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Consultation summary on maximum nutrient values in beef and dairy cattle feeds - Respondent comments and CFIA responses

July 17 - August 18, 2017

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Introduction

Building on considerable consultation, research, design and planning work completed over the past few years to continuously improve how the CFIA does business. The Agency is moving forward on five strategic priorities to help safeguard food, animals and plants in order to enhance the health and well-being of Canada's people, environment and economy.

To maximize the Agency's capacity to respond to risk now and into the future, all work being done by the CFIA will align with the these five priorities:

  1. Modern regulatory toolkit - the CFIA's modern regulatory toolkit, which focuses on outcome-based regulations with new compliance promotion tools, supports the Agency's role in protecting Canada's food, plants and animals, while facilitating product innovation
  2. Integrated risk management - the CFIA's decisions and actions are based on risk and science. The Agency's new risk management tools; analytics and surveillance contributes to informed resource allocations and enforcement priorities while also bolstering the CFIA's ability to adapt quickly and respond to emerging risks in a changing global environment
  3. Consistent and efficient inspections - a single inspection approach focused on regulatory outcomes and effectiveness of industry controls, supported by guidance and mobile tools, will contribute to greater efficiency and agility for the Agency when responding to emerging risks
  4. Digital-first tools and services - electronic access as the preferred method of requesting and receiving services from the CFIA, through applications such as My CFIA and Ask CFIA, will support industry compliance with regulatory requirements while helping to manage and prevent food safety risks
  5. Global leader - the CFIA's collaboration with partners around the world will support the development of international rules and standards, fairness in trade practices, enhanced use of technology, increased regulatory cooperation and improve market access for industry

The modernization of the Feeds Regulations (Regulations) is taking these priorities into account in order to benefit the collective Canadian feed industry, which includes livestock producers, commercial feed manufacturers, retailers, importers, exporters, ingredient manufacturers, and food processors. In addition to aligning with other international feed regulatory regimes, modernization also maintains the objective of ensuring the regulations are as outcome-based, efficient and as flexible as possible while also continuing to ensure feeds are safe and contribute to the production and maintenance of healthy livestock, safe foods of animal origin, and that they do not pose a significant risk to the environment.

The oversight of nutrient values in feeds is just one aspect of the Regulations that is being reviewed as part of the comprehensive modernization project. Table 4 of Schedule I was created and incorporated into the Feeds Regulations in the 1980s as a mechanism to exempt certain groups of feeds from registration. Currently, if a complete feed provides nutrients which fall within the ranges listed in Table 4, or a supplement has directions for use which would result in a complete feed that provides nutrients which fall within the Table 4 ranges, the feed can be exempted from registration. Feeds that provide nutrients which fall outside the ranges listed in Table 4, and that do not meet any additional exemption criteria, require assessment and registration by the CFIA prior to manufacture and sale.

The values in Table 4 no longer have the same nutritional relevancy that they did when the table was first introduced. Stakeholders have also indicated that they feel Table 4 prevents innovation for new feed products, however, many of the maximum nutrient limits which are currently set in Table 4 have health and safety implications that must be considered.

The CFIA undertook a consultation from July 17, 2017 to August 18, 2017 on a proposal to identify maximum nutrient values in beef and dairy cattle feeds. It was also proposed that Table 4 be removed from the Regulations and no longer serve as a trigger for registration of feeds based on specified ranges of nutrient content. Finally, the proposal indicated that these maximum nutrient values would be included in a document to be incorporated by reference in the regulations to allow the flexibility to amend the list(s) in a timely manner, as necessary.

This report consolidates and summarizes the comments received on the maximum nutrient values in beef and dairy cattle feeds proposal and the CFIA's response to those comments.

The CFIA would like to thank everyone who participated in the consultation for contributing their time to the consultation process and sharing their views.

About the consultation

The primary mode of consultation involved the preparation and posting of the Proposal - Maximum Nutrient Values in Beef and Dairy Cattle Feeds - on the CFIA website, and outreach directly to industry stakeholders, government partners and CFIA staff. 19 sets of written comments were received in response to the maximum nutrient values in beef and dairy feeds proposal.

What we heard

Respondent profile

Table 1: Respondent profile
Category of respondent Distribution
Feed industry - individual 7
Feed industry - association 5
Livestock producer - individual 0
Livestock producer - association 3
Other feed inputs 1
Government (Canadian federal/provincial) 3
Total 19

The feed industry association comments represent Canadian and American commercial feed manufacturers, as well as some larger feed ingredient supplier organizations. The Canadian feed manufacturers association represents 90% of commercial feed manufactured in Canada, while the US association represents about 75% of commercial feed manufactured in the US. The "Other Feed Inputs" listed in the table above included a response from a Canadian University.

Key respondent messages

While stakeholders provided many suggestions for improvement regarding the proposed maximum nutrient values for beef and dairy feeds, the CFIA did not receive any comments indicating an outright disagreement with the proposed regulatory approach.

