My career path has taken quite a few turns, but for most of my life I’ve worked in the animal agriculture industry. When I talk with people who aren’t familiar with the industry it never ceases to surprise me how unfamiliar people are in general about how animals are raised and how extensively the Government of Canada protects our animals as well as their food supply.
We have a long history of protecting our animal agriculture in Canada. For example, when the North West Mounted Police came from Ontario to the West, one of the only non-military people on the trek was a veterinarian. He was there to assess the damage inflicted by American cattle rustlers who were trafficking cattle back and forth, spreading diseases from the USA to Canada with their activities. Since that time the federal government has continued to enact laws, regulations and guidelines which cover all aspects of livestock feeding, health of animals and even meat inspection.
The Canadian Food Inspection Agency Feeds Division is responsible for enforcing and upholding the Feeds Act. The CFIA registers new feed products as well as ensuring product labels are accurate and that feed for sale is appropriately manufactured. The Feeds Act was created in 1983. At that time the most common feed ingredients that were used were grandfathered into the approved list, which is attached to the Feeds Act on a legal schedule, Schedule IV. Many industrialized countries have systems that are very similar to what occurs in Canada, approved lists of feed ingredients can be found on the web for the USA and the EU.
The boom of the bioeconomy in Canada and bioprocessing for bioproducts or for biofuels in Saskatchewan has meant an increasing large number of potential new and novel feed ingredients are moving through the CFIA Feeds Division for approval. Currently two new oilseeds are being developed in Western Canada for potential biofuel production; camelina and carinata. Neither the seed nor the meal, of either oilseed is approved in Canada and therefore are “Novel Feeds” (i.e. not listed on Schedule IV of the Feeds Act). Camelina meal is an approved ingredient in the EU and the USA; carinata is not approved in either jurisdiction, but “mustard meal” (no specific species or genus listed) is approved in the USA. For registration to take place a research exemption must be obtained so that the ingredient can be included in the rations of experimental animals.
For a Novel Feed, the information requested for a research exemption includes the majority of the information required for the actual product registration. Once the animal experiments are concluded, a full application to register the meal or seed as a “Single Ingredient” must be applied for. At the research exemption stage, the CFIA may require a full description of the chemical profile of the meal, all nutrient information as well as anti-nutrient information on three separate batches of meal. The cost of the chemical analyses for one batch could range from $1000-1500. A full description of the manufacturing process to produce the meal is required; simply quoting a peer reviewed paper or an industry standard is not acceptable.
Finally, animal performance trials are required to demonstrate how the meal would be used in livestock diets. The meal must be registered separately for each intended livestock species. The duration of trials must be for the length of use in the intended species (i.e. broiler chicken trials would last 28-35 days, beef trials may last up to 10 months). The cost of one animal trial may range from $35,000 for broiler chickens to $100,000 for beef cattle. For full registration, three replications of an animal performance trial are necessary. Including labour to complete the registration process, the cost to register either camelina meal or carinata meal with the CFIA could range from $90,000 – $350,000 depending on the species – and remember these costs would be for only one livestock species. Depending on the business planning of a company, the company may want to register their meal for more than one species to diversify their business operations.
My other life is in healthcare, where the latest trend is applying the tools of lean manufacturing to revamp health care processes. The Saskatchewan Surgical Initiative has set a bold target that any patient in Saskatchewan will receive their surgery within three months. During the last two years the Regional Health Authorities have been very successful in incrementally decreasing wait lists through development of value streams, specialist directories, etc. Are there lessons that can be learned from lean manufacturing that can be applied to the CFIA feeds approval processes? For example, if a feed product is registered in a country that Canada recognizes through our trade processes and we have a good working knowledge of the countries regulatory processes, how could we modify our Canadian requirements to include the evidence acknowledged by the other country?
To register a feed product in Canada we need to demonstrate evidence that the product is effective and safe. We need to recognize the uniqueness of the Canadian agricultural system – we are a cold, Northern country where plants have a very short growing season. There may be differences in genetics by environmental interactions which may potentially impact animal health (e.g. glucosinolate content may be higher in plants grown under Canadian conditions than the same plants grown in warmer climates; glucosinolates are known to be anti-nutritional compounds).
Could we incorporate lean manufacturing techniques to the regulatory realm and still achieve feed product efficacy and safety? Rather than three replications of an animal trial that may cost from $30,000 – $150,000 per replicate, could we decrease that to one replicate given approval of a product with the same description is registered in a country with similar registration processes? Besides saving cost, time would be saved by the applicant as well as the CFIA staff involved.
The Modernization of CFIA Regulations announced in December 2011 by CFIA president George Da Pont, is an excellent step toward modifying our regulations to reflect the 2012 economy rather than 1983 conditions. Let’s hope that we can change our regulatory processes so that our growing Saskatchewan bioeconomy can flourish and our livestock producers can access a potential growing range of new feed products. A Consultation Period on potential changes to the CFIA Feeds Division is currently active on line, until October 5, 2012.