophies Imported Into Canada.

Regulatory authority

The Regulations regarding the importation of integumentary tissues are found in section 42 of Part IV of the Health of Animals Regulations. Other sections of Part IV, notably sections 40 and 41, also relate to the importation of integumentary tissues, among other animal by-products, as well as Part XIII, section 160.

The Health of Animals Regulations, section 42, states the following:

Raw Wool, Hair or Bristles, Hide or Skin

A person may import into Canada raw wool, hair or bristles or an untanned hide or skin from a country or a part of a country not referred to in section 41 if

1. the article is transported under seal of an inspector directly from the place of entry to an approved disinfection establishment for disinfection in accordance with these Regulations; or
2. in the case of an untanned hide or skin, an inspector is satisfied that the article
   1. is a hard dried hide or skin of an animal,
   2. has been pickled in a solution of salt containing mineral acid and was packed in a leakproof container while still wet with such solution; or
   3. is the hide or skin of an animal and has been treated with lime so as to become de-haired.

Glossary

Bristles (Soies): Stiff hairs commonly found in pigs, often used to make brooms and brushes.

CFIA Seal (Sceau de l'ACIA): A CFIA control tool used in containers and conveyances to prevent deliberate or accidental opening of a conveyance that is used for the international transport of animals, or animal products and by-products during the transportation period. A seal includes any tamper-evident means of securing a shipment, including lead seals or other tamper-evident materials, but does not include tape, either plastic or adhesive.

Designated country or zone (Zone ou pays désigné): A country or zone determined by the CFIA to be free of reportable and immediately notifiable diseases that either affect or are transmitted by the species of origin of the animal, animal product, or by-product to be imported into Canada.

Dry (or green) salted hides or skins (Cuirs ou peaux séchés [ou verts] salés): Skins that have been rubbed on the flesh surface with dry salt and left to dry. At the end of the process, the hides and skins are shaken of the salt and folded for consignment.

Feathers (Plumes): Unique to birds, feathers form the distinctive component structure of the outer covering and flight surfaces of all modern birds.

Fully mounted taxidermy specimens, including trophies, teeth, skulls, horns, and antler chandeliers (Animaux entièrement empaillées, y compris les trophées, les dents, les crânes, les cornes et les lustres faits de bois de cervidé): A hunting trophy is an item prepared from the body of a game animal killed by a hunter and kept as a souvenir of the successful hunting or fishing expedition. Often, the heads or entire bodies are processed by a taxidermist, although sometimes other body parts, such as teeth, tusks, or antlers, are prepared as a trophy. Polyurethane or plastic mannequins are used to support the skins and horns of the hunted animals. The skins are fully prepared before placement in the mannequin for completion of taxidermy procedures.

Hard dried skins (Peaux séchées dures): Skins that have been air-dried.

Integumentary tissues (Tissus tégumentaires): A network of features that forms the covering of an organism. The integument delimits the body of the organism, separating it from the environment and protecting it from foreign matter. At the same time, it provides communication with the outside, enabling an organism to live in a particular environment.

Leak-proof containers (Containers étanches): For the purposes of this directive, defined as fully enclosed sealable shipping containers made of impervious materials (hard plastic or metal, never wood) and lined with a plastic liner of at least 6-mm thickness to prevent leakage. Plastic liners are available from various Canadian suppliers, including, but not limited to, the following:

• DuPont: aseptic bulk bags
• Mercury Plastics

Shipments with leaking contents, or that are not in a fully enclosed sealable metal shipping container, are refused entry and returned to the country of origin. For feathers or wool, a plastic liner should be used, but some leniency may be possible, as long as there is no leakage or spillage of the contents.

Liming (Chaulage): A procedure that results in the "un-hairing" of hides and skins by applying a strong alkaline solution to the skin.

Non-designated countries or zones (Zones ou pays non désignés): Countries or zones not determined by the CFIA to be free of reportable or immediately notifiable diseases that either affect or are transmitted by the species of origin of the animal, animal product or by-product to be imported into Canada.

