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Archived - Feed Regulatory Renewal Pre-Consultation: What We Heard Report

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Prepared By: Feed Program Coordination and Outreach Section

Date: July 17, 2013

Table of Contents

1 Feed Regulatory Renewal Pre-Consultation – What We've Heard

1.1 Executive Summary

2 Introduction

2.1 Pre-Consultation Activities and Results

3 Bilateral Meetings

4 Multi-Stakeholder Workshop

4.1 Group Session #1 – Future Influencing Factors

4.2 Group Session #2 – Strategic Outcomes

4.3 Group Session #3 – Theme Discussions

5 Online Consultation

5.1 Discussion Paper

5.2 Online Survey

5.3 A Sampling of Additional Comments (11)

6 Summary of Key Results from the Pre-Consultation Phase

7 Next Steps

8 Appendices

Appendix I

Appendix II

Appendix III

1 Feed Regulatory Renewal Pre-Consultation – What We've Heard

1.1 Executive Summary

The Canadian Food Inspection Agency (CFIA) has initiated a multi-year review of the regulatory frameworks that it administers for food safety, plant health, and animal health. Among these various frameworks, the Agency has identified the regulatory framework for livestock feed as a priority for modernization.

Stakeholder consultation is an important part of regulatory modernization. The CFIA conducted a pre-consultation with stakeholders during 2012 in order to gather information regarding interest in a renewed feed regulatory framework, current and future trends, opportunities, and challenges facing stakeholders as they might relate to feed production and utilization. The Agency took a three-tiered approach to this pre-consultation:

  1. informal bilateral meetings were held with stakeholder groups;
  2. a discussion paper and survey were made available online to provide all stakeholders with the opportunity to provide feedback; and
  3. a two-day multi-stakeholder workshop was held.

From January through August of 2012 bilateral meetings were held with approximately 30 stakeholder groups. A structured presentation was used during the bilateral meetings to outline some of the history and background, relevant information from other countries, drivers for change and considerations, ending with a series of questions that stakeholders were invited to consider and respond to. Stakeholder feedback was divided into four categories:

  1. safeguarding the food supply;
  2. safeguarding the animal resource base;
  3. consumer protection; and
  4. market access.

Written comments were received from six organizations in response to the bilateral meetings staged.

Following this, to more broadly engage regulated parties, stakeholders, other government departments (including federal partners), and Canadians generally, an electronic consultation was launched for a period of 60 days from early August to early October 2012.

To provide background and context regarding the regulatory modernization initiative, a discussion paper that was designed to inform the development of a renewed regulatory framework was developed and posted. Divided into several sections, the paper provided a range of information regarding the background to feed regulation in Canada, the current operating environment, and internal and external drivers for change. In addition, an online survey was developed, based on the discussion paper.

The paper and survey provided discussion topics for stakeholder input on:

The CFIA received 26 written submissions from 18 organizations, 7 individuals, and 1 provincial ministry in response to the discussion paper, and 78 surveys were submitted electronically with an additional 5 completed and mailed to the CFIA.

Finally, a two-day multi-stakeholder workshop was held on September 5 and 6, 2012. The three objectives for this workshop were to:

  1. identify key factors that will influence livestock, livestock feed, and food production in the future;
  2. identify, discuss, and prioritize the key requirements of a renewed framework; and
  3. specify next steps for moving forward.

This was a working meeting, with stakeholders spending the majority of the two days in small discussion groups at their respective tables. Electronic polling technology, using either the internet or text messaging via cell phones, allowed participants to text in response to polls, used to gain participant feedback in the plenary sessions throughout the day.

This pre-consultation phase was well received by stakeholders and, as indicated above, a large amount of information was gathered. A number of themes emerged and overlapped from the various consultation activities:

Although the pre-consultation generated much information, we still require more detail on specific topics such as ingredients, how a tiered system might work, and the role for regulatory oversight of feed efficacy. Given the level of interest expressed by stakeholders in being a part of a working group process following the workshop, it was suggested that the CFIA establish a small steering group to oversee and provide guidance on the working group discussion topics and process. To this end, the Feed Regulatory Steering Group (FRSG) has been established, comprising representatives from the ANAC, Canadian Aquaculture Industry Alliance (CAIA), Canadian Cattlemen's Association (CCA), Canadian Pork Council (CPC), Chicken Farmers of Canada (CFC), and Dairy Farmers of Canada (DFC). The Steering Group is co-chaired by Veronica McGuire and Dr. Ian Alexander of the CFIA. Collaboratively, the FRSG has developed a proposal regarding the roles, responsibilities, and activities of both the FRSG and the technical working group(s) to be established as part of this consultation. Additional work by the technical working groups will include ingredient and feed manufacturing topics, and will provide the CFIA with more detailed information on these topics.

