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Proposal - Maximum Nutrient Values for Beef and Dairy Cattle Feeds

Purpose

As part of a comprehensive, multi-year regulatory modernization process, the Canadian Food Inspection Agency (CFIA) has initiated the renewal of the federal Feeds Regulations (Regulations) as one of several priorities identified for modernization.

The goal of renewing the Regulations is to develop a modernized risk- and outcome - based regulatory framework for feeds which:

Modernization of the Regulations provides the opportunity to review feed controls, standards, labelling and other regulatory requirements. The purpose of this proposal is to:

Background and Current Situation

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 mandatory registration. The original Table 4 established nutrient ranges (minimums and maximums) as exemption criteria for feeds for chickens, turkeys, swine, beef and dairy cattle, and sheep. In 1990, via two regulatory amendments, the table was first expanded to include horses, goats, ducks, and geese; and then for rabbits, mink, and salmonid fish. Since that time, there have been no other substantive changes to the table or to any of the nutrient ranges.

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.

In the case of beef and dairy cattle feeds, the original Table 4 established nutrient ranges in complete feed (grain portion) only. However, the National Research Council (2001, 2007, and 2016) report nutrient requirements for dairy cattle, beef cattle, and small ruminants on a total diet dry matter basis. Many factors – breed, size, reproduction stage, lactating stage, climate, type of forages and grains, on-farm feed management and practices, environmental conditions among others – have an impact on the variability of the daily feed intake. As total daily ration for ruminants includes forages, establishing nutrient ranges on the basis of complete feeds only does not take into consideration the nutrient contribution from the forage portion of the total daily diets and may lead to over supplementation of certain nutrients especially when the forages contain high level of nutrients and constitute a greater proportion of the daily diets.

As indicated in the Feed Regulatory Renewal Consolidated Modernized Framework Proposal, both the CFIA and stakeholders recognize that some of the values in Table 4 may no longer have the same nutritional relevancy that they did when the table was first introduced. Stakeholders have also indicated that they feel that Table 4 prevents innovation for new feed products. However, many of the maximum nutrient levels which are currently set out in Table 4 have health and safety implications that must be considered.

Proposal

It is proposed that:

  1. Table 4 be removed from the Regulations and no longer serve as a trigger to register feeds based on specified ranges of nutrient content;
  2. maximum nutrient levels be established and incorporated by reference for beef and dairy cattle feeds; and,
  3. proposed maximums are established based on total daily diets rather than for complete feeds only.

This proposed approach addresses stakeholder concerns regarding Table 4 and its relevance in current industry practices, as well as claims that the nutrient ranges provided in Table 4 impede new products from entering the marketplace. Furthermore, it addresses concerns regarding the harmful impact that higher levels of certain nutrients may have on livestock or the resulting food products, and underscores the modernized regulatory framework's focus on health and safety for humans, animals, and the environment. It is further proposed that:

Considerations

The domestic feed industry considers that the Table 4 nutrient ranges are out of date, and that this table is no longer an appropriate regulatory tool for feeds. However, there remains a continued need for an enforceable regulatory framework regarding maximum nutrient concentrations in livestock feeds for health and safety reasons. For instance, levels of certain vitamins in livestock rations (e.g., vitamins A, D, and E) in excess of nutritional requirements can be harmful to livestock or can be concentrated into tissues that are used for human consumption, thus posing potential risk to human health. Similarly, certain minerals (e.g., copper, iodine, phosphorus and zinc) fed in excess of livestock requirements can also contribute to increased human and environmental risks.

A significant proportion of minerals fed in excess of requirements are excreted into the environment via urine and feces. Consequently, even though the maximum tolerable level (MTL) of a given mineral may be significantly greater than the nutritional level, feeding at the maximum tolerable level may result in negative impact on the environment.

An analysis of beef and dairy cattle nutritional requirements and maximum tolerable dietary nutrient levels was conducted by the CFIA to determine:

Information sources used in the review and development of nutrient maximums in beef and dairy cattle feeds included:

Appendix I sets out the proposed maximum nutrient values for beef cattle feeds.
Appendix II sets out the proposed maximum nutrient values for dairy cattle feeds.

The current Table 4 nutrient values to exempt feeds from registration, are for the complete feed (grain portion of diets only) on an "as fed" basis (assumed 90% dry matter), assuming a fixed intake for all classes of cattle. In contrast, the proposed maximum nutrient levels are to be applied to the total dietary intake. These proposed maximums were derived taking into consideration typical total daily diets for the various classes of cattle and ranges for nutrient content of the forages (where known) as well as complete feeds (grain portion) and are reported on a "dry matter" basis. The proposed maximum nutrient concentration in the daily diet has been set high enough to provide flexibility to formulate nutritionally and environmentally sound diets. Where practical, classes of dairy or beef cattle with similar maximums have been grouped or a common and rounded nutrient value is presented across all classes.

While the NRC requirements for vitamins are on a supplemental basis and the maximum values indicated in this proposal are on a total diet DM basis, the proposed values are over and above the NRC requirements such that contributions from the grain and forages, though variable, would not result in values exceeding the stated maximums.