Pickled skins (brining) (Peaux picklées [saumurage]): An acid bath treatment in which skins are prepared for tanning. This is an ideal method for treatment of skins for international transportation.

Specified risk material (SRM) (Matière à risque spécifiée [MRS]):The skull, brain, trigeminal ganglia, eyes, tonsils, spinal cord, and dorsal root ganglia of cattle aged 30 months or older, and the distal ileum of cattle of all ages from cattle originating in countries classified by the WOAH as being of undetermined or controlled risk for BSE.

Tanning (Tannage): A preservation process, usually a chemical treatment, which converts the otherwise perishable skin to a stable and non-decaying material.

Trophies (Trophées):Comprises the head, antlers (with or without skins), or other body parts of animals that will be preserved for display by taxidermy.

Wet blue hides (Cuirs bleus humides): Usually, the phrase "in the blue" or wet blue is applied to hides or skins that have been chrome-tanned.

Wet green hides (Cuirs verts humides): Hides that have been submitted to a process of green salting or wet salting. Wet green hides contain approximately 50% of the original weight of the green hide and are considered to be cured and ready to be shipped.

Wet-salting (see wet green hides) (Salage humide [voir cuirs verts humides]): A method of curing hides and skins for storage and/or transportation. After salting, the hides are left in a pile. When ready for shipment they are "taken up," the salt is knocked off, and the hides are then bundled and tied (also "wet green salting").

Wool (Laine): The fibre that grows on the body of most sheep. It replenishes itself each time the sheep is sheared and continues to grow throughout the sheep's lifetime. Wool is the product for which sheep are best known. Wool is widely used in clothing, from knitwear such as socks and sweaters to cloth used for suits and costumes.

Some commonly used wool terms:

• Carbonizing (Carbonisage):Removing vegetable matter (e.g. burrs, seeds, straw) from wool by immersion in dilute sulphuric acid.
• Carded wool (Laine cardée): Wool that has undergone the carding process and been put through two procedures that remove short fibres and place the longer fibres parallel to each other.
• Fleece (Toison): The wool from a single sheep in the shorn-grease state.
• Grease wool or raw wool (Laine en suint ou brute): Wool that is shorn from the sheep before any processing or cleaning has taken place.
• Scouring (Dessuintage): The actual separation of dirt, grease, and foreign matter from grease wool.

Animal disease agents of concern

Hides, skins, stuffed animals, trophies, wool, and feathers are known to transmit serious animal diseases, such as the following:

Bovines (Bovins): Foot-and-mouth disease, lumpy skin disease, anthrax.

Sheep (Moutons): Foot-and-mouth disease, sheep and goat pox, peste des petits ruminants, anthrax.

Goats (Chèvres): Foot-and-mouth disease, sheep and goat pox, peste des petits ruminants, anthrax.

Swine (Porcs): Classical swine fever, African swine fever, foot-and-mouth disease, swine vesicular disease, anthrax.

Avian (Oiseaux): Newcastle disease, highly pathogenic avian influenza.

Equine (Équins): Glanders, anthrax.

Rabbits (Lapins): Rabbit haemorrhagic disease

Procedures for importation of integumentary tissues

1. Inspection at the port-of-landing

There are no restrictions on products imported from the U.S., and these will be released by the Canada Border Services Agency (CBSA). For products from countries other than the U.S., all commodities must be inspected at the first port of importation. Regardless of the species of animal or type of material imported, if on first inspection any specimen is found dirty or contaminated with blood, soil, vegetable material, straw, hay, or manure, the item is refused entry and not allowed into Canada under any circumstances.

