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Chicken Poop With Your Beef, Anyone?

By Ivan McIlroy, Gowanstown, Ontario

I am a beef farmer in SW Ontario (cow/calf to finish)

Got a letter from CFIA about the rules around feeding chicken excrete to cattle - seems it is banned in Canada - has been since 1998 but was only clearly posted April 08 on the CFIA website

But wait it is FDA approved to feed this chicken excrete to cattle (a very cheap protein supplement) in the US, has been since 2005, and then ship the meat to Canada - Duh! - Something seriously wrong I say! How are Canadian producers to compete with this? - What are Canadian consumers to think! - According to CFIA they could or should be sick - Yikes!!!!!!!!!!!!! ....I seriously think that if ever there was a time for a recall of meat This is it! ------------- Not to say anything about the unfair competition by US producers!

I am attaching the correspondence which came directly from CFIA. Unbelievable, is all I can say! Read it completely and carefully, I can't believe what they are saying!

Anyway have you got any ideas on how we can get this issue to a point were this contaminated beef from the US is taken off the market?

I feel this is of a serious nature and requires immediate action. Will you help in this regard?

Have sent correspondence to our politicians - don't seem to care - hopefully maybe you do! Will you at least acknowledge that you received this letter from me? - would be better than what our politicians have done so far!

Ivan McIlroy 519 291-5887 or ivan_and_karen@porchlight.ca.

Letter from CFIA

200 McNab Street
PO Box 158
Walkerton, ON
N0G 2V0

May 20, 2008

Mr. Ivan McIlroy
RR# Gowanstown, ON
N0G 1Y0

Dear Mr. McIlroy,

I am writing in response to your email to Mr. Gary Schellenberger, MP, regarding your various concerns with the Feeds and Health of Animals Regulations. Your email was brought to my attention and I am sending this reference letter to you as a follow up to our phone conversation we had this morning.

It is not allowable to feed chicken excrete to ruminants in Canada. The feeding of any form of poultry manure (including poultry litter) to livestock remains illegal in Canada. I have attached the Policy Document on this at the end of this document. You may also find it on CFIA's website: http://merlin/english/anima/feebet/poldoce.asp

As a result of the first case of bovine spongiform encephalopathy (BSE) in the United States in December 2003, the Food and Drug Administration (FDA) temporarily banned the feeding of poultry litter to beef cattle. The temporary ban was put in place to allow the FDA time to assess the risks to human health associated with the practice. Some scientists were concerned that the infectious agents of BSE could be passed to beef cattle via spilled feed or manure. Since that time, FDA has mandated the removal of all tissues that have been shown to carry infectious agents of BSE (i.e., specified risk materials) from poultry diets. As a result, the practical possibility of transmitting BSE to beef cattle via poultry litter was deemed to be zero by FDA. Poultry litter was again approved as a feedstuff for beef cattle in October 2005.

CFIA is currently performing on farm feed inspections. This is an ongoing initiative and we have been working towards getting out to as many farms as possible. We do keep all information confidential, however, as with all federal government bodies, there is an Acess to Information and Privacy Unit (ATIP). Within this unit, information could be requested by the public. The ATIP unit would then process the request and determine which information may be released and which information would stay confidential. For more information regarding ATIP please see our website at the below listed link: http://merlin.inspection.gc.ca/english/liaison/atipe.asp

We have been taking the approach of making the on farm inspections an educational process. If we find something that isn't as per the regulations we would inform the producer and work with them to becoming compliant. However, as a last resort, we also do have legislative authority to detain feed, or charge the producer with an Administrative Monetary Penalty (AMP) or prosecution.

We have attended many producer group meetings to provide presentations for information purposes. We have developed and distributed brochures regarding CFIA's various programs and initiatives. We have also run numerous articles in the various farm magazines, including the Ontario Farmer. In addition, CFIA has a website with all the Acts, Regulations and Policy documents listed on it. We do our best to have the information readily available at all times on our Website http://www.inspection.gc.ca/english/toce.shtml

At the Dairy Processing Plant, an organoleptic inspection and an antibiotic test of incoming raw milk id done to ensure that purchase specifications, which include no trace of antibiotics, have been met by supplier. Any other testing outside of this would be performed by Dairy Farmers of Ontario (DFO). I have included a link for referal to DFO for further information on their requirements: http://www.milk.org/Corporate/pdf/Processors-InhibitorProcedures.pdf

From the Dairy Regulations http://laws.justice.gc.ca/en/C-0.4/SOR-79-840

2.4 An inspector may direct that a dairy product be disposed of or destroyed where the inspector suspects on reasonable grounds that the dairy product

(a) [Repealed, SOR/2004-80, s. 8]

(b) is contaminated;

"contaminated" , in respect of a dairy product, means containing, for any reason whatsoever, a chemical, drug, food additive, heavy metal, industrial pollutant, ingredient, medicament, microbe, pesticide, poison, toxin or any other substance not permitted by, or in an amount in excess of limits prescribed under, or regulated by the Canadian Environmental Protection Act, 1999, the Food and Drugs Act and the Pest Control Products Act; ( contaminé )

Providing Specified Risk Material is removed, the ultimate end use of dead or condemned ruminants can go to rendering but it is considered Prohibited Material and thus must follow the regulations associated with Prohibited Material. I have included some questions and answers from CFIA website found at: http://www.inspection.gc.ca/english/anima/feebet/rumin/enhqueste.shtm

Q1 How do I handle deadstock inside my establishment?