2 Introduction

In the fall of 2011, the Canadian Food Inspection Agency (CFIA) began a systematic review of its regulatory frameworks for food safety, plant health, and animal health. In the ensuing months, the CFIA has undertaken to engage Canadians, industry stakeholders, and other government departments, including federal partners, through a series of discussions and electronic consultations to discuss its regulatory modernization strategy.

Based on the 2011 review, regulatory renewal initiatives for each of the CFIA's business lines (Food, Animal, and Plant) have been planned for the short, medium and long term. The CFIA identified the feed regulatory framework, among those administered by the Agency, as a short-term (one to three years) priority in its regulatory modernization plan.

The objective of the regulatory renewal project is to develop a modernized risk- and outcome-based framework which:

The project plan for feed regulatory renewal has five phases:

While Phase 1 was largely completed prior to the end of 2011, the CFIA spent much of 2012 working on Phase 2 – Pre-consultation process. This report provides a summary of the CFIA's pre-consultation activities and responses from stakeholders regarding this phase of the project.

2.1 Pre-Consultation Activities and Results

Stakeholder consultation is an important part of regulatory modernization. To gather information with respect to interest in a renewed feed regulatory framework, current and future trends, opportunities, and challenges that face stakeholders in relation to feed production and utilization, the CFIA conducted a pre-consultation with stakeholders during 2012.

The Agency took a three-tiered approach to this pre-consultation:

  1. informal bilateral meetings were held with stakeholder groups;
  2. a discussion paper and survey were made available online to provide all stakeholders with the opportunity to provide feedback; and,
  3. a two-day multi-stakeholder workshop was held.

Stakeholders who participated included associations and individuals representing feed manufacturers, animal health product manufacturers, livestock producers, food producers, consumers, and other government partners. In some cases, stakeholder organizations participated actively in all three pre-consultation activities (for example, the Canadian Pork Council and Turkey Farmers of Canada).

3 Bilateral Meetings

From January through August 2012, bilateral meetings were held with approximately 30 stakeholder groups. A structured presentation was used during the bilateral meetings to outline some of the history and background, relevant information from other countries, drivers for change and considerations, ending with a series of questions that stakeholders were invited to consider and respond to. Stakeholder feedback was divided into four categories:

  1. safeguarding the food supply
  2. safeguarding the animal resource base
  3. consumer protection
  4. market access

Written comments were received from six organizations in response to the bilateral meetings staged.

Key Results

A more detailed summary report regarding the bilateral meetings pre-consultation activity is available upon request.

4 Multi-Stakeholder Workshop

A two-day multi-stakeholder workshop was held on September 5 and 6, 2012. The three objectives for this workshop were to:

  1. identify key factors that will influence livestock, livestock feed, and food production in the future;
  2. identify, discuss, and prioritize the key requirements of a renewed framework; and
  3. specify next steps for moving forward.

This was a working meeting, with stakeholders spending the majority of the two days in small discussion groups at their respective tables. Electronic polling technology, which used either the internet or text messaging via cell phones, allowed participants to text in a response to polls used to gain participant feedback in the plenary sessions throughout the day.

4.1 Group Session #1 – Future Influencing Factors

Participants were divided into groups representing one of three industry sectors (Livestock production, Livestock feed, or Food processing) and were asked to discuss the implications of scientific, technological, environmental, economic, political and social factors which could have an impact on their sector. This was intended as an exercise in looking ahead to identify future challenges, changes, and issues for all three sectors, so that the need for feed regulation could be more clearly situated.

Key Results

The following items were determined as having a high level of importance, over which the stakeholders as a whole had a high level of influence. In other words, these items will have a future impact, which, to some extent, can be controlled.

Scientific

Technological

Environmental

Economic

Political

Social

4.2 Group Session #2 – Strategic Outcomes

The CFIA has its own strategic outcome, and recognizes that other stakeholders such as farmers, feed manufacturers, feed ingredient manufacturers, and the food-processing sector also have interests that they would like to see recognized and supported by a regulatory framework for feeds. To better understand these "strategic outcomes" or key requirements for other stakeholder groups, participants were asked to respond to the question, "What additional strategic outcomes should be considered for the renewed framework?"