2. Entry without CFIA requirements (all countries, no inspection required)

The following products are not regulated under the Health of Animals Regulations:

• fully tanned leather and leather products
• fully dressed furs and fur products
• skins of wool and knitted wool products
• souvenir items made from washed and dyed feathers
• feather fishing lures, etc.
• professionally mounted fish and reptiles

3. Entry without certification or disinfection (all countries except the U.S., CFIA inspection required)

The following items may be released subsequent to visual inspection. They must be free from all feces, blood, dirt, and ectoparasites to qualify for exemption from further restrictions. Items that are found to be soiled, as above, are to be refused entry and either destroyed or returned to the country of origin. Alternatively, they may be directed to an approved premises for disinfection (refer to Item 7):

• fully tanned hides and skins, including wet blue hides (or in the blue hides)
• professionally prepared taxidermy mounted animals, birds, trophies, and museum specimens in display form^Footnote 1
• professionally prepared horns and hooves in display form
• bongo drums with skins included, and processed hard-dried skins ready for use as drums, and similar uses
• wool, feathers, and down that have been washed and are scrupulously clean on inspection

4. Entry with proof of origin (unprocessed items originating in the U.S.)

The following items are released with documentation, stating U.S. origin acceptable to the CBSA:

• untanned hides and skins
• animal and bird carcasses and trophies that are not prepared and are not mounted and that will be used for taxidermy
• hoofs and horns that have not been processed
• museum specimens that have not been processed;
• wool, feathers, and down that have not been processed
• furs that have not been dressed

Also included in this category are trophies consisting of the whole (or part of the) skull from animals aged 30 months or older of the species Bos taurus and Bos indicus –namely, Highland Cattle and Texas Longhorns, or a mix thereof – from the U.S., with the following conditions (as the U.S. is considered to be of controlled risk for BSE by the WOAH ):

1. An import permit is required. The importer must obtain the permit prior to the arrival of the products in Canada and present the original at the time of importation. The facility where the trophy will be cleaned and disinfected and further processed must be indicated in the permit, and must be a facility approved by the CFIA to handle such materials.
2. A SRM transport permit and (if the importer is also the taxidermist who will process the specimen) salvage or storage permits are required. The original copy of the import permit must be presented to the CFIA inspector at the time of the importation. The transport and/or salvage and storage permits must be addendums to the import permit. The importer is required to contact the district office where the final destination of the trophies is located to request a permit at least two weeks prior to the arrival of the skulls in Canada.

More detailed information on SRM permits may be found at: SRM Permits and Enhanced Animal Health Protection From BSE.

For the importation of trophies comprising the whole (or part of the) skull from animals aged 30 months or older of the species Bos taurus and Bos indicus –namely, Highland Cattle and Texas Longhorns, or a mix thereof – from all other countries, a case-by-case evaluation is required.

5. Entry with certification (wool, feathers, and un-tanned hides and skins, originating in countries or zones designated by the CFIA as free of important diseases for the species from which the product is derived, released by the National Import Service Center with appropriate certification)

The items mentioned above may be released with appropriate certification if they originate in a country or zone designated by Canada as free of diseases in the animals (see, animal health status by country) from which the product is derived.

An official veterinary certificate is required that fully describes the products, stating that they originate in that country or that they were legally imported into that country.

6. Post-entry disinfection (unprocessed products, originating in countries not designated by the CFIA as free of serious diseases affecting the species from which they originate)

The following items must be directed to pre-approved premises for disinfection after arrival. A copy of the premises approval must be provided by the importer to the CFIA at the time of importation. The premises approval must have been carried out not more than 24 months prior to the importation. If no premises has been approved, the items may be retained for a maximum of 30 days awaiting premises approval. If no premises approval has been obtained in 30 days, the items are to be refused entry and either destroyed or returned to the country of origin at the importer's expense:

• untanned hides and skins
• trophies and trophy material that have not been prepared or mounted
• animal carcasses for taxidermy (not including fish and reptiles)
• animal bones, skulls, and skeletons
• museum specimens that have not been processed or mounted
• rabbit furs
• raw wool
• unprocessed feathers and down

These items must be transported in sealed leak-proof containers from the port-of-landing directly to the pre-approved disinfection premises.

