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What we heard report – Consultation on maximum nutrient values in horse feeds

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Introduction

The Canadian Food Inspection Agency (CFIA) has embarked on a comprehensive change agenda to strengthen its foundation of legislation, regulatory programs and inspection delivery. These directions set the context for the renewal of the Feeds Regulations, 1983 (the regulations).

The goal of modernizing the regulations is to reduce the compliance burden and support innovation, while ensuring feeds are safe and contribute to the production and maintenance of healthy livestock and safe foods of animal origin that do not pose a significant risk to the environment. The modernization of the regulations is being designed to benefit the collective Canadian feed industry, which includes livestock producers, commercial feed manufacturers, retailers, importers, exporters, ingredient manufacturers, and food processors. As well as aligning with other international feed regulatory regimes, modernization also maintains the objective of enhancing animal health and food safety for the Canadian public.

The oversight of maximum nutrient values in feeds is just one aspect of the regulations that is being reviewed as part of the comprehensive modernization project. Table 4 of Schedule I was created and incorporated into the Feeds Regulations, 1983 in the 1980s as a mechanism to exempt certain groups of feeds from registration. Currently, if a complete feed provides nutrients that fall within the ranges listed in Table 4, or a supplement has directions for use that would result in a complete feed that provides nutrients that fall within the Table 4 ranges, the feed can be exempted from registration. Feeds that provide nutrients that fall outside the ranges listed in Table 4, and that do not meet any additional exemption criteria, require assessment and registration by the CFIA prior to manufacture and sale.

The values in Table 4 no longer have the same nutritional relevancy that they did when the table was first introduced. Stakeholders have indicated that they feel Table 4 prevents innovation for new feed products; however, many of the maximum nutrient limits that are currently set in Table 4 have health and safety implications that must be considered.

The CFIA undertook a consultation from July 10, 2018 to August 17, 2018 on a proposal to identify maximum nutrient values in horse feeds to identify maximum nutrient values in horse feeds. It was also proposed that Table 4 be removed from the regulations and no longer serve as a trigger for registration of feeds based on specified ranges of nutrient content. Finally, the proposal indicated that these maximum nutrient values would be included in a document to be incorporated by reference in the regulations to allow the flexibility to amend the lists in a timely manner, as necessary.

This report consolidates and summarizes the comments received on the maximum nutrient values in horse feed proposal and the CFIA's response to those comments.

The CFIA would like to thank everyone who participated in the consultation for contributing their time to the consultation process and sharing their views.

About the consultation

The primary mode of consultation involved the preparation and posting of the Proposal – Maximum Nutrient Values in Horse Feeds on the CFIA website, and outreach directly to industry stakeholders, government partners, and CFIA staff. 6 sets of written comments were received.

What we heard

Respondent profile

Table 1: Respondent Profile
Category of respondent Distribution
Feed industry – individual 2
Feed industry – association 2
Livestock producer – individual 1
Livestock producer – association 0
Other feed inputs 0
Government (Canadian federal/provincial) 1
Total 6

Comments were received from feed industry associations that represent Canadian commercial feed manufacturers, and from individuals within the feed industry. The Canadian feed manufacturers associations represent 90% of commercial feed manufactured in Canada. A response was also received from a colleague at the CFIA.

Key respondent messages

While stakeholders provided suggestions for improvement regarding the proposed maximum nutrient values in horse feeds, the CFIA did not receive any comment indicating an outright disagreement with the proposed regulatory approach.

Respondents indicated they agreed with the concept of discontinuing the use of Table 4 as a means of exempting feeds from registration; however, they also raised some concerns regarding the proposal, including:

A more detailed discussion on these concerns and the CFIA's responses follows below.

Feedback on the proposed maximum nutrient values in horse feeds

Scope of the proposal

The scope of the proposal included:

2 respondents commented on the stated scope of this proposal. All respondents provided positive support for the replacement of, or at least changes to, Table 4 values with scientific-based nutrient values, and understood that changes to Table 4 would increase the number of feeds that would not require registration.1 respondent provided a comment about how removing the minimum levels of nutrients in feeds could be problematic in determining feeds that are suitable for their intended purpose and meet the nutritional requirements if minimum nutrient values are no longer established.

In general, positive feedback and support was provided on the scope of this proposal.

Horse classes and average intakes

The proposal included a table displaying the range of dry matter (DM) intake, and forage intake for horses. In addition, the proposed maximum nutrient values were applied to the total dietary intake. It was the intent to establish proposed maximum nutrient values on a total diet basis that were high enough to provide flexibility to formulate nutritionally sound diets while remaining safe for livestock and not resulting in food safety concerns.