Respondents indicated they agreed with the concept of discontinuing the use of Table 4 as a means of exempting feeds from registration, however, they also raised some concerns regarding the proposal, including:

A more detailed discussion on these concerns and the CFIA's response follows below.

Feedback on the proposed maximum nutrient values in beef and dairy feeds

Average intakes and nutrient profiles of ingredients

The proposal included tables displaying average total dry matter intake, complete feed intake and forage intake for the identified classes of beef and dairy cattle. 7 respondents expressed concerns over some of the values included in these tables. 4 respondents suggested that the proposal does not account for the different breeds of cattle and commented that the average consumptions vary with the live weight of the animals that is strongly influenced by the breed. Furthermore, 3 respondents indicated the average intake levels for the animals were too restrictive and factors such as size of the animal and the broad ranges in age and weight for the heifer class make the suggested values not reflective of actual needs.

The proposal suggested that the maximum nutrient values for beef and dairy will be established based on total daily diets rather than for complete feeds only. 6 respondents commented on the difficulties determining the nutrient profile for all ingredients, including forages, used in the total diet. 3 respondents questioned if the future state would require each facility to test every ingredient used in the manufacture of their feeds and went on to express concern over the financial impact of that testing. 3 respondents questioned what standard for ingredient nutrient profiles CFIA would be utilizing when determining compliance and went on to suggest that National Research Council of the National Academies (NRC) values are not reflective of regional variations and flexibility would be required to allow for those regional variations.

CFIA response

Intakes (grain and forages)

Intakes for the classes of cattle were not used in the calculations of the maximum nutrient values and therefore do not reflect all production situations. They were examples of average total dry matter intake associated with the various classes of beef and dairy cattle. CFIA is aware of the variations in intake associated with breed of cattle, weight, age and varying production conditions. The tables have been modified to include a range of dry matter intake (DMI), rather than averages. The tables would not be used as a "standard or facts" for calculations of intakes to verify compliance, as production conditions will differ.

Beef
Class Range of total dry matter intake
(kg DM/day) Table Note 1
Lactating cows (LT) 10-14
Dry pregnant cows and bred heifers (DC) 8-13
Growers - medium energy diet (GM) 6-10
Growers - high energy diet (GH) 6-10
Finishers (F) 9-12
Calves - birth to weaning (C) 0.5-6
Red veal calves (RV) 5-7

Table Notes

Table Note 1

Note: Total dry matter intakes on farms may be below or above these ranges.

Return to table note 1 referrer

Dairy
Class Range of total dry matter intake
(kg DM/day) Table Note 2
Lactating Cow (LT) 10-30
Dry Cow (DC) 6-15
Heifer - 3 months to calving (H) 3-15
Calf - birth to 3 months (S) 0.5-3

Table Notes

Table Note 2

Note: Total dry matter intakes on farms may be below or above these ranges.

Return to table note 2 referrer

Ingredient nutrient profiles

Feed manufacturers and nutritionists analyze forages periodically for their feed formulations and manufactured feed and ingredients are currently labelled with "directions for use" as well as nutrient guaranteed analysis. No extra requirements would be expected for the industry, other than proper labelling and records of their feed sources/formulations in case they are required for verification during regular inspection activities or during a contamination issue.

Databases (from lab analyses) would also be consulted to reflect current and regional variations especially regarding forages, where no records are available. Also for specific nutrients in forages, the CFIA would use NRC values for typical forages. If there is specific forage data from a producer or feed mill that better represents the region or particular feeding program, this can be provided to a CFIA inspector and used. This should allow for greater flexibility across the country to account for geographic difference in forage and even in cases where mixtures of forages are being used. As these proposed maximums would be included in a document to be incorporated by reference in the regulations, the values may be adjusted from time to time to keep up with science and new production technologies.

Suggestions for improvement

With respect to the nutrient values, in many cases respondents indicated that the proposed values were too low based on current industry practices and the experiences of individual nutritionists in the formulation of diets for beef and dairy cattle. Furthermore, 2 respondents indicated that the NRC is releasing a revised nutrient requirement publication for cattle which may require a review of the values in the proposal.

CFIA response

The CFIA appreciates the time stakeholders invested in providing detailed descriptions and rationales of their production practices and concerns with the proposed maximum nutrient values. The CFIA acknowledges these perspectives and in many instances, agrees to increase certain nutrient maximum levels in response to this feedback as further described below.

The CFIA intends to incorporate the maximum nutrient values by reference in the regulations which will provide flexibility in amending the list(s) as changes in science or technology occur.

Macro-minerals

Calcium (Ca) and Phosphorus (P)

13 respondents provided comments regarding the proposed maximum calcium values for beef and/or dairy cattle. In all instances respondents felt the proposed values were low and should be increased.

