Archived - What we heard report – Consultation on maximum nutrient values in small ruminant (sheep and goat) feeds

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On this page

• Introduction
• About the consultation
• What we heard
  • Respondent profile
  • Key respondent messages
  • Feedback on the proposed maximum nutrient values in small ruminant (sheep and goat) feeds
• Next steps
• Appendix I – Proposed maximum nutrient values in sheep feeds
• Appendix II – Proposed maximum nutrient values for goat feeds

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 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 small ruminant (sheep and goat). 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 small ruminant (sheep and goat) 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 – Maximum nutrient values for small ruminant (sheep and goat) feeds on the CFIA website, and outreach directly to industry stakeholders, government partners, and CFIA staff. 7 sets of written comments were received.

What we heard

• Respondent profile
• Key respondent messages
• Feedback on the proposed maximum nutrient values in small ruminant (sheep and goat) feeds

Respondent profile

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. In addition, comments were received from a livestock producer association and a colleague at the CFIA.

Key respondent messages

While stakeholders provided suggestions for improvement regarding the proposed maximum nutrient values in small ruminant (sheep and goat) 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:

• forage intake values for small ruminants
• small ruminant classes/production phases
• regional and seasonal variability of nutrient levels in forages, high levels of some nutrients in forages, and lack of data on nutrient levels in forages
• some of the proposed maximum nutrient values were not appropriate
• proposed maximum levels need to be flexible to encompass current animal feeding practices and new developments in animal nutrition and production
• determining compliance for maximum nutrient values based on total diet

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

Feedback on the proposed maximum nutrient values in small ruminant (sheep and goat) feeds

• Scope of the proposal
• Small ruminant classes and average intakes
• Proposed maximum nutrient values in sheep feeds
  • Macrominerals
  • Trace minerals
  • Vitamins
• Proposed maximum nutrient values in goat feeds
  • Macrominerals
  • Trace minerals
  • Vitamins
• Additional respondent feedback

Scope of the proposal

The scope of the proposal included:

• determining those nutrient values that may impact the health and safety of the respective livestock, humans, and environment
• determining those nutrient values that support a nutritional purpose as opposed to a therapeutic purpose; and
• determining those nutrient values that may produce residues in the resulting food that could be harmful to those consuming the products

3 respondents commented specifically 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.

• CFIA response to the scope of this proposal

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

  The minimum and maximum criteria currently in Table 4 of Schedule I have never truly characterized the respective nutrient requirements or tolerances for livestock and were developed as an exemption from registration criteria. As such, feeds with nutrient levels less than Table 4 minimums and greater than Table 4 maximums were permitted in the marketplace once data provided for the feeds was assessed and found to adequately meet the requirements and not exceed tolerances. While minimum levels for nutrients will no longer be provided in the regulations, feeds will still need to be suitable for their intended purpose, which includes meeting the minimum nutritional requirements for the intended livestock species. These requirements change over time with advances in animal nutrition, and with publications such as those by the National Research Council (NRC) characterizing what livestock species require. The CFIA has focussed on setting maximum nutrient values where animal health and food safety impacts were more likely to be observed. If producers are not sure if the feeds being fed to their livestock are meeting their nutritional requirements, it is suggested that an animal nutritionist be consulted to ensure a well-balanced and formulated diet is being fed that is suitable for its intended purpose and that meets their minimum nutritional requirements.

Small ruminant classes and average intakes

The proposal included tables displaying the range of dry matter (DM) intake, and forage intake for various production classes of sheep and goats. 3 respondents provided comments regarding the percentage of forages in the total diet for small ruminants.

No comment was provided with regards to the classes of small ruminants identified in the proposal and the average intakes (range of DM intake) for each class of sheep and goats. However, modifications were made to the tables for small ruminant classes and average intakes to ensure the proposed classes match the proposed maximum nutrient values for each identified class for which a proposed maximum value was established.

• CFIA response to Small ruminant classes and average intakes

  Intakes (grain and forages)

  3 respondents provided comments on the range of forage intakes of certain small ruminant classes and stated that the total diets for small ruminants would contain a higher percentage of forages than the ranges proposed in the tables.