No comment was provided with regards to horse classes (mature and growing) identified in the proposal and the average intakes (range of DM intake) for each horse class. However, 3 respondents provided comments regarding the percentage of forages in the total diet for horses. In addition, 2 respondents provided comments that a separate class for pregnant and lactating mares be created as this particular production class has different requirements for certain nutrients (that is, zinc).

Macrominerals

Calcium (Ca) and phosphorus (P)

3 respondents provided comments regarding the proposed maximum calcium value for horses. In all instances, respondents felt the proposed maximum calcium value was too low and should be increased. 1 comment was provided regarding the proposed maximum phosphorus value for horses and the respondent felt the proposed value was too low.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement –
Summary of feedback
Calcium (Ca) 3 0 3 respondents commented that the maximum nutrient value for calcium is too low and not high enough to account for forages that contain naturally high levels of calcium. The respondents proposed a maximum nutrient value of 3% for calcium.
Phosphorus (P) 1 0 1 respondent commented that the proposed maximum phosphorus value of 1% is too extreme.
Magnesium, sodium, potassium, and sulfur

3 respondents provided comments regarding the proposed maximum potassium value for horses. In all instances, respondents felt the proposed maximum potassium value was too low and should be increased. No comment was provided regarding the proposed maximum magnesium, sodium, and sulfur values for horses.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement –
Summary of feedback
Magnesium (Mg) 0 0 0
Sodium (Na) 0 0 0
Potassium (K) 3 0 3 respondents commented that the maximum nutrient value for potassium is too low and not high enough to account for forages that contain naturally high levels of potassium. The respondents proposed a maximum nutrient value of 5% for potassium.
Sulfur (S) 0 0 0

Trace minerals

Cobalt, copper, iodine, and iron

4 respondents provided comments regarding the proposed maximum nutrient values for cobalt and that the maximum nutrient value for cobalt was too low. 4 respondents provided comments regarding the proposed maximum nutrient values for iodine with 1 respondent agreeing with the proposed maximum iodine value. 3 respondents provided comments regarding the proposed maximum nutrient values for iron and that the maximum nutrient value for iron was too low. No comment was provided regarding the proposed maximum copper value for horses.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement –
Summary of feedback
Cobalt (Co) 4 0

2 respondents commented that the maximum nutrient value for cobalt is too low and should be kept at 10 mg/kg in complete feed (added) until additional information is obtained on the content of cobalt in feed. Worker safety issues for the use of cobalt and cobalt compounds in the workplace are addressed under the Workplace Hazardous Materials Information System (WHMIS) and associated regulations and should not restrict the maximum nutrient value set in feed.

1 respondent commented that the maximum nutrient value for cobalt is too low as horses are provided cobalt-iodized salt blocks that are available on pasture.

1 respondent commented that the maximum nutrient value for cobalt is too low and proposed a maximum nutrient value of 5 mg/kg of total diet DM for cobalt.

Copper (Cu) 0 0 0
Iodine (I) 4 1

1 respondent commented that the maximum nutrient value for iodine is too high.

2 respondents commented that the maximum nutrient value for iodine is too low and that having a separate nutrient iodine value for pregnant and lactating mares and a separate nutrient iodine value for the other horse classes is warranted. The respondents proposed a maximum nutrient value of 10 mg/kg of the total diet DM on an "added" basis.

Iron (Fe) 3 0

2 respondents commented that the maximum nutrient value for iron is too low due to high levels of iron in forages, water and minerals as well as differences and bioavailability of iron-containing compounds. The respondents proposed a maximum nutrient value of 750 mg/kg of total diet DM for iron.

1 respondent proposed a maximum nutrient value of 750 mg/kg of total diet DM for iron.

Manganese, selenium, and zinc

3 respondents provided comments regarding the proposed maximum nutrient values for manganese, selenium, and zinc for horses. In all instances, respondents felt the proposed maximum nutrient values were too low and should be increased.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement –
Summary of feedback
Manganese (Mn) 3 0

1 respondent commented that the maximum manganese value is too low and proposed 300 mg/kg of total diet DM for all horse classes.

2 respondents commented that the maximum manganese value is too low and proposed 300 mg/kg of total diet DM for all horse classes. Worker safety issues for the use of manganese and manganese compounds in the workplace are addressed under the WHMIS and associated regulations and should not restrict the maximum nutrient value set in feed.

Selenium (Se) 3 0

1 respondent commented that the maximum selenium value is too low and proposed 2.0 (total) mg/kg of total diet DM for all horse classes.