Concerns raised by respondents
Nutrient Beef Dairy
Calcium
  • The maximum tolerable level (MTL) is 2%
  • The proposed maximum level needs to account for the use of milk replacers and forages which are >1% Ca
  • Suggest keeping the level in lactating beef and dairy cows at 2% as Ca:P and Ca:Magnesium (Mg) ratios are more important than Ca level
  • 1% maximum for feeds for calves and dry cows may not be high enough as forages contain more Ca than that already - suggest increasing to 1.5% to prevent milk fever and
  • The maximum level needs to be higher for instances when alfalfa is being fed
  • Propose a max of 2% for all classes as there are no health issues
  • Dry Cow class should have a maximum of 2%, due to the use of Dietary Cation-Anion Difference (DCAD) supplements in diets for close up transition cows
  • If the diet is high in distillers, the P level might be as high as 1% of diet so need to ensure the Ca:P ratio is 2:1 or Ca at 2% and
  • Increase to 2.5% to accommodate feeding anionic supplements to dry cows

4 respondents provided comments regarding the proposed maximum phosphorus values for beef and/or dairy cattle. While 1 respondent felt the proposed value was too low when the addition of by-product feeds is included in the ration, all other respondents indicated approval for the proposed values.

CFIA response

Calcium

After careful review and consideration of the suggested values from all respondents, the CFIA intends to amend the maximum calcium values in beef and dairy cattle feeds to account for high Ca levels in forages and mineral ratios under varying production conditions and feeding anionic supplements to dry dairy cows. No risks to animal health or food safety would be anticipated with increases to these levels. Caution should be taken by nutritionist to prevent milk fever. The proposed modifications are set out in the tables below.

Beef
Class Proposed
(% of diet DM)
Revised
(% of diet DM)
Lactating cows 1.5 2
Dry pregnant cows & bred heifers 1 2
Growers (medium energy diet) 1.5 2
Growers (high energy diet) 1.5 2
Finishers 1.5 2
Calves (birth to weaning) 1 2
Red veal calves 1.5 2
Dairy
Class Proposed
(% of diet DM)
Revised
(% of diet DM)
Lactating Cow 1.5 2
Dry Cow 1 2
Heifer (3 months to calving) 1.5 2
Calf (birth to 3 months) 1.5 2
Phosphorus
Beef and Dairy

The CFIA will proceed with the maximum values for phosphorus identified in the proposal. Respondent concerns related to the feeding of byproduct feeds considering the change to total diet vs previous maximums relative to complete feed are unlikely in the view of the CFIA. Furthermore the proposed maximum levels (0.7% of diet DM) aligns with the MTL for P (NRC, 2016)

Summary of feedback - Magnesium, Sodium, Potassium and Sulfur levels
Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement - Summary of feedback
Magnesium (Mg) 7 2 3 - Proposed maximum level was too low for beef cattle and suggested to increase this to mirror the dairy value of 0.5%
1 - Suggested that Mg and K levels in forages in Alberta (AB) and British Columbia (BC) may affect other macro-mineral adequacy
1 - Suggested there may be issues when high forage diets are used for lactating and/or dry cows and/or calves
Sodium (Na) 5 3 2 - Noted that salt is used to limit the intake of energy and protein supplements and questioned whether the proposed value would restrict such feeding practices
Potassium (K) 8 0 7 - Suggested the proposed value was lower than the K amount found in many forages thus proposed to increase the maximum value between 2-3% and went on to further suggest to increase the level for beef to at least the same as the values for dairy cattle
1 - Suggested that Mg and K levels in forages in AB and BC may affect other macro-mineral adequacy
Sulfur (S) 6 3 1 - Suggested possible interactions between S and Copper (Cu) in Saskatchewan (SK) and parts of AB
1 - Suggested rations with high levels of by-products may put levels over the MTL for beef cattle
1 - Proposed to increase the maximum value for beef to 0.5% as per NRC recommendation

CFIA response

Magnesium

The CFIA will proceed to increase magnesium maximum to 0.6%DM (MTL) for all classes of beef cattle as set out in the table below, due to the high inherent level in forages and mineral ratios under varying production conditions. No animal health or food safety issues would be anticipated in the view of the CFIA.

Beef
Class Proposed
(% of diet DM)
Revised
(% of diet DM)
Lactating cows 0.4 0.6
Dry pregnant cows & bred heifers 0.4 0.6
Growers (medium energy diet) 0.4 0.6
Growers (high energy diet) 0.4 0.6
Finishers 0.4 0.6
Calves (birth to weaning) 0.4 0.6
Red veal calves 0.4 0.6
Dairy

No comments were received indicating a concern with the Mg levels proposed for dairy cattle; as such the CFIA will proceed with the maximum values for Mg identified in the proposal.

Sodium
Beef and Dairy

The CFIA will keep the maximum values for sodium identified in the proposal and does not believe that the proposed limit will affect the practice of using salt to limit the intake of energy and protein supplements.

