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Proposal – Maximum Nutrient Values in Horse Feeds

July 2018

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, the feed can be exempted from registration if:

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. However, complete feeds intended for feeding to livestock not intended for human consumption and which are in packages up to 5 kg are exempt from any requirements of the Feeds Act and Regulations altogether.

In the case of horse feeds, the original Table 4 established nutrient ranges for complete feed (grain portion) only. However, the National Research Council's Nutrient Requirements of Horses (2007) ("NRC") reports several nutrient requirements for horses 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 the total daily ration for horses 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 levels 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:

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

There remains a 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 (for example, 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 (for example, 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 a negative impact on the environment.

An analysis of horse nutritional requirements and maximum tolerable dietary nutrient levels was conducted by the CFIA with the following scope:

Information sources used in the review and development of nutrient maximums in horse feeds included:

Appendix I setsout the proposed maximum nutrient values for horse 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 horses. 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 horses 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.

While the NRC requirements for vitamins are on a supplemental basis and the maximum values indicated in this proposal are on a total diet dry matter 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.

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 Appendix.

Anticipated outcomes

This modernized regulatory approach to the oversight of maximum nutrient content in horse feeds would:

Stakeholders are being 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 for horse feeds?
  • Do you have any concerns with raising the exemption for complete feeds not intended for food-producing animals in packages containing up to 5 kg to packages containing up to 10 kg?
  • 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 08/17/18 to:

Sergio Tolusso
Canadian Food Inspection Agency
Animal Feed Division
59 Camelot Drive
Ottawa, ON K1A 0Y9

Email: Sergio.tolusso@canada.ca
Fax: 613-773-7565

Appendix I – Proposed maximum nutrient values for horse feeds

Horse classes and average intakes: (dry matter basis (DM))
Class Range of DM intake
(% body weight (BW))Table note 1
Forages
Horses (Mature and growing) 1.5 to 3.2 Up to 90%

Table Note

Table Note 1

Adapted from NRC (2007). Nutritional Requirements of Horses Sixth Revised Edition. Washington, DC, The National Academies Press.

Return to table note 1  referrer

Macro-minerals

Calcium (Ca)
Class Current
(% of complete feed, as fed)
Proposed
(% of total diet DM)
Horse (All) 2 2

Considerations:

Phosphorus (P)
Class Current
(% of complete feed, as fed)
Proposed
(% of total diet DM)
Horse (All) 2 1

Considerations:

Magnesium (Mg)
Class Current
(% of complete feed, as fed)
Proposed
(% of total diet DM)
Horse (All) 0.3 0.8

Considerations:

Sodium (Na)
Class Current
(% of complete feed, as fed)
Proposed
(% of total diet DM)
Horse (All) 1.2 2.4

Considerations:

Potassium (K)
Class Current
(% of complete feed, as fed)
Proposed
(% of total diet DM)
Horse (All) 3 3

Considerations:

Sulfur (S)
Class Current
(% of complete feed, as fed)
Proposed
(% of total diet DM)
Horse (All) NRS (No requirement specified) 0.5

Considerations:

Trace minerals

Cobalt (Co)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Horse (All) 10 1

Considerations:

Copper (Cu)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Horse (All) 125 125

Considerations:

Iodine (I)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Pregnant and lactating mares Not applicable (N/A) 3
Horse (All others) 2.5 4

Considerations:

Iron (Fe)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Horse (All) 500 500

Considerations:

Manganese (Mn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Horse (All) 400 150

Considerations:

Selenium (Se)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Horse (All) No requirement specified (NRS) 1.0 (total)

Considerations:

Zinc (Zn)
Class Current
(mg/kg of complete feed, as fed)
Proposed
(mg/kg of total diet DM)
Horse (All) 500 150

Considerations:

Vitamins

Vitamin A
Class Current
(IU/kg)
Proposed
(IU/kg of total diet DM)
Horse (All) 40,000 16,000

Considerations:

Vitamin D
Class Current
(IU/kg)
Proposed
(IU/kg of total diet DM)
Horse (All) 5,000 4,000

Rationale:

Vitamin E
Class Current
(IU/kg)
Proposed
(IU/kg of total diet DM)
Horses No requirement specified (NRS) 2400

Considerations:

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