  The intake rates for small ruminants (sheep and goats) were not used in the calculations of the maximum nutrient values, and therefore do not reflect all production situations. They were provided as examples of intakes for small ruminants. CFIA is aware of the variations in intake associated with production classes, breed, weight, age, and varying production conditions. The tables have been modified to include a range of total DM intake, rather than averages. The tables would not be used as a "standard or facts" for calculations of intakes to verify compliance as production conditions will differ.

  Modifications were made to the classes for sheep and goats based on inputs from small ruminant nutritionists and to align with the sheep and goat classes proposed for certain maximum nutrient values.

  The proposed modifications have been set out in the tables below.

  Sheep

  Class	Range of DM intake (% body weight) Table Note 1
  Rams	1.6 to 2
  Ewes	1.6 to 5
  Lambs for rearing (< 2 months old)	1.5 to 6
  Market lambs and sheep	1.5 to 6

  Goats

  Class	Range of DM intake (% body weight) Table Note 2
  Mature bucks	1.9 to 2.7
  Mature does (breeding and lactating)	1.7 to 7.7
  Mature does (non-lactating)	1.7 to 5
  Market goats	1.5 to 6
  Growing kids	2.4 to 6

Proposed maximum nutrient values in sheep feeds

• Macrominerals
• Trace minerals
• Vitamins

Macrominerals

Calcium (Ca) and phosphorus (P)

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

• CFIA response to the proposed maximum nutrient values for calcium and phosphorus in sheep feeds

  Calcium

  After reviewing and considering the responses received and the suggested maximum value of calcium from all respondents, the CFIA intends to amend the maximum calcium value in sheep diets to account for high calcium levels in forages (legume forages and hays). 2 respondents provided information on the levels of certain nutrients (for example, calcium) in forages that are used typically in sheep diets. Since forages (alfalfa, legume, and hay forages), which may consist of a high percentage of the total diet for sheep, can contain elevated levels of calcium, there is the possibility of the proposed maximum calcium value of 1.5% of the total diet DM being exceeded. The higher maximum calcium value of 2% total diet DM would allow for greater flexibility when formulating diets during normal feeding practices. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 2% total diet DM for calcium for all sheep classes.

  The proposed modification is set out in the table below.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  2	1.5	2

  Phosphorus

  After reviewing and considering the responses received and the suggested maximum value of phosphorus from all respondents, the CFIA intends to amend the maximum phosphorus value in sheep diets to account for high phosphorus levels in by-product feed ingredients (distiller grain products, wheat middlings, wheat millrun, etc.). 2 respondents provided information on the elevated levels of phosphorus in the by-product feed ingredients, and clarified that these feed ingredients can be the sole ration on farms and represent a high percentage in creep feeds and grower and finisher sheep diets. Since these feed ingredients can contain elevated levels of phosphorus, there is the possibility of the proposed maximum phosphorus value of 0.6% of the total diet DM being exceeded. The higher maximum phosphorus value of 1% total diet DM would allow for greater flexibility when formulating diets during normal feeding practices. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 1% total diet DM for phosphorus for all sheep classes.

  The proposed modification is set out in the table below.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  0.6	0.6	1

  It is important to note that the maximum nutrient values are not target values. The feed industry should not be aiming for, or targeting, the maximum values for nutrients. The industry should be formulating diets that are balanced in nutrients, including the correct calcium to phosphorus ratio. The nutrient profile of the ingredients should be known and typical of what is available and used within the industry. In addition, having a diet that is formulated with the correct calcium to phosphorus ratio is important and tends to mitigate toxicity. Many adverse effects related to phosphorus toxicity are observed when the calcium intake is marginal or low. Therefore, the correct calcium to phosphorus ratio and an adequate amount of calcium in the diet can mitigate these adverse effects.

Magnesium, sodium, potassium, and sulfur

4 respondents provided comments regarding the proposed maximum potassium value for sheep. 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 sheep.

• CFIA response to the proposed maximum nutrient values for magnesium, sodium, potassium, and sulfur in sheep feeds

  Magnesium

  No comment was received indicating a concern with the maximum nutrient value of 0.6% of the total diet DM for magnesium for sheep. As such, the CFIA will proceed with a maximum nutrient value of 0.6% of the total diet DM for magnesium as identified in the proposal.

