Change Over to Specified Risk Material (SRM) Removed Meat and Bone Meal (MBM) in Feed Production

The enhanced feed ban regulations which came into force on July 12, 2007, are intended to eliminate the potential for cross-contamination by completely removing SRM from animal feed, pet food and fertilizer.

CFIA's position regarding the change over in feed mills to achieve compliance with the enhanced requirements recognizes that the complete removal of SRM from the entire feed production system will further reduce the risk of cross-contamination. The combination of the original restrictions and the enhanced requirements provides a double barrier against BSE exposure for ruminant given that SRM-removed ruminant MBM cannot be fed to ruminants as it continues to be a prohibited material for ruminant feeding.

In order for the feed industry to meet the requirements under the enhanced feed ban regulations and assure clients that their products do not contain MBM with SRM, they will need to provide reasonable assurances that the SRM-containing MBM currently in the system has been removed in a manner accepted by the CFIA. In either of the scenarios mentioned below, the objective is to ensure bins, equipment and conveyances are free from SRM ruminant MBM or feed containing SRM ruminant MBM.

Items 1 and 2 below outline CFIA's considerations regarding the manner in which this can be acceptably accomplished at commercial feed manufacturers. The use of other methodology to achieve similar outcomes will be considered. The feed industry should submit such proposals to the CFIA for endorsement prior to their being undertaken. The approved proposal may also be applied in premises where, after an acceptable flush, SRM-containing MBM is accidentally or otherwise re-introduced into the system.

Verification

To maintain uniformity across all feed production facilities (Feed Assure™ and non Feed Assure™ facilities) the SRM-Removal Inspection Form would be used. The SRM-Removal Inspection Form should be dated and signed by the Production Supervisor or designate.

1. Changeover to SRM-removed ruminant MBM use after demonstrated non-use of SRM-containing ruminant MBM in a feed mill

The feed mill must demonstrate that SRM-containing ruminant MBM has not been stored or used in the facility for a minimum of 10 days of operation prior to changeover to the use of SRM-removed MBM only (i.e., all inventory cleared from the facility). The feed mill must have documented records to demonstrate that all storage bins and compartments have been emptied of all materials containing ruminant MBM and cleaned according to the following cleaning protocol:

Cleaning Protocol:

To maintain uniformity across all feed production facilities CFIA expects operators to employ very similar measures as those outlined below. If not, prior review and approval of procedures that deviate from those below by CFIA would be required before the flush out is undertaken.

Storage Bins and Compartments:

Visual Inspection:

A visual inspection of each storage bin will identify if there are residues in the bin.

Procedure:

1. If during the inspection a bin is found to be in an unacceptable condition, (i.e. hung up or bridged material or build-up on walls and ceiling is present) the bin must be cleaned before being refilled.
2. Personnel, using shovels, brooms, scrapers, air pressure, vibration, etc. and in accordance with confined space safe work procedures, will thoroughly clean the designated bin. Personnel will sign off on a SRM Removal Inspection Form when completed.
3. The completed clean-out inspection SRM Removal Inspection Form is filed in the appropriate folder in the Production Supervisor's office.

Documentation should demonstrate that there has been no storage of SRM-containing ruminant MBM on the premises in this period. The documentation must identify all materials which have been processed through the system subsequent to the last use of SRM-containing ruminant MBM and that such processing represents a minimum of 10 days of operation. Where the documented evidence demonstrates that the above conditions have been met, the system will be deemed to have achieved adequate flush out of SRM-containing ruminant MBM and an additional validation step is not considered necessary by the CFIA.

2. Immediate Changeover to SRM-removed ruminant MBM use in a feed mill

This applies to premises in which SRM-containing ruminant MBM has been used in the facility prior to changeover to the use of SRM-removed ruminant MBM and the conditions noted under Item #1 above cannot be met.

In this case, parts A and B of the below Cleaning Protocol apply. However, a validation step is necessary.

Cleaning Protocol:

To maintain uniformity across all feed production facilities CFIA would anticipate operators would employ very similar measures as those proposed below. If not, prior review and approval of procedures that deviate from those below by CFIA would be required before the flush out is undertaken.

A. Storage Bins and Compartments

Visual Inspection:

A visual inspection of each storage bin will identify if there are residues in the bin.

Procedure:

1. If during the inspection a bin is found to be in an unacceptable condition, (i.e. hung up or bridged material or build-up on walls and ceiling is present) the bin must be cleaned before being refilled.
2. Personnel, using shovels, brooms, scrapers, air pressure, vibration, etc. and in accordance with confined space safe work procedures, will thoroughly clean the designated bin. Personnel will sign off on a SRM Removal Inspection Form when completed.
3. The completed clean-out inspection SRM Removal Inspection Form is filed in the appropriate folder in the Production Supervisor's office.

B. Equipment and Conveyances

Appropriate flushing of feed mill equipment (not bins).

Visual Inspection:

Where possible and in consideration of safety and accessibility of equipment, a visual inspection will be performed to identify if there are any residue in the equipment.

1. Equipment within reach (pellet mill, cooler) will be cleaned manually in an appropriate manner with necessary aid to remove all residue found during the visual inspection.
2. Equipment not within reach must be flushed with an appropriate material not containing prohibited material through all equipment and conveyances to ensure that the manufacturing path has been flushed out and to eliminate any residues of such prohibited material. This includes pneumatic lines, augers, pelleting equipment, drag conveyors, elevators and baggers.

Validation:

In order to validate the effectiveness of the flush out procedures as noted above, testing of feeds manufactured following the completion of the flush out procedure must be undertaken to demonstrate the effectiveness of the measures taken.
The use of biological, chemical or physical tracers will be accepted when an appropriate methodology to detect the identified tracer can be applied to subsequent lots of feed at a limit of detection of at least 0.1%. In addition, information indicating that the performance of the tracer is equivalent to the performance of ruminant MBM in a feed manufacturing system will also need to be provided.

Results from testing for the subject tracer must demonstrate the non-detection of the tracer in at least 5 successive lots manufactured after the flush out procedure in order for the system to be deemed to have achieved adequate removal of ruminant MBM.

For information regarding other acceptable methods, industry should contact the CFIA.