02.feb.07
Canadian Cattlemen: The Beef Magazine
Debbie Furber
http://www.agcanada.com/custompages/stories_story.aspx?mid=31&id=1106
In June the Canadian Food Inspection Agency (CFIA) announced it would move forward with regulations making it illegal to use Specified Risk Material (SRM) in all animal feed, pet food and fertilizer. This simple sentence states the facts of the enhanced feed ban but not the profound impact it will have on the industry.
The new regulations being phased in this year will affect producers, abattoirs, meat processors, deadstock collectors, rendering plants, feed and pet food manufacturers, fertilizer and fertilizer supplement manufacturers, food service outlets, landfill operators and our trading partners.
The cornerstone of the enhanced feed ban is a new permitting system to control the handling, transportation and disposal of SRM. CFIA wants continuous control over these tissues until they are either destroyed or disposed of in a manner that poses no further risk to animal health. The enhanced ban also satisfies the final recommendation of the international panel that reviewed Canada’s system for controlling BSE, and the world animal health organization’s criteria for a controlled-risk country under the new BSE-risk classification system.
On July 12, 2007, it will be illegal to move SRM to non-permitted premises. All federally inspected plants and large meat operations must also be ready to segregate and stain SRM. Smaller operations will have until January 30, 2008 to comply.
In Canada SRM is defined as the distal ileum of the small intestine from bovines of all ages, and the skull, brain, trigeminal ganglia (nerves attached to the brain), eyes , tonsils, spinal cord and dorsal root ganglia (nerves attached to the spinal cord) from over-30-month (OTM) cattle.
Two points of reference help put this into context at the farm level.
First, SRM can be in raw, rendered, composted or carcasses form. The regulations don’t differentiate between edible carcasses and deadstock. If SRM has not been removed, the whole carcass will be treated as an SRM. If SRM is not segregated from raw waste, the total volume must be handled as SRM.
Secondly, CFIA permits will be required to remove any SRM from the premise where it was generated. The transporter, either producer or commercial trucker, must have a permit to carry SRM. And the receiver, whether a butcher shop, renderer or landfill, must have a permit to accept them.
“It’s important that all players in the beef industry understand their obligations and responsibilities in controlling SRM,” says Greg Douglas, BSE veterinary program specialist with CFIA in Regina. “The CFIA will inspect, monitor, permit and enforce these regulations and may cooperate with local or provincial inspection agencies in regions where these synergies make sense.”
Producer responsibility
Abattoirs, which generate 92% of bovine waste and renderers who choose to process it, will bear the brunt of this policy. Bottom line, 41% of raw bovine waste will no longer be saleable.
The remaining 8% is deadstock. Farm operators are exempt from staining, segregating and permitting if the SRM is disposed of on their premises. But they still must maintain records of what they did with the SRM, Douglas says.
A premise extends beyond the immediate yardsite, corrals or pasture where the animal died to connected land owned and operated by the same legal entity. When a public road separates parcels of an operation it is still considered one premise.
Your first responsiblity is to obtain a permit from your district CFIA office if you plan to haul carcasses off your place. That would make you a transporter. Transporters and receivers must record the date the material is moved, their names and addresses, what dye was used to stain the SRM, the weight of SRM and OTM carcasses or sides containing dorsal root ganglia, and identification tag numbers from dead animals. These records must be kept for 10 years.
Records of feed ingredient purchases, including the amount, date, and supplier information, must be kept for 2 years. Purchase records, storage and on-farm processing may be inspected and audited to be sure they are in compliance with the ban.
When transporting SRM in any form it must be stained. Carcasses must be marked with a conspicuous stripe down the spine. No staining or permit is required for carcasses of UTM animals after the distal ileum has been removed.
You can use a tarp or heavy plastic container to contain edible carcasses, deadstock or offal during transport but it should be dedicated to this purpose and clearly marked with the CFIA permit number. Otherwise the vehicle has to be cleaned out and disinfected each time it is used to transport SRM. There are no between-load cleanout procedures for commercial transporters who use dedicated trucks or trailers marked with “SRM” on the outside.
Dicey situations
Douglas says CFIA will set up a service to provide off-hour permits to cover emergencies such as an animal dying in transit or transporting euthanized animals to a local butcher to salvage some meat.
Generally, farms will not be permitted to receive SRM. So when an animal dies somewhere other than on your premise you won’t be able to bring thecarcass back to the farm if it still contains SRM.
Moving edible carcasses off the farm for processing: You need a permit to transport carcasses containing SRM, and the cut and wrap shop will need one to receive SRM. It’s unlikely that other farms and food banks will qualify as SRM receivers.