Key Results

The final result of this discussion was a list of six main strategic outcomes:

  1. public health
  2. consumer protection
  3. market access
  4. competitiveness
  5. sustainability
  6. regulatory flexibility and consistency

4.3 Group Session #3 – Theme Discussions

The theme discussions were intended to obtain more detailed information from participants on items that they viewed as risks regarding feed and feed regulation, as well as how the Codeof Practice met their needs, and who should play a role in controls for the strategies of dealing with those identified risks. Eight themes were identified for further discussions:

  1. feed labelling
  2. feed ingredients
  3. medicated feeds
  4. process controls
  5. efficacy
  6. product controls
  7. enforcement
  8. harmonization

Key Results

In each theme discussion, participants were asked to identify the risks or challenges associated with that theme. There was a high level of overall discussion and participation. Table 1 reports the key risks for each of the themes, along with, where available, an indication of whom workshop participants viewed as playing a role in mitigating or managing the risks: government (Gov.), industry (Ind.), or a joint (Joint) responsibility. If this information was not identified, it is indicated as "not available" (n/a).

Table 1 Key Risks For Each Theme Discussion and Roles in Mitigating or Managing Each Risk

Feed Labelling
Risks Responsability
Lack of harmonization of international labels Gov.
Loss of access to new products and emerging technologies Gov.
Perception of Canada as a closed market n/a
Compliance issues and costs n/a
Risk of intellectual property disclosure Joint
Lack of clarity on claims Joint
Feed Ingredients
Risks Responsability
Feed versus drug determinations and "grey zone" products Gov.
Safety assessments of feed ingredients Joint
Tiered ingredient classes with different levels of oversight Joint
Establishing or driving an international harmonization process or an internationally recognized evaluation process Joint
List of ingredients for use in feeds Joint
Medicated Feeds
Risks Responsability
Inability to access new, useful drug products (such as alternatives to antimicrobials) Joint
Lack of Canadian oversight of Active Pharmaceutical Ingredients (APIs) and Own-Use Importation (OUI) Gov.
Near-zero residue testing (impractical and irrelevant) Joint
Improper mixing at the farm level Joint
Over- and under-medication of feeds Joint
Process Controls
Risks Responsability
Risk-based facility licensing Gov.
Duplication of existing food/feed safety programs Gov.
Incomplete hazard identification by a portion of the industry Ind.
Preventative controls not effective at some facilities Ind.
Lack of technology to evaluate risks Joint
Feed regulatory system – inconsistent with other CFIA programs Joint
Feed regulatory system – inconsistent with market expectations Joint
Efficacy
Risks Responsability
"Novel" ingredients Gov.
Claims for ingredients Joint
Impact of the feed vs. drug paradigm on availability Ind.
Misrepresentation of a product Ind.
Need for flexible assessment of requirement to demonstrate efficacy Joint
Product Controls
Risks Responsability
Loss of competitiveness due to lengthy registration process Gov.
Consumers may not be protected from fraud Joint
Lack of clarity around registration of feed Gov.
Avoidance of registration due to length of process Gov.
Lack of traceability information or records upstream Joint
Appropriate level of product controls needs to be determined Joint
Third party product controls Ind.
Enforcement
Risks Responsability
Uniformity and consistency of enforcement nationally Gov.
Alignment and consistency with international enforcement Joint
Prohibitive costs Gov.
Transparency – publication of non-compliances Joint
Competency of enforcement personnel Gov.
"Chasing zero" with regards to contaminants Joint
Third party certification – consistency among providers Ind.
Harmonization
Risks Responsability
Canadian Environmental Protection Act (CEPA) equivalence Gov.
Disharmony in "feed vs. drug" determination and market access n/a
Innovation stifled n/a
Overlap of various systems n/a
Duplication of inspections n/a
Inconsistency among CFIA frameworks n/a
Difficulty in getting products to market n/a

Some general comments from the workshop:

A detailed workshop record was prepared and is available upon request.

5 Online Consultation

To more broadly engage regulated parties, stakeholders, other government departments (including federal partners), and Canadians, generally, an electronic consultation was launched for a period of 60 days – from early August to early October 2012.

To provide background and context regarding the regulatory modernization initiative, a discussion paper, designed to provide information on the development of a renewed regulatory framework, was developed and posted as part of the three-tiered pre-consultation process.