  Sodium

  No comment was received indicating a concern with the maximum nutrient value of 1.6% of the total diet DM for sodium for sheep. As such, the CFIA will proceed with a maximum nutrient value of 1.6% of the total diet DM for sodium as identified in the proposal.

  Potassium

  After considering the responses received and the suggested maximum value of potassium from all respondents, the CFIA intends to amend the maximum potassium value in sheep diets to account for high potassium levels in forages. Forages can make up a significant portion of the sheep diet. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 3% total diet DM for potassium.

  Respondents provided data that forages contain high potassium levels (between 1 to 4% potassium) and that having a total diet for sheep, in which forages are the majority of their diet, containing potassium levels below 2% would be too restrictive and often impossible to meet based on current feeding practices. The higher levels of potassium in the diet may result in the need for increases in the magnesium levels in the diet.

  CFIA is aware that there are high levels of potassium in forages and there is variability in the levels of potassium in forages. Therefore, knowing the range of potassium and other nutrients in forages will help to formulate a total diet that is safe and meets the nutritional requirements of the intended livestock species.

  The proposed modification is set out in the table below.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  3	2	3

  Sulfur

  No comment was received indicating a concern with the maximum nutrient value of 0.4% of the total diet DM for sulfur for sheep. As such, the CFIA will proceed with a maximum nutrient value of 0.4% of the total diet DM for sulfur as identified in the proposal.

Trace minerals

Cobalt, copper, iodine, and iron

3 respondents provided comments regarding the proposed maximum nutrient value for cobalt and that the maximum nutrient value for cobalt was too low. 5 respondents provided comments regarding the proposed maximum nutrient value for copper, and most respondents were concerned with the maximum nutrient value for copper being too low. 3 respondents provided comments regarding the proposed maximum nutrient value for iodine. No comment was provided regarding the proposed maximum iron value for sheep.

• CFIA response to the proposed maximum nutrient values for cobalt, copper, iodine, and iron in sheep feeds

  Cobalt

  In light of the limited data for the levels of cobalt in forages and grains, and after reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum cobalt value in sheep diets to 5 mg/kg of total diet DM.

  1 respondent provided information that some nutritionists are supplementing up to 5 mg/kg DM of cobalt for receiving diets and up to 3 mg/kg DM for finishing diets. The revised maximum cobalt value of 5 mg/kg of total diet DM would align with current feeding practices and the use of cobalt in certain sheep diets.

  No animal or food safety issue has been shown with the increase to 5 mg/kg of total diet DM for cobalt. The maximum tolerable level (MTL) of 25 mg/kg DM intake has been set for cobalt for sheep (NRC 2005). The requirement for cobalt by sheep is 1 mg/day or less (NRC 2007). While the revised maximum cobalt value is below the MTL, it provides sufficient room to formulate feeds to meet the nutritional requirements of sheep. It is important to note that the inclusion of supplemental cobalt in feeds in excess of the requirements is not recommended since cobalt and cobalt compounds pose a risk to workers during mixing and feeding due to their dusting potential and presumed carcinogenicity after inhalation. Reducing unnecessary amounts being used in feeds reduces worker exposure and the associated risk. The careful handling of cobalt and cobalt compounds, especially highly concentrated sources, is recommended due to worker safety concerns.

  The proposed modification is set out in the table below.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  10	1	5

  Copper

  After reviewing the information provided; the data on the levels of sulfur, molybdenum, iron, and zinc in different feeds and forages, as well as levels in soils and water supplies; the interactions of different minerals and the potential for copper deficiency or toxicity; and after considering the suggested values from all respondents, the CFIA intends to maintain the proposed maximum copper value for all sheep classes to 15 mg/kg of the total diet DM, which aligns with the MTL recommendation of the NRC 2005 and NRC 2007.