Veterinary clinics: Moving dead animals and fetuses to a veterinary clinic for autopsy will require a permit. However, you won’t be able to get a permit to move SRM from the clinic back to the farm. When an animal dies at the clinic the veterinarian will have to dispose of the SRM on site or arrange to have it removed by a permitted shipper. UTM carcasses without the distal ileum and samples sent to a Level 2 veterinary pathology lab can be shipped without permit.
On pasture: Community pastures don’t require permits to dispose of dead animals as long as the carcass remains on the premise. If you rent private pasture, make sure you discuss terms for disposing of the carcass on site with the owner.
SRM generated in a stock trailer: An animal that dies in transit will be treated as SRM at its destination. It can’t be unloaded or transported to a receiver without staining and permitting.
Carcasses for show purposes: Entries in carcass classes will require a permit and must be maintained under a permit until they are delivered to a permitted SRM receiver.
Carcass or raw bovine waste to a municipal landfill: Landfills must be inspected and permitted to receive SRM from any source. To be approved, a landfill must have procedures in place to prevent exposure of the SRM to cattle and maintain control of the SRM. Research is underway to find other cost-effective methods of destroying SRM but it will take time to evaluate and develop them.
Salvage: While no SRM can be fed to any animal, non-SRM parts of cattle carcasses may be harvested and fed to non-food producing animals such as those on fur farms and zoos. Non-SRM bovine waste may still be used in the manufacture of animal feed (except for ruminants), pet food and fertilizer.
Hunting and road kill: Only bovine carcasses contain SRM. There are restrictions on the use of wild ruminants in ruminant feeds, however, wild ruminant products won’t be subject to these permitting requirements. If a bovine is hit on a roadway, it may be buried or composted on a contiguous premise if both belong to the same operator. Otherwise a permit will be required to move and dispose of it.
Plan ahead
Use up feed ingredient supplies on hand and purchase only those labeled SRM-free. Be aware that SRM-free doesn’t necessarily mean that the feed is free of prohibited material.
Put a mortality management plan in place for your operation. Be aware that municipal and provincial regulations for on-farm disposal vary from jurisdiction to jurisdiction.
Burial and composting are approved in Ontario, Manitoba, Saskatchewan and Alberta but open-fire burning is not (except in unusual circumstances, such as an anthrax outbreak). In Ontario scavenging is not allowed. Alberta is the only province with formal guidelines for natural disposal.
If on-farm disposal is not an option due to high water tables, light soil, rocky terrain, or proximity to neighbors, roads and water systems try your municipal land landfill or the nearest renderer.
Canadian Cattlemen: The Beef Magazine
Debbie Furber
http://www.agcanada.com/custompages/stories_story.aspx?mid=31&id=1106
In June the Canadian Food Inspection Agency (CFIA) announced it would move forward with regulations making it illegal to use Specified Risk Material (SRM) in all animal feed, pet food and fertilizer. This simple sentence states the facts of the enhanced feed ban but not the profound impact it will have on the industry.
The new regulations being phased in this year will affect producers, abattoirs, meat processors, deadstock collectors, rendering plants, feed and pet food manufacturers, fertilizer and fertilizer supplement manufacturers, food service outlets, landfill operators and our trading partners.
The cornerstone of the enhanced feed ban is a new permitting system to control the handling, transportation and disposal of SRM. CFIA wants continuous control over these tissues until they are either destroyed or disposed of in a manner that poses no further risk to animal health. The enhanced ban also satisfies the final recommendation of the international panel that reviewed Canada’s system for controlling BSE, and the world animal health organization’s criteria for a controlled-risk country under the new BSE-risk classification system.
On July 12, 2007, it will be illegal to move SRM to non-permitted premises. All federally inspected plants and large meat operations must also be ready to segregate and stain SRM. Smaller operations will have until January 30, 2008 to comply.
In Canada SRM is defined as the distal ileum of the small intestine from bovines of all ages, and the skull, brain, trigeminal ganglia (nerves attached to the brain), eyes , tonsils, spinal cord and dorsal root ganglia (nerves attached to the spinal cord) from over-30-month (OTM) cattle.
Two points of reference help put this into context at the farm level.
First, SRM can be in raw, rendered, composted or carcasses form. The regulations don’t differentiate between edible carcasses and deadstock. If SRM has not been removed, the whole carcass will be treated as an SRM. If SRM is not segregated from raw waste, the total volume must be handled as SRM.
Secondly, CFIA permits will be required to remove any SRM from the premise where it was generated. The transporter, either producer or commercial trucker, must have a permit to carry SRM. And the receiver, whether a butcher shop, renderer or landfill, must have a permit to accept them.
“It’s important that all players in the beef industry understand their obligations and responsibilities in controlling SRM,” says Greg Douglas, BSE veterinary program specialist with CFIA in Regina. “The CFIA will inspect, monitor, permit and enforce these regulations and may cooperate with local or provincial inspection agencies in regions where these synergies make sense.”