Persons or organizations that wish to provide the Agency with input were invited to respond in one of two ways:

  1. submit written comments directly to the CFIA; or
  2. provide feedback on discussion questions and comments, using and submitting an online survey form.

Beyond the posting of the discussion paper and online survey on the CFIA's external website, the CFIA actively communicated the posting of the consultation by

5.1 Discussion Paper

The paper was divided into several sections and provided a range of information with respect to the background to feed regulation in Canada, the current operating environment, and internal and external drivers for change.

In addition, the paper provided discussion topics for stakeholder input on the following:

In total, the CFIA received 26 written submissions from 18 organizations, seven individuals, and one provincial ministry.

5.1.1 Key Results – Discussion Paper

The following were recurring themes in the comments that were received:

A sample of comments from stakeholders:

5.2 Online Survey

The survey comprised 20 questions, and was divided into the following 6 sections:

  1. demographics
  2. stakeholder objectives and interests
  3. safeguarding the food supply (including the application of the Codex Code)
  4. safeguarding the animal resource base
  5. consumer protection
  6. market access

Demographics

In total, 78 surveys were submitted electronically, and an additional five were completed and mailed to the CFIA. Table 2 provides a summary of the categories and numbers of responses received. In addition, responses to certain questions contained in the survey were provided by 10 members of the American Feed Industry Association (AFIA) that were sent directly to the CFIA.

Table 2 Breakdown of responses to the online feed regulatory survey by category of respondent
Category of Respondent Number of Responses
Consumer (general public) 6
Consumer association 0
Academic 2
Provincial government 1
Federal government 9
Foreign government 0
Food processor 0
Food processor association 1
Feed manufacturer 28
Feed retailer 5
Feed importer 1
Feed transporter 0
Feed ingredient manufacturer/distributor 9
Livestock producer 4
Livestock producer association 9
Other: Veterinarians 3
Other: Consultants 3
Other: Other agri-food organizations 2
Total 83

Of the respondents, 77 were from Canada and 6 were from the U.S. As no additional information was provided about the AFIA responders, it is assumed that all 10 of the partial responses were also from companies based in the U.S.

Within Canada, the majority of responses (47, or 56%) were provided from individuals or organizations that were located in Ontario. The next most represented provinces were Alberta and Quebec, with 8 responses each.

Among the 9 livestock producer organizations that responded, 4 were national in scope (Canadian Cattlemen's Association, Canadian Pork Council, Canadian Sheep Federation and Chicken Farmers of Canada), and 5 were provincial associations (Egg Farmers of Alberta, Fédération des producteurs de bovins du Québec, Fédération des producteurs d'œufs de consommation du Québec, Les Éleveurs de volailles du Québec, and the Union des producteurs agricoles.)

For the purposes of summarizing the survey results, the responders have been grouped into four categories:

  1. "Feed" (representing 45 feed and feed ingredient manufacturers, distributors, importers etc.);
  2. "AFIA" (representing responses received from 12 AFIA members to certain survey questions);
  3. "Livestock" (representing 13 individual producers and producer associations); and
  4. "Other": (representing 25 academics, consumers, federal and provincial governments, veterinarians and other agri-food organizations).

Of the federal government responses, 8 were received from CFIA employees; their responses are not included in the results of the survey at this time. An intra-CFIA consultation will be undertaken as a separate initiative of the pre-consultation process.

5.2.1 Key Findings – Online Survey

Stakeholder Objectives and Interests

In response to the survey question, "What would your organization's interests be in feed regulatory renewal?"

Sample Comments
Safeguarding the Food Supply

In this section of the survey, respondents were asked a question (#11) regarding feed-related measures linked to the safeguarding of food for human consumption, and given a range of measures from which to choose. Appendix I provides the question's full text. A summary of the responses by grouping of respondents for each measure is available upon request.

Table 3 summarizes the results for measures d, e, f, and g that are of note.

Table 3 Proportion of respondents in favour of specific measures to safeguard the food supply, by category of respondent
Question Measure Grouping
(% of respondents who selected measure)
Feed Livestock Other Overall
11 d Controls on the manufacturing, sale, and labelling of commercial medicated feeds. 61% 77% 60% 64%
11 e Controls on the manufacturing, sale, and labelling of non-medicated commercial feeds. 36% 31% 33% 35%
11 f Controls on the manufacturing of medicated feeds produced on-farm. 57% 69% 33% 54%
11 g Controls on the manufacturing of non-medicated feeds produced on-farm. 36% 8% 27% 29%

Generally speaking, the items related to measures to control medicated feeds, regardless whether they are produced commercially or on-farm, were selected about twice as often as those related to controls on non-medicated feeds.

