The proposed amendments prohibit the use of specified risk materials (SRMs) in animal feeds, including pet food. SRMs are defined in the proposal as the skull, brain, trigeminal ganglia, eyes, tonsils, spinal cord, and dorsal root ganglia of cattle 30 months of age or older, and the distal ileum of cattle of all ages. These tissues may contain the agent that causes BSE. The Government of Canada already requires the removal of SRMs from the human food supply, which is the most effective measure that can be taken to protect public health from BSE.
As a precautionary measure, the government implemented a feed ban in 1997 prohibiting the feeding of most mammalian proteins to ruminant animals. According to CFIA, preventing SRMs from entering the feed production chain enhances the existing feed ban by diminishing the effects of potential cross-contamination of animal feeds that could occur as feed is produced and distributed, as well as any inappropriate on-farm use.
The amendments also prohibit the use of SRMs in fertilizers. This provision is intended to prevent the potential accidental or intentional misuse of fertilizers as feed. As well, it addresses the possibility that contaminated grazing pastures could spread BSE, although the current science surrounding the environmental behavior of the disease is incomplete.
The proposed regulations have been placed in the Canada Gazette Part 1. A 75-day comment period ending February 24, 2005, is being provided to give regulated industries, trading partners, and other interested parties the opportunity to review the proposed amendments and provide CFIA with written comments. This comment period builds on extensive consultations undertaken during the development of the amendments. Copies of the proposed amendments can be found on the CFIA’s Web site at www.inspection.gc.ca, on the Canada Gazette Web site at www.canadagazette.gc.ca, or by contacting the CFIA at (613) 225-2342. The Canadian Renderers Association and individual Canadian rendering companies intend to respond to the proposed amendments and urge individual U.S. rendering and animal agriculture companies to submit written comments to CFIA.
Costs of Proposed Controls
CFIA estimates the annual costs to industry of the proposed SRM ban to range from $20 million to $27 million (Canadian), which represents up to 0.1 percent of beef production’s contribution (approximately $20 billion in 2003) to the Canadian economy. For SRMs removed at beef processing plants, the ongoing costs in the short run are expected to be comprised of the costs of operating a separate inedible by-product line within beef processing plants (that are already required to remove SRMs from the carcass), plus the cost of segregated transportation from the beef plant in many cases to a primary treatment facility, plus marginal increase of SRM processing (e.g., rendering) cost, plus the cost of disposing of meat and bone meal, plus the loss of value from meat and bone meal sales for feed or fertilizer (net of meat and bone meal production costs no longer incurred by that enterprise).
The proposed regulations would require that when the carcass of a ruminant animal that dies on farm, or its constituent parts or products derived from it, leaves the farm, the receiver of that carcass must operate under a CFIA-issued permit. For dead stock removed from the farm, these ongoing costs associated with the proposed regulations would be comprised of dead stock pickup/transportation costs, plus marginal increase in processing (e.g., rendering) cost, plus the cost of disposing of meat and bone meal, plus the loss of value from meat and bone meal sales for feed or fertilizer (net of production costs no longer incurred by that enterprise).
CFIA estimates, collectively, some 170,000 tons of raw SRMs might be generated annually in Canada that would require redirection from animal food uses. If all this material were to be rendered, some 44,000 tons of meat and bone meal would remain and need to be destroyed, disposed of, or used in an alternative fashion. To put this volume into context from a waste management perspective, it is also estimated that each household in Canada generates some 750 kilograms (kg) to 1,000 kg (where 1,000 kg equals one ton) of solid waste per year. For the estimated 11,000,000 households in Canada, upwards of 11,000,000 tons of solid waste is being generated and managed in Canada annually.
In some regions, dead stock pickup and/or rendering are already relatively uneconomical or in short supply. In these situations, burial at a cost of approximately $38 (Canadian) per ton or landfill at about $75 per ton may be more economical than rendering. However, the costs and relative availability of such disposal alternatives varies across the country and by jurisdiction.
In recognition of the multi-jurisdictional and varied nature of these challenges, in parallel with these proposed amendments, federal/provincial/territorial ministers of agriculture have initiated a separate process, led by Agriculture and Agri-Food Canada, to identify the most efficient and environmentally acceptable SRM disposal options by province/territory. It is also important to note that the proposed amendments provide scope for adopting alternative uses of SRMs (e.g., in cement production or co-generation of energy) that have the potential to either reduce the disposal cost or even to generate new revenue streams for the beef industry over the medium to long run.
Costs to governments are expected to approach those incurred by the beef value chain. For the CFIA, based on the proposed amendments, it has been estimated that the annual cost of providing inspection oversight and program verification would be $23 million to $27 million.
International Report - February 2005 Render