In some cases, the highest values generated have been used as the maximum level for all classes, if there were no known food safety or environmental safety issues for any particular class. For others, where the MTLs have been exceeded, the MTLs have been used as the maximum safety values for that class of cattle. Notes on some of the considerations incorporated into setting the maximum value are provided at the bottom of the tables for each nutrient in the Appendices.

Anticipated Outcomes

This modernized regulatory approach to the oversight of maximum nutrient content in beef and dairy cattle feeds would:

While this proposal is specific to beef and dairy cattle feeds, future proposals will be developed for additional species subject to the Feeds Regulations and include proposed maximum nutrient values for the species in question.

Stakeholders will be provided with an opportunity to comment on all proposals, including the maximum nutrient values being suggested for each species or class of species, before they are incorporated into a regulatory framework.

References: A complete bibliography is available upon request

Have your say

The CFIA is seeking feedback on the proposal to modify the regulatory requirements related to maximum nutrient content in livestock feed:

  • Do you have any concerns with the proposal to remove the Table 4 nutrient levels from the Feeds Regulations and no longer exempting feeds from registration based on the nutrient content of the feeds?
  • Do you have any concerns with the proposal to establish maximum nutrient values for livestock feeds?
  • Do you have any concerns with the proposed maximum nutrient values outlined in Appendix I and II for beef and dairy cattle feeds, respectively?
  • Would the proposed amendments to the Feeds Regulations be effective in protecting human and animal health and the environment?
  • Are there options not mentioned in this proposal that should be explored?
  • Any additional feedback?

We strongly encourage you to provide your input and feedback, which is critically important to the success of the regulatory modernization initiative. Please send written comments by August, 18th, 2017 to:

Sergio Tolusso
Canadian Food Inspection Agency
Animal Feed Division
59 Camelot Drive
Ottawa, ON K1A 0Y9
Email: Sergio.tolusso@inspection.gc.ca
Fax: 613-773-7565

Appendix I – Proposed Maximum Nutrient Values for Beef Cattle Feeds

Beef Cattle Classes and Average Intakes: (Dry Matter Basis (DM)) Table Note 1 , Table Note 2 , Table Note 3
Class of Beef Cattle Class Codes Total
Dry Matter Intake
(kg DM/day)
Complete Feed
Intake
(kg DM/day)
Forage
Intake
(kg DM/day)
Lactating cow, 600 kg, mature cow from calving to weaning of calf at 6 mo. of age LT 13.5 2 11.5
Dry pregnant cow, 600 kg, mature cow from weaning of calf to calving DC 12 1 11
Growers, medium energy diet, ≥ 80% forage, 350 kg, includes growing and replacement cattle (including bulls) GM 9 2 7
Growers, high energy diet, 30 to 70% forage, 350 kg, weaning to 1 year of age, includes growing cattle (including bulls) GH 9 5 4
Finishers, high energy, ≤ 20% forage, 450 kg, includes growing cattle, yearling cattle and bulls F 11 10 1
Calves, birth to weaning at 6 months of age, < 200 kg C 5 1.5 3.5
Red veal calves, market weight 200 to 300 kg RV 6 6 0

Table Notes

Table Note 1

Intakes may vary under different production situations; maximum intakes may exceed average intakes.

Return to table note 1 referrer

Table Note 2

Assumption: Dry matter content of complete feeds at 90%.

Return to table note 2 referrer

Table Note 3

Adapted from Revised Beef Table 4 recommendations (Beauchemin and Koenig, 2006, 2009).

Return to table note 3 referrer

Macro-minerals

Calcium (Ca)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 2 1.5
DC 2 1.0
GM, GH 2 1.5
F 2 1.5
C 2 1.0
RV 2 1.5

Rationale:

Phosphorus (P)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 1 0.7
DC 1 0.7
GM, GH 1 0.7
F 1 0.7
C 1 0.7
RV 1 0.7

Rationale:

Magnesium (Mg)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 0.5 0.4
DC 0.5 0.4
GM, GH 0.5 0.4
F 0.5 0.4
C 0.5 0.4
RV 0.5 0.4

Rationale:

Sodium (Na)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 2.4 1.2
DC 2.4 1.8
GM, GH 2.4 1.8
F 2.4 1.8
C 2.4 1.8
RV 2.4 1.8

Rationale:

Potassium (K)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 3 2
DC 3 2
GM, GH 3 2
F 3 2
C 3 2
RV 3 2

Rationale:

Sulfur (S)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 0.4 0.5
DC 0.4 0.5
GM, GH 0.4 0.5
F 0.4 0.3
C 0.4 0.3
RV 0.4 0.3

Rationale:

Trace Minerals

Cobalt (Co)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 10 1
DC 10 1
GM, GH 10 1
F 10 1
C 10 1
RV 10 1

Rationale:

Copper (Cu)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 50 30
DC 50 30
GM, GH 50 30
F 50 30
C 50 30
RV 50 30

Rationale:

Iodine (I)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 10 1.3
DC 10 1.3
GM, GH 10 1.3
F 10 1.3
C 10 0.7
RV 10 0.7