Regarding measure k in this question, "Health and safety labelling information in both official languages," there was a low level of support by Feed (14%), Livestock (8%), and Overall (21%) as a requirement in a regulatory framework, although about half of the Other grouping selected item k (53%).

Codex Alimentarius Code of Practice on Good Animal Feeding (Code of Practice)

Included in the section of the survey concerning the safeguarding of the food supply were questions relating to the potential adoption in regulation of, and current adherence with, requirements set out in the Codex Alimentarius Code of Practice on Good Animal Feeding.

The objective of this Code of Practice is to help ensure the safety of food for human consumption through adherence to good animal feeding practices at the farm level and good manufacturing practices (GMPs) during the procurement, handling, storage, processing, and distribution of animal feed and feed ingredients for food-producing animals.

The Code of Practice sets out general principles and, more specifically, requirements for:

Question 12 of the survey asked respondents, "Is using the Codex Code of Practice an appropriate frame of reference for consultation on feed regulatory renewal?" Overall, 60% of respondents selected "Yes," 9% "No," and 31% "I don't know." A significant proportion of the responders are, as a result, unfamiliar or uncertain about whether the Code of Practice and its use are appropriate in this discussion.

In Question 15 of the survey, respondents were asked:

  1. Which aspects of the Code would be important to you or your organization to have included within the scope of a regulatory framework? (Select all that apply.); and
  2. Which aspects of the Code that apply to you, or your organization, are being adhered to at present? (Select all that apply.)

As responses to these questions were not made mandatory, 26 of 44 Feed, 8 of 10 AFIA, 9 of 13 Livestock, and 7 of 15 Other respondents completed this question.

Protecting the Animal Resource Base

In section 4 of the survey, respondents were asked a question (#16) regarding feed-related measures, linked to the safeguarding of animal health, and given a range of measures from which to choose. Appendix II provides the full text for the questions.

Table 4 illustrates the responses to Questions 11a and 16a regarding the assessment of hazards in feed ingredients. While Feed and Other respondents selected the measure at about the same rate in both questions, Livestock respondents indicated that it was more important to have regulations to assess new feed ingredient safety to livestock, rather than food safety and human health.

Table 4 Proportion of respondents in favour of specific measures to protect the animal resource base, by category of respondent.
Question Measure Grouping
(% of respondents who selected measure)
Feed Livestock Other Overall
11 a Assessment of new feed ingredients for safety to food for human consumption. 61% 46% 93% 65%
16 a Assessment of new feed ingredients for safety to livestock. 64% 69% 93% 71%
Table 5 Proportion of respondents in favour of specific measures to safeguard the food supply, by category of respondent
Question Measure Grouping
(% of respondents who selected measure)
Feed Livestock Other Overall
16 d Listing maximum levels in feeds of nutrients that would be harmful to livestock. 43% 60% 53% 50%
16 e Listing of nutrients and minimum levels in feeds that would prevent nutrient deficiencies and provide for adequate livestock nutrition. 39% 31% 53% 40%
16 f Feeds provide adequate nutrition for the intended species and class of livestock. 36% 46% 67% 44%
16 h Non-nutritional claims for feeds that may impact the productivity of livestock are assessed and approved prior to marketing. 27% 38% 60% 36%
Consumer Protection

In section 5 of the survey, respondents were asked a question (#17) regarding feed-related measures, linked to the safeguarding of consumers, and given a range of measures from which to choose. Appendix III provides the full text for the questions.

Table 6 Proportion of respondents in favour of specific consumer protection measures, by category of respondent
Question Measure Grouping Table Note 1
(% of respondents who selected measure)
Feed Livestock Other Overall
17 e Additional label information/logo is allowed without pre-market verification. 41% 0% 0% 25%
17 f Additional label information/logo is allowed with pre-market verification. 32% 62% 60% 44%
17 g Additional label information/logo is not allowed. 9% 0% 15% 8%

Table Notes

Table Note 1

Not all survey participants responded to these measures.

