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What we heard report – Consultation on maximum nutrient values in rabbit 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 compliance burden and support innovation, while ensuring feeds are safe and contribute to the production and maintenance of healthy livestock, safe foods of animal origin, and that they 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 (range of nutrient guarantees for complete feeds for use in the exemption of feeds from registration) was created and incorporated into the Feeds Regulations 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 also 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 rabbit 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 rabbit feeds 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 for the maximum nutrient values in rabbit feeds on the CFIA website, and outreach directly to industry stakeholders, government partners, and CFIA staff. 4 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 1
Livestock producer – individual 0
Livestock producer – association 0
Other feed inputs 0
Government (Canadian federal/provincial) 1 (provincial)
Total 4

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 feeds manufactured in Canada. A response was also received from the Saskatchewan Ministry of Agriculture.

Key respondent messages

While stakeholders provided suggestions for improvement regarding the proposed maximum nutrient values in rabbit feeds, the CFIA did not receive any comments 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 follow.

Feedback on the proposed maximum nutrient values in rabbit feeds

Scope of the proposal

The scope of the proposal to identify maximum nutrient values in rabbit feeds 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.

Rabbit classes and average intakes

No comment was provided with regards to the classes of rabbits (bucks, does, and growing) identified in the proposal and no comment was provided with regards to the average intakes (range of dry matter [DM] intake) for each rabbit class and percentage of forages in the total diet for each rabbit class.

Macrominerals

Calcium (Ca) and phosphorus (P)

No comment was provided regarding the proposed maximum nutrient values for calcium and phosphorus in rabbit feeds.

Magnesium, sodium, potassium, and sulfur

3 respondents provided comments regarding the proposed maximum nutrient value for potassium in rabbit feeds. 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 nutrient values for magnesium, sodium and sulfur in rabbit feeds.

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 (timothy and alfalfa) and some oilseed meals and by-products (soybean meal, canola meal, etc.) that contain naturally high levels of potassium. The respondents proposed a maximum nutrient value of 2% for potassium.
Sulfur (S) 0 0 0

Trace minerals

Cobalt, copper, iodine, and iron

No comment was received regarding the proposed maximum nutrient values for cobalt, copper, iodine, and iron in rabbit feeds.

Manganese, selenium, and zinc

No comment was provided regarding the proposed maximum nutrient values for manganese and selenium in rabbit feeds. 2 respondents provided comments regarding the proposed maximum nutrient value for zinc, and felt the nutrient zinc value was too low.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement – Summary of feedback
Manganese (Mn) 0 0 0
Selenium (Se) 0 0 0
Zinc (Zn) 2 0

1 respondent commented that the maximum nutrient value for zinc is too low and proposed a maximum nutrient value of 250 mg/kg for zinc. The respondent felt that the proposed maximum zinc value of 150 mg/kg was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

1 respondent commented that the maximum nutrient value for zinc is too low and proposed a maximum nutrient value of 280 mg/kg for zinc. The respondent felt that the proposed maximum zinc value of 150 mg/kg was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

Vitamins

Vitamin A, vitamin D, and vitamin E

Respondents provided comments regarding the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E, and expressed concerns that the proposed maximum vitamin values were too low.

Nutrient Number of respondents with comments Number in agreement with proposed values Number not in agreement – Summary of feedback
Vitamin A (Vit A) 2 0

1 respondent commented that the maximum nutrient value for vitamin A is too low and proposed a maximum nutrient value of 35,000 IU/kg for vitamin A. The respondent felt that the proposed maximum vitamin A value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

1 respondent commented that the maximum nutrient value for vitamin A is too low and proposed a maximum nutrient value of 40,000 IU/kg for vitamin A. The respondent felt that the proposed maximum vitamin A value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

Vitamin D (Vit D) 2 0 2 respondents commented that the maximum nutrient value for vitamin D is too low and proposed a maximum nutrient value of 2,200 IU/kg for vitamin D. They felt that the proposed maximum vitamin D value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.
Vitamin E (Vit E) 2 0

2 respondents commented that the maximum nutrient value for vitamin E is too low and proposed a maximum nutrient value of 2,000 IU/kg for vitamin E. They felt that the proposed maximum vitamin E value was too restrictive since micro-premixes for major livestock species are used in formulating rabbit feeds.

Additional respondent feedback

2 respondents provided comments on using micro-premixes intended for major livestock species for use in the manufacturing of feeds for minor species. They added that the maximum nutrient values for certain minerals and vitamins should try to align between feeds for major terrestrial livestock species and minor terrestrial livestock species to help with the manufacturing of feeds for minor species.

1 respondent provided a comment with regards to considerations to be taken for the seasonal and regional variability in nutrient values of commodities, in particular the range of nutrients in forages and the need to obtain data on the nutrient values in forages across various areas in Canada.

Next steps

The CFIA is preparing a formal regulatory proposal for publication in the Canada Gazette, Part I, that 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 Rabbit Feeds will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I – Proposed maximum nutrient values in rabbit feeds

Rabbit classes and average dry matter (DM) intakes

Class Range of DM intake (% body weight) Forages
Bucks 3 to 3.5 70%
Does 3.5 to 10 40% to 70%
Growing 4 to 6.7 50%

Macrominerals

Calcium (Ca)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 2 2
Phosphorus (P)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 1 1
Magnesium (Mg)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 0.6 0.6
Sodium (Na)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 0.5 0.5
Potassium (K)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 1 2
Sulfur (S)
Class Proposed (% of the total diet DM) Revised (% of the total diet DM)
Rabbits (All) 0.5 0.5

Trace minerals

Cobalt (Co)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 1 1
Copper (Cu)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 125 125
Iodine (I)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 10 10
Iron (Fe)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 500 500
Manganese (Mn)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 150 150
Selenium (Se)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 1 1
Zinc (Zn)
Class Proposed (mg/kg of the total diet DM) Revised (mg/kg of the total diet DM)
Rabbits (All) 150 280

Vitamins

Vitamin A
Class Proposed (IU/kg of the total diet DM) Revised (IU/kg of the total diet DM)
Rabbits (All) 16,000 35,000
Vitamin D
Class Proposed (IU/kg of the total diet DM) Revised (IU/kg of the total diet DM)
Rabbits (All) 2,000 2,200
Vitamin E
Class Proposed (IU/kg of the total diet DM) Revised (IU/kg of the total diet DM)
Rabbits (All) 1,875 2,000
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