2 respondents commented that the maximum selenium value is too low due to the high and variable levels of selenium found in forages. The respondents expressed concerns on setting a maximum selenium value based on the "total" diet as opposed to an "added" basis and concerns with basing the maximum selenium value on food safety risks, and proposed 1.0 (added) mg/kg of total diet DM for all horse classes.

Zinc (Zn) 3 0

1 respondent commented that the maximum zinc value is too low and proposed 500 mg/kg of total diet DM for pregnant mares and 400 mg/kg of total diet DM for the all other horse classes.

1 respondent commented that the maximum zinc value is too low and not high enough to account for forages that contain naturally high levels of zinc. The respondent requested that, as a minimum, a separate class be created for pregnant and lactating mares and proposed a maximum nutrient value of 400 mg/kg total diet DM.

1 respondent commented that the maximum zinc value is too low and not high enough to account for forages that contain naturally high levels of zinc. The respondent requested that, as a minimum, a separate class be created for pregnant and lactating mares and proposed a maximum nutrient value of 500 mg/kg total diet DM.

Vitamins

Vitamin A, vitamin D, and vitamin E

No specific comment was provided regarding the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E for horses. However, 1 respondent provided a general concern on the maximum nutrient values for vitamins being significantly decreased.

Additional respondent feedback

1 respondent provided comments that the proposed maximum nutrient values should be based on animal health and food safety concerns, and not environmental concerns.

1 respondent provided comments with regards to the labelling of feeds with specific nutrient guarantees to help with formulating well-balanced nutritional diets and identifying that there are different nutrient requirements and tolerable levels for different production classes, as well as for different equine species.

3 respondents provided concerns on how CFIA inspection staff will determine compliance when maximum nutrient values are established for the total diet, and not solely established for complete feed.

Next steps

The CFIA is preparing a formal regulatory proposal for publication in the Canada Gazette, Part I, which will incorporate the comments received on all the consultation proposals, public meetings, stakeholder workshops and submissions, and other outreach activities that have been used over the course of the project. A draft of the Maximum Nutrient Values in Horse Feeds will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I – Proposed maximum nutrient values in horse feeds

Horse classes and average intakes: Dry matter (DM) basis

Class Range of DM intake
(% body weight)Table Note 2
Forages
Horses (mature and growing) 1.5 to 3.2Table Note 2 Up to 90%Table Note 2
Pregnant and lactating mares 1.5 to 3.2Table Note 2 Up to 90%Table Note 2

Table Note

Table Note 2

Note: The range of DM intakes and forage intakes on farms may be below or above these intake values.

Return to table note 2  referrer

Macrominerals

Calcium (Ca)
Class Proposed
(% of the total diet DM)
Revised
(% of the total diet DM)
Horse (All) 2 3
Phosphorus (P)
Class Proposed
(% of the total diet DM)
Revised
(% of the total diet DM)
Horse (all) 1 1
Magnesium (Mg)
Class Proposed
(% of the total diet DM)
Revised
(% of the total diet DM)
Horse (All) 0.8 0.8
Sodium (Na)
Class Proposed
(% of the total diet DM)
Revised
(% of the total diet DM)
Horse (All) 2.4 2.4
Potassium (K)
Class Proposed
(% of the total diet DM)
Revised
(% of the total diet DM)
Horse (All) 3 5
Sulfur (S)
Class Proposed
(% of the total diet DM)
Revised
(% of the total diet DM)
Horse (All) 0.5 0.5

Trace minerals

Cobalt (Co)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Horse (All) 1 5
Copper (Cu)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Horse (All) 125 125
Iodine (I)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Pregnant and lactating mares 3 5
Horse (All others) 4 5
Iron (Fe)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Horse (All) 500 750
Manganese (Mn)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Horse (All) 150 300
Selenium (Se)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Horse (All) 1 (total) 1
Zinc (Zn)
Class Proposed
(mg/kg of total diet DM)
Revised
(mg/kg of total diet DM)
Horse (All) 150 280

Vitamins

Vitamin A
Class Proposed
(IU/kg of total diet DM)
Revised
(IU/kg of total diet DM)
Horse (All) 16,000 16,000
Vitamin D
Class Proposed
(IU/kg of total diet DM)
Revised
(IU/kg of total diet DM)
Horse (All) 4,000 4,000
Vitamin E
Class Proposed
(IU/kg of total diet DM)
Revised
(IU/kg of total diet DM)
Horse (All) 2,400 NMS (NMS = no maximum specified)
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