Return to table note 1  referrer

Table 7 Proportion of respondents in favour of specific measures to address foreign languages, by category of respondent
Question Measure Grouping Table Note 2
(% of respondents who selected measure)
Feed Livestock Other Overall
17 k Foreign languages are permitted without any oversight/ pre-market approval. 20% 8% 13% 17%
17 l Foreign languages are permitted with oversight/pre-market approval. 11% 15% 20% 14%
17 m Foreign languages are not permitted. 14% 15% 33% 18%

Table Notes

Table Note 2

Not all survey participants responded to these measures.

Return to table note 2 referrer

Market Access

In section 6 of the survey, respondents were asked questions (18 and 19), concerning measures linked to the export and import of feeds, respectively:

Other Comments

Question 20 of the survey inquired whether respondents had any additional comments. In total, 26 responders provided additional comments (Feed = 14, Livestock = 7, Other = 5).

5.3 A Sampling of Additional Comments (11)

The Canadian feed industry is over regulated and uncompetitive because of an attempt by the [CFIA] to reinvent the wheel. Adherence to the U.S. American Association of Feed Control Officials (AAFCO) standards for ingredients would greatly simplify our relationship with our main trading partner the U.S.A.

Yes, I am glad someone is looking at amending the Regulations and specifically points dealing with Schedule IV. I suggest to you, while you are at it, consider eliminating the list altogether. This list is a bad idea gone wrong, in my opinion, and you can never fix it.

I would like to see more human and animal health studies being done on effects of Genetically Modified Foods as well as labelling requirements in food and feeds. This should be part of the honest labelling in any application.

Most of my concerns are in regards to the registration of feeds/ingredients. I feel the regulatory framework is cumbersome and wasteful.

Many feed products from countries like Denmark have already been approved in the European Union (EU) on the background of testing etc. Those countries have some very strict rules on use of medication to livestock. Many of these feed additives etc. are based on natural ideas and help prevent the use of medication and drugs in livestock production. Many of these products never make it to Canada due to the regulatory system in place now. This is a great downfall to Canadian livestock producers.

As a feed retailer to small "backyard" clients I cannot understand the requirement to capture individual customer sales information and store for 10 years. It is not consistent with the retail of food at a grocery store.

Presently the Feeds Regulations stifle domestic innovation as there are no categories set for innovation e.g. nucleotides. Further, if an ingredient e.g. Yogurt can be consumed directly by humans why is it that there are regulations in place at the CFIA which basically make it almost impossible to register and then feed to animals.

With previous efforts to modernize the Feed Regulations not coming to completion, it will be important for industry engagement to have set timelines and reasonable outcomes for this process.

Mink are not linked to the food chain for human consumption. We should not be part of CFIA inspections.

I am looking for innovation, competitive, sustainability of Canadian Feed Industry with Cost Reduction but No compromise in Human or Animal safety.

Under section 3: We would like CFIA to consider that there are instances where reduced oversight is necessary when feed is being made on-farm for individual use. The various commodity food safety programs already do a significant amount of the work suggested under the codex, and industry would typically prefer that using these existing food safety systems is preferred to CFIA administering a new program at the farm level.

A summary of the results from the online survey has been compiled and is available upon request.

6 Summary of Key Results from the Pre-consultation Phase

This pre-consultation phase was well received by stakeholders and as indicated above, a large amount of information was gathered. A number of themes emerged and overlapped from the various consultation activities:

A strong role for the CFIA in overseeing feed safety. There was strong support for the CFIA to continue its role in feed safety. Feeds should not cause harm to the animals consuming them and the environment, or result in food safety issues via contaminants or residues in meat, fish, milk, and eggs. While there was strong support for using the Code of Practice to frame discussions regarding feed-related requirements that contribute to safeguarding the food supply, there was a high degree of unfamiliarity with the Code and variability between, and within, industry sectors on which requirements are necessary within the scope of a regulatory framework for feed.

Debate about the CFIA's role in overseeing feed efficacy. There was a divergence of opinion on the CFIA's role with respect to the oversight of feed efficacy (e.g. classifying the purpose of feeds and ingredients [nutritional vs. non-nutritional], their fitness for their purpose, nutritional composition, claims on labels etc.), as it contributes to the health and performance of animals, the protection of consumers, and market access.

A continued need for oversight of ingredients. Although stakeholder feedback was inconsistent in terms of the level of oversight needed, stakeholders generally agreed that, to determine safety, new ingredients should be assessed by the competent authority. Also viewed as beneficial was a way to recognize the approval of an ingredient by another country, or a mechanism for fast-tracking these ingredients. Further, having a list of acceptable ingredients is useful, but the ability to maintain and update this list quickly and easily would provide stakeholders with faster access to new and innovative products.