A1Dead animals must be segregated in a designated specified risk material (SRM) area within the inedible products section for staining and disposal, in accordance with the Health of Animals Regulations. There are two options for staining:

If SRM is removed from the deadstock, the remaining carcass is considered non-SRM; however, the SRM removed from the carcass must be stained.

If SRM is not removed from the deadstock, the whole carcass is considered SRM. The carcass must be marked with a wide stripe down the back of the head and length of spine using a dye or stain which contrasts to the animal's coat colour.

Staining should be performed in common dedicated leak-proof containers, bins or trailers, or inside the auger using a spray. The stain should be applied over each layer of SRM, so that it is visible on the surface of all SRM.

I hope that I have answered your questions. If you require further assistance, please feel free to contact me directly at (519)881-2404.

Sincerely,

Cindy Young
A/Feed Program Officer, NE Region
Canadian Food Inspection Agency
PO Box 158, 200 McNab Street
Walkerton, ON N0G 2V0

www.inspection.gc.ca

Attachment

Canadian Food Inspection Agency
FEED POLICY DOCUMENT
PD- 002
April 2008

On The Feeding Of Poultry Manure To Cattle

This note is to serve as a reminder to all livestock producers that the feeding of any form of poultry manure (including poultry litter) to livestock remains illegal in Canada. The Canadian Food Inspection Agency (CFIA) published its original Information Note on the Feeding of Poultry Manure to Cattle in December 1998. Since that time, the CFIA has successfully prosecuted several producers for continuing this practice. Follow-up inspections have demonstrated that there has been a significant decline in the use of poultry manure as a feed ingredient. Such incidents remain subject to enforcement action by the CFIA. This revised Information Note is being issued toaccurately reflect recent regulatory changes and the Canadian situation which has changed due to the finding of a case of BSE (Bovine Spongiform Encephalopathy) in Canada in May 2003.

The CFIA regulates the import, manufacture and sale of livestock feed under the authority of the federal Feeds Act and Regulations. Any ingredient added to livestock rations must first be approved and listed in the Feeds Regulations. This legislation stipulates that, besides being effective, ingredients and mixed feeds must also be safe for humans, animals and the environment. No product may be used as a feed ingredient without first undergoing a rigorous safety review.

Poultry manure is not an approved feed ingredient in Canada.

There are several safety concerns associated with the use of poultry manure as a feed ingredient. First and foremost, the feeding of poultry manure may have implications for the spread of Bovine Spongiform Encephalopathy (BSE). An amendment to the Health of Animals Regulations came into effect August 4, 1997 banning the feeding of certain mammalian protein, including ruminant meat and bone meal, to cattle and other ruminants. Poultry manure often contains residues of poultry feed which may contain ruminant meat and bone meal. Thus, feeding poultry manure to cattle may inadvertently result in the feeding of ruminant meat and bone meal to cattle and contravene the Health of Animals Regulations.

The quality of any source of poultry manure may be affected by its processing. Inadequate heat treatment may contribute to the exposure of animals to pathogens. There is the potential for residues of microbial pathogens, drugs, and other chemicals which may harm livestock or result in the transfer of violative residues in animal products, e.g., meat and milk, to humans.

Producers feeding unapproved or unregistered feed ingredients to their cattle are taking a risk for both animal and human safety. Producers have a responsibility in this situation. They control the first link in the food chain and as such have an obligation to produce safe feed using approved ingredients.

Questions regarding this policy should be forwarded to your local regional office or the national office at:

Animal Feed Division
Canadian Food Inspection Agency
59 Camelot Drive,
Ottawa, ON K1A 0Y9
Telehone: 613-225-2342
Fax: 613-228-6614

www.inspection.gc.ca

QUESTIONS AND ANSWERS

What are the federal Feeds Act and Regulations?

The Canadian Food Inspection Agency regulates the import, manufacture and sale of livestock feed under the authority of the federal Feeds Act and Feeds Regulations. Any ingredient added to livestock rations must first be approved and listed in the Feeds Regulations. This legislation stipulates that, besides being effective, ingredients and mixed feeds must also be safe for humans, animals and the environment.

Are producers in Canada exempt from the authority of the federal Feeds Act and Regulations?

Exemptions are granted to livestock producers who produce their own feed only if criteria set out in section 4(a) or (b) of the Feeds Act apply: The feed shall not be offered for sale and has not had incorporated into it any drug or other substance that may adversely affect human health or the environment; or if it is free from deleterious substances. As there are risks associated with the feeding of untreated poultry manure and litter, this exemption does not apply.

What are the safety concerns associated with using poultry manure and litter as a feed ingredient?

Concerns are of a dual nature. That is to say, there is concern for both the health of the animal ingesting the feed and for food safety as humans eating the edible end products of these animals may be exposed to contaminants. Safety concerns are varied depending on the source of poultry litter and manure. There is also potential for pathogenic microbial contamination, i.e., bacteria such as Salmonella, E. coli, and Clostridium botulinum. The transfer of residues of drugs approved for use in poultry may result in residues in manure and litter. Other concerns include chemical contaminants such as heavy metals and pesticides which may accumulate in poultry waste products.

What considerations should be made for public acceptance issues?

There is increasing public concern over food safety issues. Consumers are asking questions, and they have the right to know how the food they are purchasing is produced. They are closely questioning what food-producing animals are eating.

Other articles that may be of interest:

http://www.mindfully.org/Farm/2004/Arsenic-Chicken-Roxarsone4jan04.htm




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