Potassium

The CFIA will proceed to increase the maximum values for potassium to 3% for all classes of beef cattle as set out in the table below due to the high inherent levels of this nutrient in forages and mineral ratios under differing production conditions. No animal health or food safety issues would be anticipated with this slight increase.

Beef
Class Proposed
(% of diet DM)
Revised
(% of diet DM)
Lactating cows 2 3
Dry pregnant cows & bred heifers 2 3
Growers (medium energy diet) 2 3
Growers (high energy diet) 2 3
Finishers 2 3
Calves (birth to weaning) 2 3
Red veal calves 2 3
Dairy

No comments were received indicating a concern with the K levels proposed for dairy cattle; as such the CFIA will proceed with the maximum values for K identified in the proposal.

Sulfur

The CFIA will proceed to increase the maximum values for S to 0.5% for classes F, C and RV due to high levels of S potentially in DDGs and NPN usage that may be fed in these classes. No animal health or food safety concerns are associated with this increase to 0.5% (MTL).

Beef
Class Proposed
(% of diet DM)
Revised
(% of diet DM)
Lactating cows 0.5 0.5
Dry pregnant cows & bred heifers 0.5 0.5
Growers (medium energy diet) 0.5 0.5
Growers (high energy diet) 0.5 0.5
Finishers 0.3 0.5
Calves (birth to weaning) 0.3 0.5
Red veal calves 0.3 0.5
Dairy

The CFIA will proceed with the maximum values for S identified in the proposal.

Trace minerals

Summary of feedback - Cobalt, Copper, Iodine and Iron levels
Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement - Summary of feedback
Cobalt (Co) 7 1 2 - Suggested the proposed maximum value was much lower than the toxicity level unnecessarily
2 - Suggested to maintain the current maximum level of 10 mg/kg to ensure Vitamin B12 production
2 - Indicated the US does not have a maximum value for Co thus Canadian producers would be at a competitive disadvantage and suggested increasing the proposed maximum value to 1.5 mg/kg
Copper (Cu) 7 2 2 - Suggested high levels of Mo and S influence the availability of copper and suggested the Cu value needed to be 6 times higher
2 - Suggested increasing the maximum value to 40 mg/kg to provide flexibility for mineral interactions
1 - Proposed having a recommended level of 20 mg/kg but suggested a maximum value between 40-50 mg/kg to offset high S and Mo levels may also be needed
Iodine (I) 8 1 4 - Suggested the maximum value was unnecessarily low and proposed increasing the value to 2 mg/kg, 3 mg/kg and even 5 mg/kg to increase health status and decrease lameness in animals
2 - Suggested a dairy maximum value of 2.5 mg/kg for lactating cattle and 10 mg/kg for all other beef and dairy classes
1- Suggested the proposed maximum value is too restrictive to account for ingredients such as canola meal
Iron (Fe) 4 3 1 - Suggested needed more flexibility to account for the other sources of Fe and went on to propose a maximum value of 750 mg/kg for beef

CFIA response

Cobalt

The CFIA will proceed with increasing the maximum values for cobalt to 5 mg/kg DM for all classes of beef and dairy cattle as set out in the tables below to account for vitamin B12 requirements and rumen function. No animal or human health issues have been shown with the increase. Inclusion of supplemental Co in feeds in excess of the requirements is not recommended as Co and Co compounds pose a risk to workers during mixing and feeding due to their dusting potential and presumed carcinogenicity after inhalation (EFSA FEEDAP Panel (EFSA Panel on Additives and Products or Substances used in Animal Feed) 2009, European Food Safety Authority 2012).

Beef
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating cows 1 5
Dry pregnant cows & bred heifers 1 5
Growers (medium energy diet) 1 5
Growers (high energy diet) 1 5
Finishers 1 5
Calves (birth to weaning) 1 5
Red veal calves 1 5
Dairy
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating Cow 1 5
Dry Cow 1 5
Heifer (3 months to calving) 1 5
Calf (birth to 3 months) 1 5
Copper

The CFIA will proceed with increasing the maximum values for copper to 40 mg/kg (MTL) for all classes of beef and dairy cattle to accommodate possible mineral interactions/ratios and variations in soils. No safety concerns identified.

Beef
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating cows 30 40
Dry pregnant cows & bred heifers 30 40
Growers (medium energy diet) 30 40
Growers (high energy diet) 30 40
Finishers 30 40
Calves (birth to weaning) 30 40
Red veal calves 30 40
Dairy
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating Cow 40 40
Dry Cow 40 40
Heifer (3 months to calving) 30 40
Calf (birth to 3 months) 30 40
Iodine

The CFIA will proceed with increasing the maximum values for iodine to 5 mg/kg for beef cattle destined for slaughter and 2.5 mg/kg for lactating cows to counteract the presence of anti-nutrients (goitrogenic compounds) in ingredients that interfere with iodine function. No animal and human safety issues associated with increase.