The need for process controls. Stakeholders identified a need for regulatory controls on the manufacture and processing of feeds and for a lesser focus on the content of the feed itself. It is believed that purchasers of feed are knowledgeable and thus do not require regulatory controls over the nutrient content of the feed. Instead, a requirement for hazard identification and control by feed manufacturers would enhance the mitigation of safety risks associated with feeds.

Support of the ANAC White Paper (The Case for Modernization of the Canadian Feed Regulations, 2010). Stakeholders expressed a general level of support for the conclusions and recommendations from the paper. The main principle of the paper is that the emphasis of the regulatory system should be on the identification and control of risk, both in the ingredients used to produce feeds and in the manufacturing environment itself; the Regulations should focus clearly on safety, rather than attempt to control the nutrient content of feeds.

A need for tiered levels of control. Stakeholders suggested a risk-based approach to regulatory controls. This included a desire to recognize that farms that are manufacturing feeds for their own use may not need as high a level of oversight as a commercial feed mill. Other factors that could influence the level of control included the use of medications, the types of ingredients used, and foreign approval of a product. To this end, some stakeholders suggested including a risk-based facility registration/licensing system in a modernized feed regulatory framework that should be harmonized with a parallel CFIA initiative to modernize its inspection approaches.

Concerns regarding the current registration system. The current feed registration system is considered too lengthy and burdensome. Stakeholders expressed a number of frustrations with the current system. Stakeholders view the intent of the registration system as one that could be met by shifting to a facility registration system. Subsequent to approving a facility, any feeds it manufactured would not require registration.

Recognition of existing industry programs. A number of Hazard Analysis Critical Control Points (HACCP) or HACCP-based programs are already being followed by stakeholders. This includes the FeedAssure program, administered by ANAC for feed manufacturers and a number of CFIA-recognized On-Farm Food Safety programs for livestock producers. Recognition of these existing systems, under a feed regulatory framework, would mean that stakeholders may not require as extensive a regulatory oversight, as many of these requirements would be met through the programs.

Access to innovative products. Stakeholders frequently indicated that the current feed regulatory system did not facilitate timely access to innovative feed products. This was, in part, due to the registration requirements for feeds or ingredients, and, to some extent, because these innovative products are viewed as feeds by the industry. However, they are often classified as therapeutic products under the Food and Drugs Act and Regulations and are treated as new drugs. Stakeholders want the ability to access these products, and for those who manufacture or sell the products, to do so in a timely manner, without a number of regulatory hurdles.

International alignment. Stakeholders agreed that, to facilitate competitiveness and trade, there is a need to align the Canadian system with our international trading partners (mainly the U.S. and EU). Canada is seen as a small market, and it is perceived that our domestic regulatory requirements prevent some foreign companies from marketing their new and innovative products in Canada, thus depriving Canadian feed manufacturers and livestock producers of these products.

7 Next Steps

Although the pre-consultation generated much information, more detail is required on specific topics, such as ingredients, how a tiered system might work, or the role for regulatory oversight of feed efficacy. Given the level of interest expressed by stakeholders to be part of a working group process following the workshop, it was suggested that the CFIA establish a small steering group to oversee and provide guidance on the working group discussion topics and process. To this end, a Feed Regulatory Steering Group (FRSG) has been established, co-chaired by Veronica McGuire and Dr. Ian Alexander of the CFIA, comprising representatives from the ANAC, Canadian Aquaculture Industry Alliance (CAIA), Canadian Cattlemen's Association (CCA), Canadian Pork Council (CPC), Chicken Farmers of Canada (CFC), and Dairy Farmers of Canada (DFC). Collaboratively, the FRSG has developed a proposal regarding the roles, responsibilities, and activities of both the FRSG and the technical working group(s) to be established as part of this consultation. Additional work by the technical working groups will include ingredient and feed manufacturing topics, and provide the CFIA with more detailed information on these topics.