  NRC 2007 indicates that copper requirements vary from 3 to 7 mg/kg diet DM depending on the type of sheep and stage of production. Some respondents provided additional information that feeds, forages, and water supplies can have elevated levels of molybdenum and sulfur, which are copper antagonists, reducing copper bioavailability and iron and zinc can influence copper toxicity. While it is well documented that high levels of sulfur and molybdenum in the diet can reduce copper bioavailability and absorption of copper and could lead to deficiency if the dietary levels of copper are low, the proposed maximum of 15 mg/kg of the total diet should provide adequate room to formulate feeds to meet the nutritional requirements of sheep. The treatment of a specific copper deficiency with elevated levels of copper for a short period of time to correct a deficiency situation can still be managed therapeutically. Sheep are highly susceptible to copper toxicity and should not be supplemented with elevated copper unless there is an established diagnosis of copper deficiency. The range of dietary copper requirements under certain conditions can overlap with dietary concentrations that can result in other conditions. NRC 2005 indicates that 10 mg copper/kg diet may be required by sheep if dietary sulfur and molybdenum are high; however, this same amount may result in toxicosis when sulfur and molybdenum are low. Therefore, knowledge of the levels of sulfur, molybdenum, iron, and zinc in the total diet and even water supplies is important to determine the amount of dietary copper needed to meet the nutritional requirements, but not result in copper deficiency or toxicity.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  8 (added)	15	15

  Iodine

  In light of the limited data for the levels of iodine in forages and feeds, and after reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum iodine value in lactating sheep diets to 2.5 mg/kg of the total diet DM and amend the proposed maximum iodine value in diets for all other sheep classes to 10 mg/kg of the total diet DM.

  Iodine can transfer from feeds into foods of animal origin; in particular, iodine can transfer into milk. Since Canadians consume dairy products made with sheep and goat milk, there are food safety concerns with iodine levels in sheep diets and the transfer of iodine into milk. Studies have shown that concentrations of iodine in milk vary and are influenced by a number of factors, including feeding (for example, ration formulations and ingredients with inherently high levels of iodine), but also milking practices (for example, application methods of teat sanitizers and washing and dipping procedures). The amended maximum iodine value of 2.5 mg/kg total diet DM for lactating sheep should not result in any food safety concerns.

  The amended maximum iodine value of 10 mg/kg total diet DM for all other classes of sheep should not result in any animal health or food safety concerns provided the total diet is well balanced and meets the nutritional requirements of the intended livestock species. The amended maximum iodine value of 10 mg/kg total diet DM for all other classes of sheep is well below the MTL of 50 mg/kg for sheep.

  The proposed modification is set out in the table below.

  Class	Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  Lactating ewes	10	1.3	2.5
  All other sheep classes	10	2	10

  Iron

  No comment was received indicating a concern with maximum nutrient value of 500 mg/kg for iron for sheep. As such, the CFIA will proceed with a maximum nutrient value of 500 mg/kg for iron as identified in the proposal.

Manganese, selenium, and zinc

3 respondents provided comments regarding the proposed maximum nutrient values for manganese and zinc for sheep. In all instances, respondents felt the proposed maximum nutrient values were too low and should be increased. 4 respondents provided comments regarding the proposed maximum value for selenium. 1 respondent felt the proposed maximum selenium value was acceptable, while the other respondents felt the value was too low.

• CFIA response to the proposed maximum nutrient value for manganese, selenium, and zinc in sheep feeds

  Manganese

  After reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum manganese value in sheep diets to 300 mg/kg total diet DM.

  No risk to animal health or food safety would be anticipated with the maximum manganese value being increased to 300 mg/kg total diet DM for sheep diets. This value is less than the MTL of 2,000 mg/kg DM for sheep (NRC 2005). The requirement for manganese by sheep is 83 mg/day or less (NRC 2007). While the revised maximum manganese value is below the MTL, it provides sufficient room to formulate feeds to meet the nutritional requirements of sheep.

  It is important to note that the inclusion of manganese in feeds in excess of the requirements is not recommended as manganese and manganese compounds pose a risk to workers during handling. Manganese compounds are considered eye irritants and some are considered skin irritants and dermal sensitizers. The presence of nickel in manganese-containing compounds may result in contact dermatitis. It is known that exposure to manganese in dust and exposure to nickel contained in these manganese-containing compounds can pose a risk to workers and users by inhalation. Reducing unnecessary amounts being used in feeds reduces worker exposure and the associated risks.