Beef
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating cows 1.3 5
Dry pregnant cows & bred heifers 1.3 5
Growers (medium energy diet) 1.3 5
Growers ( high energy diet) 1.3 5
Finishers 1.3 5
Calves (birth to weaning) 0.7 5
Red veal calves 0.7 5
Dairy
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating Cow 1.3 2.5
Dry Cow 1 5
Heifer (3 months to calving) 0.7 5
Calf (birth to 3 months) 0.7 5
Iron
Beef and Dairy

The CFIA will proceed to keep the iron maximum value of 500 mg/kg for all cattle identified in the proposal. This should adequately account for variations in forages and varying production conditions and aligns with the MTL for all cattle reported at 500 mg/kg (NRC, 2005).

Summary of feedback - Manganese, Selenium and Zinc levels
Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement - Summary of feedback
Manganese (Mn) 3 1 2 - Questioned why the beef maximum value was set at 150 mg/kg for young animals when the MTL is set at 1000 mg/kg
Selenium (Se) 7 2 2 - Suggested that due to the intrinsic levels of Se in commonly used ingredients, the proposed maximum value would not provide any allowances for the addition of supplemental Se
2 - Proposed a maximum level of 2 mg Se/kg for all classes and went on to suggest that Se deficiency is a greater risk than toxicity and no human, animal or environmental issues exist with this level
1 - Suggested the proposed maximum value is not high enough to eliminate white muscle disease and went on to suggest that there are very few cases when 6 mg of Se/head/day is provided
Zinc (Zn) 6 1 2 - Questioned why the maximum value was so low for dry cows and calves. They went on to propose an increase to the maximum value of 150 mg/kg for all dairy classes.
2 - Proposed maximum value of 280 mg/kg for all classes
1 - Suggested Zn has benefits for hoof health and proposed to increase the maximum value to mirror the MTL

CFIA response

Manganese

The CFIA will proceed to increase the maximum values for manganese to 200 mg/kg DM for the young growing animals. No animal and human safety was identified with the increase. The maximum is ten times the requirements for cattle and adequate to account for the variations in forages.

Beef
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating cows 200 200
Dry pregnant cows & bred heifers 200 200
Growers (medium energy diet) 150 200
Growers (high energy diet) 150 200
Finishers 150 200
Calves (birth to weaning) 150 200
Red veal calves 150 200
Dairy

No comments were received indicating a concern with the Mn levels proposed for dairy cattle; as such the CFIA will proceed with the maximum values for Mn identified in the proposal.

Selenium

Setting maximums for selenium on a total diet rather than on an added selenium basis aligns with how the standards are set for all nutrients. Recent work by Environment and Climate Change Canada under the Chemical Management Plan highlights the need for risk management measures to reduce selenium releases caused or influenced by humans into water. This would include releases from agriculture, including releases from feed. A standard based on total selenium rather than added selenium limits inputs in feeds thereby reducing agricultural releases. It also addresses the need to limit selenium transfer to foods of animal origin. The CFIA provided Health Canada's Food Directorate with data on the transfer of selenium to foods of animal origin through feed. Health Canada has indicated that 1 mg/kg total selenium in the diet should not result in selenium levels in foods of animal origin of concern. The data provided by CFIA covered studies using both organic and inorganic sources of selenium in diets and accounted for intrinsic and added selenium identified in diets. Feedback from stakeholders indicated that a total selenium maximum of 1 mg/kg was achievable. The originally proposed total selenium maximum of 0.5 mg/kg total selenium in the diets of cattle will be amended to 1 mg/kg aligning with stakeholder feedback and Health Canada's assessment.

Beef
Class Proposed
(total mg/kg of diet DM)
Revised
(total mg/kg of diet DM)
Lactating cows 0.5 1
Dry pregnant cows & bred heifers 0.5 1
Growers (medium energy diet) 0.5 1
Growers (high energy diet) 0.5 1
Finishers 0.5 1
Calves (birth to weaning) 0.5 1
Red veal calves 0.5 1
Dairy
Class Proposed
(total mg/kg of diet DM)
Revised
(total mg/kg of diet DM)
Lactating Cow 0.5 1
Dry Cow 0.5 1
Heifer (3 months to calving) 0.5 1
Calf (birth to 3 months) 0.5 1
Zinc

The CFIA will proceed with increasing the maximum values for zinc to 280 mg/kg for all classes of beef cattle and to 280 mg/kg for dairy dry cows, heifers and calves. The maximum levels are about 10 times the requirements for cattle. Maximums are set lower than MTL to reduce antimicrobial resistance issues and environmental concerns.