Rationale:

Iron (Fe)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 750 500
DC 750 500
GM, GH 750 500
F 750 500
C 750 500
RV 750 500

Rationale:

Manganese (Mn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 200 200
DC 200 200
GM, GH 200 150
F 200 150
C 200 150
RV 200 150

Rationale:

Selenium (Se)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 0.3 0.5
DC 0.3 0.5
GM, GH 0.3 0.5
F 0.3 0.5
C 0.3 0.5
RV 0.3 0.5

Rationale:

Zinc (Zn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 250 150
DC 250 150
GM, GH 250 150
F 250 150
C 250 200
RV 250 200

Rationale:

Vitamins

Vitamin A
Class Current
(IU/day)
Proposed
(IU/kg of diet DM)
LT 100,000 10,000
DC 100,000 10,000
GM, GH 100,000 10,000
F 100,000 10,000
C 100,000 10,000
RV 100,000 10,000

Rationale:

Vitamin D
Class Current
(IU/day)
Proposed
(IU/kg of diet DM)
LT 33,000 2,200
DC 33,000 2,200
GM, GH 33,000 2,200
F 33,000 2,200
C 33,000 2,200
RV 33,000 2,200

Rationale:

Vitamin E
Class Current
(IU/day)
Proposed
(IU/kg of diet DM)
LT NRS 100
DC NRS 100
GM, GH NRS 100
F NRS 100
C NRS 150
RV NRS 150

Rationale:

Appendix II – Proposed Maximum Nutrient Values for Dairy Cattle Feeds

Dairy Cattle Classes and Average Intakes: (Dry Matter Basis) Table Note 4, Table Note 5, Table Note 6
Class of Dairy Cattle Class Codes Total
Dry Matter Intake
(kg DM/day)
Complete Feed
Intake
(kg DM/day)
Forage
Intake
(kg DM/day)
Lactating Cow LT 23 11.5 11.5
Dry Cow DC 12 2 10
Heifer (3 months to calving) H 7 2 5
Calf (birth to 3 months) C 2.5 2 0.5

Table Notes

Table Note 4

Intakes may vary under different production situations; maximum intakes may exceed average intakes

Return to table note 4 referrer

Table Note 5

Assumption: Dry matter content of complete feeds at 90%.

Return to table note 5 referrer

Table Note 6

Adapted from Revised Dairy Cattle Table 4 recommendations (Beauchemin and Koenig, 2006, 2009)

Return to table note 6 referrer

Macro-minerals

Calcium (Ca)
Class Current
(% of complete feed, as fed)
Proposed
(as % of diet DM)
LT 2.5 1.5
DC 2.5 1.0
H 2.5 1.5
C 2.5 1.5

Rationale:

Phosphorus (P)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 1.3 0.7
DC 1.3 0.7
H 1.3 0.7
C 1.3 0.7

Rationale:

Magnesium (Mg)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 1.0 0.6
DC 1.0 0.6
H 1.0 0.6
C 1.0 0.6

Rationale:

Sodium (Na)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 2.4 1.2
DC 2.4 1.8
H 2.4 1.8
C 2.4 1.8

Rationale:

Potassium (K)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 3 3.0
DC 3 2.0
H 3 3.0
C 3 3.0

Rationale:

Sulfur (S)
Class Current
(% of complete feed, as fed)
Proposed
(% of diet DM)
LT 0.5 0.5
DC 0.5 0.5
H 0.5 0.5
C 0.5 0.5

Rationale:

Trace Minerals

Cobalt (Co)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 10 1.0
DC 10 1.0
H 10 1.0
C 10 1.0

Rationale:

Copper (Cu)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 100 40
DC 100 40
H 100 30
C 100 30

Rationale:

Iodine (I)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 10 1.3
DC 10 1.0
H 10 0.7
C 10 0.7

Rationale:

Iron (Fe)
Class Current
(mg/kg of complete feed as fed)
Proposed
(mg/kg of diet DM)
LT 50 500
DC 50 500
H 50 500
C 50 500

Rationale:

Manganese (Mn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 300 150
DC 300 250
H 300 100
C 300 200

Rationale:

Selenium (Se)
Class Current
(mg/kg of complete feed as fed)
Proposed
(mg/kg of diet DM)
LT 0.3 0.5
DC 0.3 0.5
H 0.3 0.5
C 0.3 0.5

Rationale:

Zinc (Zn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of diet DM)
LT 500 280
DC 500 130
H 500 130
C 500 200

Rationale:

Vitamins

Vitamin A
Class Current
(IU/day)
Proposed
(IU/kg of diet DM)
LT 200,000 10,000
DC 200,000 20,000
H 200,000 10,000
C 200,000 10,000

Rationale:

Vitamin D
Class Current
(IU/day)
Proposed
(IU/kg of diet DM)
LT 33,000 2,200
DC 33,000 2,200
H 33,000 2,200
C 33,000 1,500

Rationale:

Vitamin E
Class Current
(IU/day)
Proposed
(IU/kg of diet DM)
LT NRS 80
DC NRS 200
H NRS 80
C NRS 80

Rationale:

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