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Canadian Sheep Federation Response to Canadian Food
Inspection Agency’s Information Paper:
Development of Specific Regulatory Enhancements to Canada’s BSE
Feed Controls.
December 5, 2004
Purpose
The purpose of this document is to identify the concerns of the Canadian
Sheep Federation and our membership in regards to the "Development
of Specific Regulatory Enhancements to the Canada’s BSE Feed Controls"
published by the CFIA September 2004.
While there will be opportunity to comment on the regulatory proposal
after it is published in the Canada Gazette, however, the Canadian Sheep
Federation is request that consideration be given to our concerns before
this process takes place.
Introduction
The feed ban implemented in 1997 is an integral part of addressing the
control and spread of BSE. Having the feed ban in place also improves
and/or enhances the existing feed regulations with regard to the recommendations
by the international team following the detection of BSE in North America.
There is no question that stopping the spread of BSE is a major priority
from both a consumer confidence and international trade perspective.
To this end, the Canadian sheep industry supports the process in principle,
however, we have very strong concerns about several of the initiatives
suggested in this paper and ask that they not be implemented until there
is complete and thorough consideration given to their economic and social
impact.
As the result of the 1997 feed ban it has been impossible to dispose of
sheep and goat heads from the abattoirs and on farm deads through the
traditional rendering process. The result is that these have to be disposed
of in an alternative manner at considerable cost and there is a growing
reluctance to process sheep and lambs. Those who continue to process sheep
and lambs are increasing their processing costs dramatically. This has
never been considered by government and the sheep industry is very concerned
about the current position being taken by AAFC and CFIA that there will
be alternative disposal methods developed to solve the problem and that
these will be available to the sheep industry.
Until these methods are identified and economic analysis is completed
that assesses the cost to the producer there should be no consideration
given to changing the regulations with regard to the sheep sector.
Elements of the Proposal that we support
The CSF supports the existing regulations and Main Regulatory Enhancement
Elements identified on page six of the Information Paper and either of
the proposed definitions for SRM and most of the elements identified as
1 to 1.12.
The inclusion of sheep in the definition of SRM or the inclusion of
sheep in the definition for downer or dead stock, is NOT supported by
the Canadian sheep industry. We strongly believe that this should be restricted
to the bovine species.
We are concerned that the current definition is used interchangeably
in this document with the term "dead or downer animal".
This should be clearly stated to exclude sheep in 1 through 1.11 of the
information paper.
CSF strongly supports improved feed labeling of feeds identified under
section 1.12. We also encourage greater education and public awareness
of this regulation.
Discussion points identified as 2.1 through 2.4 and 3.3 and 3.4 also seem
reasonable.
Elements of concern
Element 2.5 Amend Feeds Regulation and Fertilizer Regulations to link
with Health of Animals Regulations for clarity, consistency and enforcement
purposes.
The CSF would not support the exclusion of the use of composted sheep
as a fertilizer. Composting is a practical and effective method of on
farm disposal particularly in the absence of other disposal options.
Element 2.6 Require livestock feeds to be labeled with complete list
of ingredients.
The cost of least cost ration formulation will be considerably increased
by the need to develop new labels each time a ration is formulated. This
whole process is adequately addressed by the current or proposed enhanced
labeling requirements identified under the 1997 feed ban or the 1.12 element
of this paper. It seems that ingredient lists are unnecessary and redundant
with the feeding restriction labeling requirement.
Element 3.1 Prohibiting the use of proteins derived from ruminant
downer and dead stock from animal food [including pet food].
The inclusion of sheep in this ban is not justified as the transmission
of scrapie is not associated with feed. Scrapie is also not considered
a human health issue. It is the oldest identified TSE and it has never
been shown to spread to humans. The sheep industry believes that prohibition
of feeding sheep products to pets in particular is totally unjustifiable
and sends the wrong message to consumers. In addition to this, it eliminates
an effective environmentally sound and economic system to utilize these
products. In Ireland for example it is permissible to feed these products
to hounds and zoo animals.
There is probably some justification for increased producer education
to prevent the accidental ingestion by sheep of dog and cat foods - particularly
in the light of increased use of guard dogs for predator control. This
could be undertaken by industry in concert with government.
Element 3.2 Prohibiting the use of proteins derived from cattle SRM,
downer and dead stock animals from use in fertilizer.
The CSF believes that sheep should not be included in this proposal. Inclusion
would cause undue hardship and eliminate the practice of composting. This
is a legitimate way to dispose of farm deads. The use of composting is
considered acceptable in the UK with some restriction on the application
of the compost to the land. There is also indication in the emerging scientific
literature that composting might be an effective method of destroying
altered prion protein. This issue should be investigated closely to see
if this could be a legitimate method of disposal before composting prohibited.
Conclusion
CSF requests that due consideration be given to the industry’s concerns
related to this Information Paper. While there is a need to address the
concerns surrounding SRM and the control of BSE, this response should
be based on science and the economic implications for the industry. Inclusion
of sheep in these regulations will create undue injury to the sheep industry
with no benefit to controlling BSE.
The Canadian Sheep Industry supports and will continue to support improved
scrapie surveillance and control measures. This has been clearly demonstrated
by our application and granting of funding for implementation of both
genotyping and Voluntary Scrapie Flock Certification Programs. We are
also encouraged by the implementation of changes to the scrapie eradication
program and implementation of active surveillance. CSF encourages the
expansion of the surveillance to levels that would equal proportionally
the levels in the US.
Scrapie control and eradication will enhance consumer confidence, industry
viability and international trade. In order for this to happen there is
need for continued and expanded government support for these programs.
There is no question that government has responsibility to assist industry
address this issue.
Hydrolysis
of the Amyloid Prion Protien and Nonpathogenic Meat and Bone Meal by Anaerobic
Thermophilic Prokaryotes and Streptomyces Subspecies. Kirill Tsiroulnikov
et all. J. Agri. Food Chem.2004, 52, 6353-6360
For more information contact the Canadian Sheep Federation at 1-888-684-7739
or cansheep@cansheep.ca.
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