Beef
Class Proposed
(mg/kg of diet DM)
Revised
(mg/kg of diet DM)
Lactating cows 150 280
Dry pregnant cows & bred heifers 150 280
Growers (medium energy diet) 150 280
Growers (high energy diet) 150 280
Finishers 150 280
Calves (birth to weaning) 200 280
Red veal calves 200 280
Dairy
Class Proposed
(% of diet DM)
Revised
(% of diet DM)
Lactating Cow 280 280
Dry Cow 130 280
Heifer (3 months to calving) 130 280
Calf (birth to 3 months) 200 280

Vitamins

Summary of feedback - Vitamin A, Vitamin D and Vitamin E levels
Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement - Summary of feedback
Vitamin A (Vit A) 7 2 2 - Proposed maximum value was too low which could lead to problem for heifers and calves. These respondents went on to say that there was no impact on the environment and questioned why the limits are tighter than before.
2 - Suggested there were no health and safety issues thus suggested to increase the maximum value to 33,000 IU/kg for all classes of cattle
1 - Suggested the proposed maximum value needs to account for degradation of supplements that will be fed free choice and left out in the elements
Vitamin D (Vit D) 6 2 2 - Suggested the maximum value was too low which could lead to problems for heifers and calves. These respondents went on to say that there was no impact on the environment and questioned why the limits are tighter than before.
2 - Proposed to increase the maximum value to 4,400 IU/kg for all classes of cattle
Vitamin E (Vit E) 8 0 3 - Suggested to maintain the current NRS level as the NRC indicates Vit E is one of the least toxic vitamins
2 - Proposed maximum value was too low which could lead to problem for heifers and calves. These respondents went on to say that there was no impact on the environment thus suggested to increase the maximum value for beef lactating and dry cow classes to the same level as those dairy classes, 150-200 IU/kg.
2 - Proposed maximum values of 200 IU/kg for the beef adult cattle classes (LT, DC, GM, GH, and F) and dairy LT class to stimulate immune function
1 - Suggested limitations in (dairy) dry cows may be a concern, especially with Se deficient areas

CFIA response

Vitamin A
Beef and Dairy

The CFIA will proceed to keep the maximum values for Vitamin A identified in the proposal. The maximum values (IU/kg diet DM), when expressed as IU/day are not more restrictive than the current Table 4 (expressed as IU/day).

Vitamin D
Beef and Dairy

The CFIA will proceed to keep the maximum values for Vitamin D identified in the proposal which align with the MTL (2,200 IU/kg DM).

Vitamin E

The CFIA will proceed with increasing the maximum values for Vitamin E to 200 IU/kg for all classes of beef and dairy cattle.

Beef
Class Proposed
(IU/kg diet DM)
Revised
(IU/kg diet DM)
Lactating cows 100 200
Dry pregnant cows & bred heifers 100 200
Growers (medium energy diet) 100 200
Growers (high energy diet) 100 200
Finishers 100 200
Calves (birth to weaning) 150 200
Red veal calves 150 200
Dairy
Class Proposed
(IU/Kg diet DM)
Revised
(IU/Kg diet DM)
Lactating Cow 80 200
Dry Cow 200 200
Heifer (3 months to calving) 80 200
Calf (birth to 3 months) 80 200

Additional respondent feedback

Additional nutrients and environmental antagonists

2 respondents identified additional nutrients to be included in the maximum value tables not already outlined in the proposal. 1 respondent felt Chromium should be included in the final maximum nutrient value table as the NRC 2016 recognizes Cr as an essential trace mineral for beef cattle.

In addition, 1 respondent felt that maximum values for Vitamin B should be included in the requirements. This respondent went on to recommend that a class for pre-ruminant calves be established in the final document.

3 respondents indicated a concern over antagonistic factors and their impacts on nutrient maximums. The respondents commented that the approach to express nutrient values on a diet DM basis ignores nutrient intake (especially Fe, salt (NaCl) and S) from water. In addition, respondents indicated that the antagonistic mineral interactions such as Cu, Mo and S can cause low bioavailability of nutrients thus increasing the need for elevated levels of nutrients beyond the proposed maximum values.

Regulations respecting customer formula feeds

In addition to the suggested amendments provided by stakeholders and summarized above, the CFIA received additional inquiries with respect to the future state of the customer formula exemption criteria. 6 respondents indicated a desire for CFIA to maintain the flexibility the current customer formula criteria currently provided to the industry, including having a provision for adding nutrients on a preventive basis to decrease the use of antibiotics and as an overall tool to customize feeds farm-to-farm based on producers' needs.

CFIA enforcement

Five (5) respondents commented on the CFIA anticipated enforcement approach with respect to the new total diet requirements. Concerns were expressed regarding the standards inspectors will use to determine compliance, especially when feeds are manufactured on-farm and when forage levels are such a large and variable component of the diet. Additionally, respondents expressed concern over the total diet requirements when the feed manufacturer can only control the portion they are manufacturing.

CFIA response

Chromium

More research is needed to set a requirement for chromium for beef cattle in various production settings and physiological stages as identified under research needs in the current Beef NRC (2016) including those for pre-ruminant calves.