7. Returns of integumentary tissues

For cases in which exported Canadian hides, skins, and integumentary tissues are refused entry into an importing country, these products may be returned to Canada in accordance with the policy, Returns and Permit Application Process for Canadian Animals, Semen, Embryos, Animal Products, Animal By-Products and Finished Pet Food. For permanent return, importers are required to complete Form CFIA/ACIA 5609 – Canadian Animal, Semen, Embryos or Products/By-Products Returning, and submit it to the CFIA Area import specialist. An import permit is not required for the permanent return of integumentary tissues; returning containers of integumentary tissues will be handled according to this policy. That is, if the return is from a designated country, the container may be imported with certification only. Conversely, if it is returning from a non-designated country, it will be sent to an approved facility for cleaning and disinfection in accordance with the procedures outlined in Appendix 1.

However, in cases where the exporter or importer wishes to return the products for re-export, a Terrestrial Animal Health Import Permit is required. The exporter or importer must apply for this import permit prior to the arrival of the container in Canada. The importer contacts the CFIA to arrange for the container to be sealed by the CBSA or the CFIA upon arrival at the first port of entry, followed by inspection and certification for re-export by the CFIA. This option is only available in cases where the exporter or importer already has a market for the materials and where the inspection at the port of entry yields favourable results. Exporters or importers wishing to avail themselves of this option must re-export the shipment from Canada within 15 days of its arrival. Otherwise, the products will be ordered removed from Canada, ordered destroyed, or sent for disinfection at an approved facility, at the cost of the exporter or importer.

If the inspection reveals irregularities with certification, seals, documentation, or with the shipment per se, the container will be ordered removed from Canada, ordered destroyed, or sealed and sent to an approved disinfection facility at the expense of the exporter or importer.

Guidelines for approval of disinfection premises

All disinfection premises are to be approved in advance of shipment arrival for disinfection. The premises must be visited by a CFIA inspector and a report must be prepared, which includes a diagram of the proposed disinfection facility. Photographs may be taken to enhance the report. Forward this report to the regional import specialist for final approval, and retain on file at the district office and Area office. Approvals must be renewed every 24 months. A renewal necessitates a visit by a CFIA inspector.

Post-entry disinfection (for unprocessed products originating in various countries)

Many unprocessed items entering Canada from non-designated countries require cleaning and disinfection. At the time of import, the premises where the imported material will be disinfected must be listed in a database of approved facilities, and thus available to the CFIA inspector for the material in question to proceed for cleaning and disinfection. The premises approval must have been carried out within the 24 months prior to the importation. If there have been no prior arrangements for a facility to carry out the cleaning and disinfection of the imported materials, the items may be retained for a maximum of 30 days, awaiting premises approval. On the 31^st day after importation, the item is refused entry and either destroyed or returned to the country of origin at the importer's expense.

Unprocessed items must be transported in leak-proof containers, bearing a CFIA seal. All items must proceed directly from the port-of-landing to the pre-approved disinfection premises.

Appendix I: Guidelines for approval of disinfection premises for hides, skins, and trophies imported into Canada

All disinfection premises must be approved prior to the arrival of shipments for disinfection. Approvals are valid for 24 months and are renewed only with a full visit and records' inspection.

1. The following criteria must be met for approval of the disinfection facility

A. Exposure of animals to imported material

The inspector must be satisfied that the method of containment prevents any possible contact between livestock, wildlife, or the public with (presumed contaminated) imported material being stored or processed. Imported materials may be contained in a cooler, a freezer, or a room containing drums or boxes of materials awaiting taxidermy. The refrigerator, the freezer, or the room must be lockable, and the inspector must be satisfied that the locking method used is in proper working order and is effective in creating a barrier between livestock and other animals and the materials in question.