Producer responsibility
Abattoirs, which generate 92% of bovine waste and renderers who choose to process it, will bear the brunt of this policy. Bottom line, 41% of raw bovine waste will no longer be saleable.
The remaining 8% is deadstock. Farm operators are exempt from staining, segregating and permitting if the SRM is disposed of on their premises. But they still must maintain records of what they did with the SRM, Douglas says.
A premise extends beyond the immediate yardsite, corrals or pasture where the animal died to connected land owned and operated by the same legal entity. When a public road separates parcels of an operation it is still considered one premise.
Your first responsiblity is to obtain a permit from your district CFIA office if you plan to haul carcasses off your place. That would make you a transporter. Transporters and receivers must record the date the material is moved, their names and addresses, what dye was used to stain the SRM, the weight of SRM and OTM carcasses or sides containing dorsal root ganglia, and identification tag numbers from dead animals. These records must be kept for 10 years.
Records of feed ingredient purchases, including the amount, date, and supplier information, must be kept for 2 years. Purchase records, storage and on-farm processing may be inspected and audited to be sure they are in compliance with the ban.
When transporting SRM in any form it must be stained. Carcasses must be marked with a conspicuous stripe down the spine. No staining or permit is required for carcasses of UTM animals after the distal ileum has been removed.
You can use a tarp or heavy plastic container to contain edible carcasses, deadstock or offal during transport but it should be dedicated to this purpose and clearly marked with the CFIA permit number. Otherwise the vehicle has to be cleaned out and disinfected each time it is used to transport SRM. There are no between-load cleanout procedures for commercial transporters who use dedicated trucks or trailers marked with “SRM” on the outside.
Dicey situations
Douglas says CFIA will set up a service to provide off-hour permits to cover emergencies such as an animal dying in transit or transporting euthanized animals to a local butcher to salvage some meat.
Generally, farms will not be permitted to receive SRM. So when an animal dies somewhere other than on your premise you won’t be able to bring thecarcass back to the farm if it still contains SRM.
Moving edible carcasses off the farm for processing: You need a permit to transport carcasses containing SRM, and the cut and wrap shop will need one to receive SRM. It’s unlikely that other farms and food banks will qualify as SRM receivers.
Veterinary clinics: Moving dead animals and fetuses to a veterinary clinic for autopsy will require a permit. However, you won’t be able to get a permit to move SRM from the clinic back to the farm. When an animal dies at the clinic the veterinarian will have to dispose of the SRM on site or arrange to have it removed by a permitted shipper. UTM carcasses without the distal ileum and samples sent to a Level 2 veterinary pathology lab can be shipped without permit.
On pasture: Community pastures don’t require permits to dispose of dead animals as long as the carcass remains on the premise. If you rent private pasture, make sure you discuss terms for disposing of the carcass on site with the owner.
SRM generated in a stock trailer: An animal that dies in transit will be treated as SRM at its destination. It can’t be unloaded or transported to a receiver without staining and permitting.
Carcasses for show purposes: Entries in carcass classes will require a permit and must be maintained under a permit until they are delivered to a permitted SRM receiver.
Carcass or raw bovine waste to a municipal landfill: Landfills must be inspected and permitted to receive SRM from any source. To be approved, a landfill must have procedures in place to prevent exposure of the SRM to cattle and maintain control of the SRM. Research is underway to find other cost-effective methods of destroying SRM but it will take time to evaluate and develop them.
Salvage: While no SRM can be fed to any animal, non-SRM parts of cattle carcasses may be harvested and fed to non-food producing animals such as those on fur farms and zoos. Non-SRM bovine waste may still be used in the manufacture of animal feed (except for ruminants), pet food and fertilizer.
Hunting and road kill: Only bovine carcasses contain SRM. There are restrictions on the use of wild ruminants in ruminant feeds, however, wild ruminant products won’t be subject to these permitting requirements. If a bovine is hit on a roadway, it may be buried or composted on a contiguous premise if both belong to the same operator. Otherwise a permit will be required to move and dispose of it.
Plan ahead
Use up feed ingredient supplies on hand and purchase only those labeled SRM-free. Be aware that SRM-free doesn’t necessarily mean that the feed is free of prohibited material.
Put a mortality management plan in place for your operation. Be aware that municipal and provincial regulations for on-farm disposal vary from jurisdiction to jurisdiction.
Burial and composting are approved in Ontario, Manitoba, Saskatchewan and Alberta but open-fire burning is not (except in unusual circumstances, such as an anthrax outbreak). In Ontario scavenging is not allowed. Alberta is the only province with formal guidelines for natural disposal.
If on-farm disposal is not an option due to high water tables, light soil, rocky terrain, or proximity to neighbors, roads and water systems try your municipal land landfill or the nearest renderer.
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