The flexibility to modify the maximum nutrient requirements, including the addition of production phases as research developments and nutritional understanding progresses is a key benefit of incorporation by reference. A consultative process will be developed to ensure stakeholder involvement in such updates.

Some maximum nutrients levels have been increased to account for the antagonistic factors among minerals, as well as regional differences and minerals that could come from water, especially for pastured beef cattle.

Vitamin B

Cobalt maximum has been increased to account for vitamin B12 requirements/deficiencies in pre-ruminants. Pre-ruminants are captured under the beef calves class (C) as "birth to weaning" and for dairy (S) as birth to 3 months. The requirements and MTL levels for B vitamins in cattle are not well established to compute maximums at this time. The Dairy NRC (2001) and Beef NRC (2016) do not provide recommended B-vitamin allowances for cattle due to a lack of research on B-vitamin requirements. In general, B-vitamin requirements are met through synthesis by ruminal microorganisms and supplemental B vitamins are extensively degraded in the rumen.

Customer formula feeds

The primary use of the customer formula exemption currently allows manufacturers to formulate feeds, as per their customer's request, outside the Table 4 nutrient ranges without requiring premarket registration by the CFIA. As the nutrient ranges in Table 4 will be removed from the Regulations and replaced with a list of maximum nutrient values established in respect of animal health, human health and the protection of the environment, it is not anticipated that feeds will be permitted to be manufactured above the maximum values identified under any circumstances. For those stakeholders who do have a desire to manufacture feeds with one or more nutrients above the established maximum value(s), an application to amend the maximum value would be required to be submitted to the CFIA along with supporting data to substantiate the safety of this feed. See Consolidated Proposal, "Customer and Consultant Formula Feeds" under heading, "Permissions - Mixed Feeds".

Inspection and enforcement

Compliance verification and enforcement related to labeled nutrient guarantees relative to prescribed maximums would evaluate the information on the associated feed label including the directions for use indicating the amount of the mixed feed to be included in the total diet. The safe use of feeds is a shared responsibility; the directions for use on the labelled feed along with the guaranteed analysis when used together should result in values below prescribed maximums. Producers can make use of the labeled directions as well as knowledge of the nutrient contents of other components of their animals' diets to ensure that they are feeding below the maximums.

Next steps

The CFIA is preparing a formal regulatory proposal for publication in the Canada Gazette Part I which will incorporate the comments received on all the consultation proposals, public meetings, stakeholder workshops and submissions, and other outreach activities that have been used over the course of the project. A draft of the Maximum Nutrient Values in Beef and dairy Cattle Feeds will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I - Maximum nutrient values for beef cattle feeds

Beef cattle classes and average intakes: Dry matter (DM) basis
Class of beef cattle Class codes Range of total
dry matter intake
(kg DM/day) Table Note 3
Lactating cows LT 10 - 14
Dry pregnant cows (& bred heifers) DC 8 - 13
Growers (medium energy diet) GM 6 - 10
Growers (high energy diet) GH 6 - 10
Finishers F 9 - 12
Calves (birth to weaning) C 0.5 - 6
Red veal calves RV 5 - 7

Table Notes

Table Note 3

Total dry matter intakes on farms may be below or above these ranges.

Return to table note 3 referrer

Macro-minerals

Calcium (Ca)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
Lactating cows 1.5 2
Dry pregnant cows & bred heifers 1 2
Growers (medium energy diet) 1.5 2
Growers (high energy diet) 1.5 2
Finishers 1.5 2
Calves (birth to weaning) 1 2
Red veal calves 1.5 2
Phosphorus (P)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
All classes 0.7 0.7
Magnesium (Mg)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
All classes 0.4 0.6
Sodium (Na)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
Lactating cows 1.2 1.2
Dry pregnant cows & bred heifers 1.8 1.8
Growers (medium energy diet) 1.8 1.8
Growers (high energy diet) 1.8 1.8
Finishers 1.8 1.8
Calves (birth to weaning) 1.8 1.8
Red veal calves 1.8 1.8
Potassium (K)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
All classes 2 3
Sulfur (S)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
Lactating cows 0.5 0.5
Dry pregnant cows & bred heifers 0.5 0.5
Growers (medium energy diet) 0.5 0.5
Growers (high energy diet) 0.5 0.5
Finishers 0.3 0.5
Calves (birth to weaning) 0.3 0.5
Red veal calves 0.3 0.5