B. Pest control

1. Approval is not permitted if dogs or cats (including guard dogs) can enter the areas where imported material is kept and disinfected. (No exceptions for this point.)
2. A pest control program should be demonstrated to the satisfaction of the inspector (logs of baiting activities or trap cleaning, invoices for purchase of traps or for regular purchase of exterminator services, or any other demonstration that satisfies the inspector). Note that felines are not allowed for use as rodent control in the areas where imported materials are kept and disinfected.
3. All containers must be kept under tight-fitting lids (to the satisfaction of the inspector) to prevent birds or other predators from carrying away any of the materials slated for disinfection. If the inspector deems a need for lockable lids for the containers where the product is stored, locks must be in place.

C. Personal protective equipment

Operators must demonstrate to the CFIA inspector that, if protective clothing and equipment is used during the handling and disinfection of imported materials, personal protective equipment (PPE) is used and disinfected properly or disposed of (in the case of disposable materials) in accordance with an approved CFIA plan.

For example, the disposal of rubber gloves, rubber boots, face masks, and Tyvek coveralls should be discussed with the CFIA. Options for disinfection are as follows:

• organic material removed from PPE, placed with all other effluent and disposed of with other organic materials (e.g. trimmings from fleshing);
• after removal of organic material, use of a disinfectant (4% sodium carbonate; Virkon) bath for a minimum contact time of 1 hour, and then regular laundering procedures; or
• acceptable cleaning procedures for rubber boots, gloves, and goggles – after removing organic material, soak in Virkon or 4% sodium carbonate for a minimum contact time of 1 hour.

For disposal purposes after following these disinfection procedures, PPE may be disposed of in accordance with municipal disposal procedures (garbage curb pickup or landfill).

For clothing, laundering with soap and hot water ensures that pathogenic organisms are destroyed.

D. Transport containers

The facility must make the shipping conveyances (i.e. leak-proof containers) and the shipping records available to the CFIA inspector for inspection. Imported specimens slated for disinfection are transported in fully enclosed sealable shipping containers lined with a plastic liner of sufficient thickness to prevent leakage. (See definition of leak-proof container.)

Shipments with leaking contents or not in fully enclosed sealable shipping containers are refused entry and returned to the country of origin.

Transport containers are sealed by CFIA inspectors at the point of entry and Form CFIA/ACIA 4206 must be issued, indicating the container number, the seal number, a description of the contents, the destination, and the method of transportation.

Under no circumstances are containers to proceed inland, unless they are sealed and the appropriate forms are completed. The facility operator may break seals on the transport containers, or may request that the container be opened by a CFIA inspector, if the inspector is already present in the facility for any reason. All seals opened by the operator must be stored and presented to the district veterinarian at the time of facility re-approval. Once all imported materials are removed from a fully enclosed sealable container, the plastic liners must be disposed of according to a CFIA-approved disposal plan. The disinfection of the shipping container must also be discussed with the district veterinarian, and the CFIA inspector must approve a method of disinfection.

2. Disinfection procedures

The following procedures are accepted for the cleaning and disinfection of imported integumentary tissues. However, operators may present other methods of cleaning and disinfection of integumentary tissues to the district veterinarian who is in charge of the facility's approval. The district veterinarian submits the request to CFIA Headquarters for evaluation and possibly risk assessment. Once approval is granted, the operator may use the alternative methodology.

These procedures must be used for each type of imported material specified.