8 Appendices

  1. Online Survey - Section 3 - Safeguarding the Food Supply
  2. Online Survey - Section 4 - Protecting the animal resource base
  3. Online Survey - Section 5 - Consumer Protection

Appendix I

Online Survey - Section 3 - Safeguarding the Food Supply

11. The safety of food for human consumption is linked to the composition and safety of feed provided to food-producing animals. Which of the following would be important to you or your organization to have included within the scope of a regulatory framework with respect to the safeguarding of food? (Select all that apply.)
  1. a. Assessment of new feed ingredients for safety to food for human consumption.
  2. Hazard identification and control plans required with respect to food safety during the manufacture of feed or feed ingredients for livestock.
  3. Controls on the manufacturing, sale and labelling of feed ingredients.
  4. Controls on the manufacturing, sale and labelling of commercial medicated feeds.
  5. Controls on the manufacturing, sale and labelling of non-medicated commercial feeds.
  6. Controls on the manufacturing of medicated feeds produced on farm.
  7. Controls on the manufacturing of non-medicated feeds produced on-farm.
  8. Establishment of controls on contaminants (biological, chemical and physical) and feed standards to reduce harmful residues in animal products for human consumption.
  9. Listing of nutrients and maximum levels in feeds to reduce harmful residues in food products for human consumption.
  10. Pre-entry controls and standards for imported feeds.
  11. Health and safety labelling information in both official languages.
  12. Other, please specify. space
  13. None of the above.

Appendix II

Online Survey - Section 4 – Protecting the animal resource base

16. Notwithstanding food safety, feeds need to be safe for livestock. Which of the following would be important to you or your organization to have included within the scope of a regulatory framework with respect to the protection of animal health? (Select all that apply.)
  1. Assessment of new feed ingredients for safety to livestock.
  2. Animal health hazard identification and control plans are required in facilities manufacturing feed or feed ingredients for livestock.
  3. Listing of contaminants (biological, chemical and physical) and levels in feeds that would be harmful to livestock.
  4. Listing maximum levels in feeds of nutrients that would be harmful to livestock.
  5. Listing of nutrients and minimum levels in feeds that would prevent nutrient deficiencies and provide for adequate livestock nutrition (for sustainable health and productivity).
  6. Feeds provide adequate nutrition for the intended species and class of livestock (for example, milking, breeding, growing or finishing animals).
  7. Nutritional information is required on feed labels.
  8. Non-nutritional claims for feeds that may impact the productivity of livestock are assessed and approved prior to marketing (e.g. Forage additive claims).
  9. Pre-entry controls for imported feeds.
  10. The labeling of health and safety information in both official languages.
  11. Controls on the manufacturing, sale and labelling of feed ingredients.
  12. Controls on the manufacturing, sale and labelling of commercial medicated feeds.
  13. Controls on the manufacturing, sale and labelling of non-medicated commercial feeds.
  14. Controls on the manufacturing of medicated feeds produced on farm.
  15. Controls on the manufacturing of non-medicated feeds produced on-farm.
  16. Feed ingredients should be obtained from safe sources and be subject to a risk analysis where the ingredients are derived from processes or technologies not previously evaluated from an animal health point of view.
  17. Feed ingredients should meet acceptable and, if applicable, statutory standards for levels of pathogens, mycotoxins, pesticides and undesirable substances that may give rise to animal health hazards.
  18. Other, please specify. space
  19. None of the above.

Appendix III

Online Survey - Section 5 - Consumer Protection

17. Notwithstanding food safety, which of the following would also be important to you or your organization to have included within the scope of a feed regulatory framework with respect to the protection of consumers? (Select all that apply.)
  1. New feed ingredients are assessed as fit for intended purpose for feeding to livestock.
  2. An accurate list of ingredients is required on feed labels.
  3. Nutritional claims for feeds intended to impact nutritional claims on food for human consumption are assessed and approved prior to the marketing of the products (e.g. Contains omega fatty acids).
  4. Nutritional, production or other claims on feed labels are assessed and approved prior to the marketing of the products (e.g. "increased milk production," "increased nutrient availability," "rumen protected").
  5. Additional label information/logo is allowed without pre-market verification (e.g. Made in a HACCP certified facility).
  6. Additional label information/logo is allowed with pre-market verification (e.g. Made in a HACCP certified facility).
  7. Additional label information/logo is not allowed (e.g. Made in a HACCP certified facility).
  8. Nutrient level testing/verification is required for feed.
  9. Labels for feeds are truthful (accurate, not misleading).
  10. Labeling of all information in both official languages.
  11. Foreign languages (other than English and French) are permitted without any oversight/pre-market approval.
  12. Foreign languages (other than English and French) are permitted with oversight/pre-market approval.
  13. Foreign languages (other than English and French) are not permitted.
  14. Feeds have a unique identifier (lot number) to facilitate traceability.
  15. Other, please specify. space
  16. None of the above.
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