Trace minerals

Cobalt (Co)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cows 1 5
Dry pregnant cows & bred heifers 1 5
Growers (medium energy diet) 1 5
Growers (high energy diet) 1 5
Finishers 1 5
Calves (birth to weaning) 1 5
Red veal calves 1 5
Copper (Cu)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
All classes 30 40
Iodine (I)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cows 1.3 2.5
Dry pregnant cows & bred heifers 1.3 5
Growers (medium energy diet) 1.3 5
Growers (high energy diet) 1.3 5
Finishers 1.3 5
Calves (birth to weaning) 0.7 5
Red veal calves 0.7 5
Iron (Fe)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
All classes 500 500
Manganese (Mn)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cows 200 200
Dry pregnant cows & bred heifers 200 200
Growers (medium energy diet) 150 200
Growers (high energy diet) 150 200
Finishers 150 200
Calves (birth to weaning) 150 200
Red veal calves 150 200
Selenium (Se)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
All classes 0.5 1
Zinc (Zn)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cows 150 280
Dry pregnant cows & bred heifers 150 280
Growers (medium energy diet) 150 280
Growers (high energy diet) 150 280
Finishers 150 280
Calves (birth to weaning) 200 280
Red veal calves 200 280

Vitamins

Vitamin A
Class Proposed level
(IU/Kg of diet DM)
Revised level
(IU/Kg of diet DM)
All classes 10,000 10,000
Vitamin D
Class Proposed level
(IU/Kg of diet DM)
Revised level
(IU/Kg of diet DM)
All classes 2,200 2,200
Vitamin E
Class Proposed level
(IU/Kg of diet DM)
Revised level
(IU/Kg of diet DM)
Lactating cows 100 200
Dry pregnant cows & bred heifers 100 200
Growers (medium energy diet) 100 200
Growers (high energy diet) 100 200
Finishers 100 200
Calves (birth to weaning) 150 200
Red veal calves 150 200

Appendix II - Maximum nutrient values for dairy cattle feeds

Dairy cattle classes and average intakes: Dry matter (DM) basis
Class of dairy cattle Class codes Range of total
dry matter intake
(kg DM/day) Table Note 4
Lactating cow LT 10 - 30
Dry cow DC 6 - 15
Heifer (3 months to calving) H 3 - 15
Calf (birth to 3 months) C 0.5 - 3

Table Notes

Table Note 4

Total dry matter intakes on farms may be below or above these ranges.

Return to table note 4 referrer

Macro-minerals

Calcium (Ca)
Class Proposed level
(as % of diet DM)
Revised level
(as % of diet DM)
Lactating cow 1.5 2
Dry cow 1 2
Heifer (3 months to calving) 1.5 2
Calf (birth to 3 months) 1.5 2
Phosphorus (P)
Class Proposed level
(as % of diet DM)
Revised level
(as % of diet DM)
All classes 0.7 0.7
Magnesium (Mg)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
All classes 0.6 0.6
Sodium (Na)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
Lactating cow 1.2 1.2
Dry cow 1.8 1.8
Heifer (3 months to calving) 1.8 1.8
Calf (birth to 3 months) 1.8 1.8
Potassium (K)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
Lactating cow 3 3
Dry cow 2 2
Heifer (3 months to calving) 3 3
Calf (birth to 3 months) 3 3
Sulfur (S)
Class Proposed level
(% of diet DM)
Revised level
(% of diet DM)
All classes 0.5 0.5

Trace minerals

Cobalt (Co)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
All classes 1 5
Copper (Cu)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cow 40 40
Dry cow 40 40
Heifer (3 months to calving) 30 40
Calf (birth to 3 months) 30 40
Iodine (I)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cow 1.3 2.5
Dry cow 1 5
Heifer (3 months to calving) 0.7 5
Calf (birth to 3 months) 0.7 5
Iron (Fe)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
All classes 500 500
Manganese (Mn)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cow 150 150
Dry cow 250 250
Heifer (3 months to calving) 100 100
Calf (birth to 3 months) 200 200
Selenium (Se)
Class Proposed level
(total mg/kg of diet DM)
Revised level
(total mg/kg of diet DM)
All classes 0.5 1
Zinc (Zn)
Class Proposed level
(mg/kg of diet DM)
Revised level
(mg/kg of diet DM)
Lactating cow 280 280
Dry cow 130 280
Heifer (3 months to calving) 130 280
Calf (birth to 3 months) 200 280

Vitamins

Vitamin A
Class Proposed level
(IU/Kg of diet DM)
Revised level
(IU/Kg of diet DM)
Lactating cow 10,000 10,000
Dry cow 20,000 20,000
Heifer (3 months to calving) 10,000 10,000
Calf (birth to 3 months) 10,000 10,000
Vitamin D
Class Proposed level
(IU/Kg of diet DM)
Revised level
(IU/Kg of diet DM)
Lactating cow 2,200 2,200
Dry cow 2,200 2,200
Heifer (3 months to calving) 2,200 2,200
Calf (birth to 3 months) 1,500 1,500
Vitamin E
Class Proposed level
(IU/Kg of diet DM)
Revised level
(IU/Kg of diet DM)
Lactating cow 80 200
Dry cow 200 200
Heifer (3 months to calving) 80 200
Calf (birth to 3 months) 80 200
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