A. Procedures for cleaning and disinfection of raw hides and skins

1. To inactivate viruses present in raw hide and skins for industrialized use, undertake salting for at least 28 days in sea salt containing 2% sodium carbonate.
2. In the presence of high concentration of organic material, use sodium carbonate – washing soda (Na₂CO₃) crystals, 100 g/L, with a minimum contact time of 10 minutes.
3. Pickling of skins – Pickling is a preparatory method for tanning, and it works well to break down some proteins in the skin to facilitate the uptake of tannins at the time of tanning of the hide. The desired pH is 2.0 for a minimum of 48 hours. Oxalic, sulphuric, and citric acid may be used. Skins are prepared by immersion in an alkaline solution, followed by the acid immersion. Pickling preserves skins for long periods of time, and hides may be transported wet and pickled.
4. For disinfection using tanning chemicals (recommended for green salted hides), undertake soaking in one or more of the following acid solutions: formic acid, acetic acid, or sulphuric acid. The solution must have a pH below 3.0 and be maintained for a period of at least 48 hours.
5. This will be effective in destroying all pathogenic agents. Agitate the materials being disinfected every 2 hours for about 10 minutes. At least once every 12 hours, check the pH, which should not be allowed to rise above pH 3.0.
6. Gamma irradiation – 40 kiloGray (kGy) at 15 degrees Celsius – is ideal for materials that are suspected of being contaminated with anthrax.
7. For a country of origin that is free of foot-and-mouth disease, but in which an active outbreak of anthrax has been declared, the following disinfection methods are acceptable:
   • Fumigation with formaldehyde: 400 mg/m³, at 30% relative humidity and >15°C, for a minimum of 4 hours. This method is recommended by the WOAH; however, provincial and municipal bylaws may prohibit the use of fumigation with formaldehyde, due to emissions that are harmful to the environment. Before a facility is approved to use this methodology, the operator must prove to the district veterinarian that the Ministry of Environment approves the use of such methodology.
   • Fumigation with ethylene oxide: 570 g/m³ at 20-40% relative humidity and 55°C for 160 minutes. This method is recommended by the WOAH; however, provincial and municipal bylaws may prohibit the use of ethylene oxide due to emissions that are harmful to the environment. Before a facility is approved to use this methodology, the operator must prove to the district veterinarian that the Ministry of Environment approves the use of such methodology.

B. Procedures for cleaning and disinfection of wool and hair

For the inactivation of viruses present in wool and hair for industrial use, use one of the following procedures:

1. Use sodium carbonate anhydrous or washing soda (Na₂CO₃) powder, 40 g/L, 4% (weight/volume) for a minimum contact time of 10 minutes.
2. Sodium carbonate or washing soda (Na₂CO₃) crystals, 100 g/L, is recommended for use in the presence of high concentrations of organic material. The minimum contact time is 10 minutes.
3. For unhairing prior to tanning, lime at a pH 12.6-13.2 is sufficient to inactivate most pathogens. This method is also recommended for wool where contamination with anthrax spores cannot be ruled out.
4. Industrial scouring consists of the immersion of wool in a water-soluble detergent held at 60-70°C.
5. Gamma irradiation at 25 kGy is ideal for specimens that may be contaminated with anthrax.
6. For a country of origin that is free of foot-and-mouth disease, but in which an active outbreak of anthrax has been declared, a five-step washing procedure is acceptable:
   • immersion in 0.25–0.3 percent soda liquor for 10 minutes at 40.5°C;
   • immersion in soap liquor for 10 minutes at 40.5°C;
   • immersion in 2 percent formaldehyde solution for 10 minutes at 40.5°C;
   • a second immersion in 2 percent formaldehyde solution for 10 minutes at 40.5°C;
   • rinsing on cold water followed by drying in hot air.

C. Procedures for cleaning and disinfection of bristles

Use one of the following procedures:

1. boil for at least 1 hour; or
2. immerse for at least 24 hours in a 1% solution of formaldehyde that is prepared from 30 mL commercial formalin per litre of water.

D. Procedures for cleaning and disinfection of trophies (without skin attached) from wild animals

Use one of the following procedures prior to, or as part of, complete taxidermy:

1. Boil in water until flesh peels away from bones to ensure that any matter, other than the bone, the horns, the hooves, the claws, the antlers and the teeth, is removed (For skulls, after boiling, submerge completely in 40% peroxide for 12 hours, or for an equivalent period, to ensure that complete bleaching and removal of flesh remnants have occurred.)
2. Use gamma irradiation at a dose of at least 40 kGy at room temperature (20°C or higher).
3. Soak, with agitation, in a 4% (w/v) solution of washing soda (sodium carbonate – Na₂CO₃) maintained at pH 11.5 or above for at least 48 hours.
4. Soak, with agitation, in a formic acid solution (100 kg salt [NaCl] and 12 kg formic acid per 1000 L water) maintained at below pH 3.0 for at least 48 hours. (Wetting and dressing agents may be added.)

