Appendix E-3: Acid based products
This document is in draft and is part of the consultation on Acid Based Products which will be open until October 5, 2020. Visit the main consultation page to find out how you can share your thoughts.
Acid Based Products (ABP) and their salts, often referred to as Acidifiers, are products that contain one or more substances with acidic properties and have had a recognized use in feeds to reduce the pH of solid feed when added to a feed matrix, for the acidification of water in areas with alkaline water sources and for use as preservatives in solid and liquid feed, for example, milk replacers. Products with acidifying properties may be intended to act within the animal to prevent disease or target and reduce a particular pathogen, which would be more consistent with a veterinary drug. Historically, a product would be classified as a veterinary drug when referring to the modification of the gut environment. The addition of the Gut Modifier category in feed, allows for the possibility of an ABP in feed to be recognized for its ability to act locally to modify the gut.
1.2 Purpose and scope
The purpose of this appendix is to provide guidance and clarification concerning the classification of ABP intended for oral use in livestock between veterinary drugs, including veterinary health products (VHP1), and livestock feeds. Previously, all feed ABP were registered under the collective term 'Acidifier'. In order to recognize different feed purposes, ABP will be divided into the following 3 categories: pH Adjusters; Preservatives and Mold Inhibitors; and Acidifiers (as Gut Modifiers). Each category is defined below.
ABP with claims related to the disinfection or sanitization of an inanimate object or surface are excluded from the scope of this appendix, as they are not found at the drug-feed interface.
2. Acid based product categories in feed
These acids are added to livestock feeds including liquid feeds, or water to adjust, or maintain the pH due to its buffering capacity. Feed acidification may significantly reduce the dietary pH, which in turn improves nutrient digestibility of the feed.
Preservatives and mold inhibitors
ABP may be added to feeds before and during processing to decrease the pH to levels that are unfavourable for the growth of spoilage organisms (microbial or fungal) or to prevent other undesirable chemical changes in the feed itself, rather than in the animal.
Acidifiers (as gut modifiers)
These products, when added to livestock feeds or water, elicit their beneficial effects through action in the gastro-intestinal tract (GIT) resulting in an increase in nutrient absorption and digestibility. Acidifiers (as gut modifiers) may be protected (for example, encapsulated) in order to pass through the GIT to the intended target site.
3. Relevant classification criteria
As with any product classification at the drug-feed interface, the criteria outlined in the guidance document should be consulted. The following additional criteria could be useful for consideration in guiding the classification of ABP.
3.1 Characteristics of acids
An essential characteristic of acids is their ability to dissociate and change their charge thereby resulting in differing modes of action and metabolic associations. Hence, a discussion on the molecular formula and the pKA value of the acid could become important criteria for their classification.
In association with the mode of action of the product, the ability of an acid to disassociate can determine its functional suitability.
3.2 Location of action
The location of action is a consideration for classification. Actions in the feed, external to the animal, are likely to reflect a classification as a pH adjuster, a preservative or mould inhibitor. Localized actions within the GIT suggest a potential classification as a Gut modifier. For example, protecting the product through encapsulation allows for targeted action in a particular location in the GIT; this would not be consistent with a pH Adjuster.
A product that includes systemic absorption and a location of action in the animal away from the GIT may indicate an action that is more consistent with a therapeutic or general health purpose and therefore would be better classified as a veterinary drug, which includes VHP. Further classification within the veterinary drug pathway will depend on the mode of action, ingredients and intended purpose.
3.3 Intended purpose and indications (claims)
An indication (or claim) needs to be provided for all ABP, regardless of classification. These claims should be based on a measurable outcome and supported by valid scientific evidence. The proposed claim is a consideration for classification, as follows:
- therapeutic claims may include the prevention or treatment of a disease condition or state, the mitigation of clinical signs, or disease risk reduction. Products with therapeutic claims are considered drugs and may consist of ABP that claim to target a particular pathogen(s), to reduce pathogen load, or to prevent and/or treat a disease condition
- nutritional or production/performance claims refer to the provision of nutrients, directly or through their improved availability, and their digestion or absorption. This can be provided by actual modifications in the gut. Products having claims that include the support of maintenance, growth, and improved performance of animals may be associated with livestock feeds
- general health claims are expected benefits in maintaining or promoting the health and welfare of animals. General health claims may be acceptable for the notification of VHP1 and regulated as veterinary drugs under the Food and Drugs Regulations
Examples of claims are provided in the table that follows.
|Food and Drugs Act and Regulations||Food and Drugs Act and Regulations||Feeds Act and Regulations|
|Therapeutic claims – New drug (Drug Identification Number)||General health claims – VHP Table Note 1 (notification number)||Feed claims – Feed (registration number)|
Prevention/Treatment of disease:
Production and performance:
Preservative or mold inhibitor:
- Table Note 1
Veterinary health products are veterinary drugs in dosage form that promote or maintain overall good health and wellbeing. VHPs cannot be sold or represented for the use in the diagnosis, treatment, mitigation of a disease, disorder or abnormal physical state, or its symptoms. Currently, notified VHPs may not be mixed in feeds where the Feeds Regulations apply, however for ABPs, addition to water is permitted.
- Table Note 2
Examples of physiological events may include: among others, castration, vaccination, heat stress or weaning.
This table is for illustrative purposes only and should not be considered as an exhaustive and complete list. If a product's claim or indication is not listed above, please contact Veterinary Drugs Directorate (as a single-window access for classification) for further assessment.
3.4 Dosage forms
Consistent with the guidance document, dosage forms that require forcible administration (for example, boluses and tablets) are regulated under the Food and Drug Regulations. Oral dosage forms that do not require forcible administration may be regulated under either the Food and Drug Regulations or the Feed Regulations depending on other classification criteria. To ensure consistent regulatory oversight and application of standards in safety, efficacy and quality, products in oral dosage form will be regulated as illustrated in Table E-3.2.
|Food and Drugs Act; Food and Drug Regulations||Food and Drugs Act; Food and Drug Regulations||Feeds Act; Feed Regulations|
|Therapeutic claims – New drug (Drug Identification Number)||General health claims – VHP1 (notification number)||Feed claims – Feed (registration number)|
(for example, bolus, tablet, drench)
|Mixed in feed||Yes||No Table Note 3||Yes|
|Top-dressed on feed||Yes||Yes||Yes|
- Table Note 3
Under the current Feeds Regulations, VHPs cannot be mixed in feed. As the regulations are modernized, some notified VHPs may be allowed to be mixed into livestock feeds
For further information on VHPs and the VHP notification pathway:
4. Other considerations
It is important to note that the type of acid (for example, citric, acetic, or formic acid) does not determine the product's classification. Products that contain similar acids (and/or their salts) may have different purposes, concentrations or formulations which may change the respective classification or feed categorization.
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