1. CFIA Feed Regulatory Renewal Project
Shawn MacEachern
Animal Feed Division (CFIA)
Fish Feed and Nutrition Workshop
September 12th, 2017

2. Outline Background Drivers for Change
Overview – Proposed Modernized Regulatory Framework
Anticipated Outcomes
AMR / Research

3. CFIA Transformation Agenda
Background
CFIA Transformation Agenda
The CFIA has embarked on a comprehensive change agenda to strengthen its foundation of legislation, regulatory programs, and inspection delivery
Goals:
Legal framework that is robust, flexible, and consistent with international approaches and appropriate for 21st century
Regulations that reduce unnecessary compliance burden and support innovation while maintaining public safety, as well as environmental and economic sustainability
Inspection delivery model that is based on common inspection activities and standard processes, and supported by a renewed training regime (Integrated Agency Inspection Model (iAIM)

4. Major drivers and influences (internal)
Feed Regulatory Renewal
Major drivers and influences (internal)
Recognition by the Animal Feed Division/CFIA internal partners of the benefits of a renewed feed regulatory framework
GoC commitments to reduce regulatory burdens/trade barriers (ex. Red Tape Reduction and Regulatory Cooperation Council initiatives)
Legislative modernization (Agricultural Growth Act)

5. Major drivers and influences (external)
Feed Regulatory Renewal
Major drivers and influences (external)
Key stakeholders see a need for regulatory change (2010 Animal Nutrition Association of Canada White Paper, 2011 Future of Feeds Forum)
International drivers
Codex Code of Practice on Good Animal Feeding (2004) and Task Force on Animal Feeding (2012 -)
U.S. FDA FSMA animal feed safety rules (2015) and implementation (on-going)
CFIA Safe Food for Canadians Act and Regulations

6. Overview – Proposed Modernized Regulatory Framework

7. Scope of Framework Domestic Ingredient Manufacturing/Products
Feed Manufacturing/Products
Distribution/Retail
On-farm Feed Manufacturing E x

8. Key Regulatory Requirements
Species – Standards – Hazard ID – PCPs
Labelling – Traceability

9. Scope of Species Keep Add Remove Horses Game birds (e.g. quail) Mink
Cattle
Cervids (e.g. deer, elk)
Fox
Sheep
Camelids (e.g. alpaca)
Goats
Ratites (e.g. emu)
Swine
Fish (e.g. non-salmonids)
Fish
Honey bees
Rabbits
Poultry (chickens, turkeys, ducks and geese

10. Standards Maximum Nutrient Levels Maximum Contaminant Levels
Remove Table 4 (Range of Nutrient Guarantees for Complete Feeds for Use in the Exemption of Feeds from Registration) and replace with maximum limits for nutrients
Consulted on Poultry, Swine and Beef & Dairy
Fish maximum nutrient standard
Maximum Contaminant Levels
Expand the list of contaminants with maximum limits set in regulation (fluorine, aflatoxins, heavy metals, dioxins, mycotoxins, etc.)
Currently consulting – closes Sept 22/17
Incorporation by Reference

11. Preventive Control Plans (PCPs)1
Identify all hazards 2
Identify (critical) control points 3
Set (critical) limits 4
Monitoring procedures 5
Corrective action procedures 6
Verification procedures 7
Record keeping

12. Increased Flexibility
Labelling
Increased Flexibility
Permissible Claims
Guarantees
International Labels

13. Increased Consumer Protection
Labelling (cont.)
Increased Consumer Protection
List of Ingredients
Bilingual Labelling

14. Traceability
One step back
One step forward
Records

15. Permissions

16. Permissions - Feeds Ingredient Assessment & Approval
Product Registration
Domestic Facility Licences
Importer Licence
Exporter Licence
Infrequent Activity Permissions

17. Assessment & Authorization of Ingredients
Permissions – Products - Domestic
Assessment & Authorization of Ingredients
1 Application
2. Notification of Application
3. Assessments
4. Assessment Outcomes
5. Authorization / Positive List
6. Post-authorization Controls
Consultation

18. Registration of Mixed Feeds (cont.)
Permissions – Products - Domestic
Registration of Mixed Feeds (cont.)
Proposal:
Further increase the number of feeds that will be exempt from registration
All feeds will continue to be required to comply with regulatory requirements for labelling and not exceed maximum limits
Feed claims must be made under a permissible claims scheme or they will require registration.
Medicated mineral feeds, feeds added to water and flavouring agents will continue to require registration

19. Licencing – Domestic, Importers & Exporters
Permissions – Persons / Facilities
Licencing – Domestic, Importers & Exporters
Feeds Regulations is to licence any person who
sends or conveys feeds across provincial or international borders; and
imports feeds for sale

20. Feed Regulatory Renewal
Anticipated Outcomes
A systems-based approach requiring hazard identification and preventive control plans
Risk-based permissions regime
Reduced number of feeds requiring registration

21. Anticipated Outcomes (cont.)
Feed Regulatory Renewal
Anticipated Outcomes (cont.)
Increased traceability of feeds
Enhanced oversight of feed imports and exports
Use of incorporation by reference for timely changes to technical documents

22. Support for Stakeholders
Developing industry and inspector guidance
Developing model systems
Proposed staggered coming into force to allow Small Business more time to meet some new requirements

23. Regulatory Renewal Project: Next Steps and Timelines
Phase 3: Consultation on Proposed Framework
Feed Regulatory Modernization
Phase 4: Complete Package Preparation and
Pre-publication (CG Part I)
Phase 5: CG Part II
Apr-16
Jun-16
Aug-16
Oct- 16
Dec- 16
Feb-17
Apr-17
Jun 17
Aug-17
Oct-17
Dec-17
Feb-18 23

24. Government of Canada Response to Antimicrobial Resistance
Health Canada has made a number of regulatory changes respecting medications
CFIA working with Health Canada to accommodate these changes
Health Canada/Provincial Vet Assoc and CAHPRAC taking the lead on developing the scheme – More info to come!

25. Research Requirements
Feeds that are to be used in research trials in Canada may require the submission of an application to the CFIA before the research trial begins for either a research exemption or an authorization for release.

26. The Exemption Criteria
You are not required to submit a research application to AFD when:
The feed(s) used in the research will be fed to species not regulated by AFD
The substances being fed are not feeds and are therefore not regulated under the Feeds Act and Regulations

27. Research Requirements:
Novel ingredients (Domestic or Imported) – Application for an Authorization for the Release of Novel Feeds for Research Purposes
Domestic ingredients/feeds - No application required if all ingredients are approved and the research facility accepts full responsibility for safe disposal.
Imported ingredients/feeds – Application for Research Exemption required.

28. Research Requirements: Guidance Document
Regulatory Guidance document has been drafted
When in doubt – It’s easy to find out!

29. Consultation
CFIA completing consultations on our proposed technical changes
Next major consultation will be Gazette I
If you’d like to be included on our distribution list please contact:
Shawn MacEachern:
or visit

30. Questions 30