3. Facility access

Only trained personnel may have access to and work with imported hides and skins in the establishment.

Personnel must receive training in the handling of imported materials, as needed.

The training must include four components:

• treatment of effluent or waste liquids and discarding of trim and carcasses;
• record-keeping;
• PPE disinfection and disposal (if used); and
• cleaning and disinfection of shipping containers and disposal of plastic liners that were used to transport the imported materials.

4. Waste management

1. Trimmings disposal – After fleshing (the removal of excessive connective tissues), as well as after cleaning of PPE (when applicable), dispose of trimmings according to the approved plan, which may include any of the following: incineration, rendering, autoclaving, or burying. Unused carcasses may be buried on-site, provided that municipal and provincial legislations allow on-site burial.

2. Specified risk material (SRM) – SRM may be composted on-site or transported to a landfill for burial: Under the CFIA's enhanced animal health protection from BSE program outlined in the Health of Animal Regulations, owners or operators of waste management facilities choosing to accept SRM in any form must apply for a permit from the CFIA. In the case of taxidermists, a salvage permit is required. Permits are issued only after the facility's disposal procedures have been assessed by a CFIA inspector and determined to meet all program requirements. Disposal procedures must prove to either destroy or permanently contain all SRM that is generated. Owners may arrange for a licensed SRM collector to collect all non-necessary bovine skulls and parts thereof, so that the SRM can be disposed of at an approved facility. The CFIA's Bovine Spongiform Encephalopathy Manual of Procedures provides additional information.

   In addition to the disposal regulations, a separate permit is required to transport SRM in any form, including cattle carcasses containing SRM.

   Applications for a SRM permit from the CFIA must be accompanied by the following:

   • all relevant municipal and provincial licences and inspection reports;
   • detailed site plans;
   • standard operating procedures and any additional applicable quality assurance programs pertaining to the containment of SRM landfills; and
   • the results of any recent analyses or verifications relevant to SRM containment for facilities wishing to compost SRM on-site.

   Applications for a SRM permit can be submitted to a CFIA animal health office. Importers are urged to apply for a permit at least two weeks in advance of the predicted date of import to ensure that the permit is issued on time.

3. Waste liquid disposal plan – Treat effluent from washing, trimming, and soaking of hides, skins, and trophies with formic acid, sulphuric acid, or any other pickling agent for a minimum of 10 hours. Baking soda must be added to this effluent to obtain a pH of 7.0 before regular disposal in municipal water systems. Other acceptable effluent treatments include 5% formaldehyde for 10 hours: let water stand for 1 week to degrade formaldehyde and dispose as usual. Environmental legislation must be respected in the formulation of waste liquid disposal. The disposal methodology must be approved by a CFIA inspector and must comply with municipal and provincial environmental laws.

5. Records

Maintain the following in the facility for a minimum of two years: invoices, permits, Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) permits (where applicable), and records on the treatment applied to material, the final destination of imported specimens, importers, purchasers, the state of the specimen (cleanliness, presence of soil, blood, vegetable material), and species of origin.

Retain SRM permits and all related information, including removal, disposal, and final destination of skull and horn sales, for 10 years.

Present written standard operating procedures to the CFIA, for each commodity treated, before completing the approval of the facility.

Keep inspection records at the district office where the treatment facility is located.

Considerations regarding endangered species

Advise the importers of these materials that Environment Canada regulations restrict the trade in certain endangered species of animals and their animal products. In some cases, import and export permits are required. For further information, importers should consult CITES.

Dr. Clarice Lulai Angi
Import/Export Animal Products and By-Products
Animal Import/Export Division
Animal Health Directorate