  The proposed modification is set out in the table below.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  200	150	300

  Selenium

  In light of the limited data and high variability of selenium levels in feed, and after reviewing the scientific literature and considering the suggested values from all respondents, the CFIA intends to maintain the proposed total maximum selenium value in sheep diets of 1 mg/kg of total diet DM.

  NRC 2007 calculated the requirement in the diet for selenium by the factorial method to be less than 0.7 mg/kg diet DM to achieve a weight gain of 400 g/day. Overall, intake requirements provided by the NRC are 1.84 mg/day or less. This level is known to prevent deficiencies. The MTL for dietary selenium in sheep is 5 mg/kg DM in consideration of animal health; lower levels are necessary to avoid excessive accumulation in edible tissues (NRC 2005).

  Feedback from stakeholders indicated that a total selenium maximum of 1 mg/kg DM was achievable in feeds for other terrestrial livestock species. This level is more than sufficient to meet the dietary requirements for sheep. In comparison, the European Union (EU) has set a total selenium level of 0.5 mg/kg of complete feeds with a moisture content of 12% for all animal species. The EU maximum level limits the content of organic forms of selenium to 0.2 mg/kg. The CFIA is proposing a maximum selenium value for sheep diets that is higher than the current maximum level set by the EU and aligns with the CFIA's proposed total maximum selenium value of 1 mg/kg total diet DM for other terrestrial livestock species, including beef and dairy cattle, swine, and poultry.

  Setting maximums for selenium on a total diet rather than an added selenium basis aligns with how the standards are set for all nutrients. Recent work by Environment and Climate Change Canada under the Chemical Management Plan highlights the need for risk management measures to reduce selenium releases caused or influenced by humans into water. This would include releases from agriculture, including releases from feeds. A standard based on total selenium rather than added selenium limits inputs in feeds, thereby reducing agricultural releases. It also addresses the need to limit selenium transfer to foods of animal origin. The CFIA provided Health Canada's Food Directorate with data on the transfer of selenium to foods of animal origin through feeds. Health Canada has indicated that 1 mg/kg total selenium in the diet should not result in selenium levels of concern in foods of animal origin. The data provided by CFIA covered studies using both organic and inorganic sources of selenium in diets and accounted for intrinsic and added selenium identified in diets.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  0.3 (added)	1 (total)	1

  Zinc

  After careful review of the scientific literature and information provided, the high and variable levels of zinc in forages, and consideration of the suggested values from all respondents, the CFIA intends to amend the proposed maximum zinc value in sheep diets to 250 mg/kg total diet DM. This will provide sufficient room to meet the requirements of different classes of sheep, which NRC 2007 indicates is 200 mg/day or less. The amended maximum is set lower than the MTL (300 mg/kg DM; NRC 2005) to address potential environmental and antimicrobial resistance concerns.

  The proposed modification is set out in the table below.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  150	150	250

Vitamins

Vitamin A, vitamin D, and vitamin E

5 respondents provided comments regarding the proposed maximum nutrient values for vitamin A and most respondents expressed concerns that the proposed value was too low. 3 respondents provided comments regarding the proposed maximum nutrient values for vitamin D and expressed concerns that the proposed value was too low. 2 respondents provided general comments regarding the proposed maximum nutrient value for vitamin E in sheep diets.

• CFIA response to the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E in sheep feeds

  Vitamin A

  After careful review of the scientific literature, current levels of vitamin A in sheep feed, current feeding practices within the sheep industry, and consideration of the suggested values from all respondents, the CFIA intends to amend the proposed maximum vitamin A value to 65,000 IU/kg of diet DM for lambs for rearing (< 2 months old) and 25,000 IU/kg of diet DM for all other sheep classes.

  The vitamin A requirement for sheep is between 1,265 RE/day (4,212 IU/day retinol) and 9,100 RE/day (30,303 IU/day retinol). The current maximum value of vitamin A in Table 4 of the Feeds Regulations is set at 75,000 IU/day. NRC 1987 suggested a presumed upper safe limit of 45,000 IU/kg diet. Animal health is not the main concern posed by vitamin A in diets for sheep. Since vitamin A accumulates and is stored in the liver, food safety concerns need to be considered. In 2013 and 2015, the European Food Safety Authority (EFSA) identified that the liver consumption may pose a risk to adult consumers.

  Respondents provided a range of current vitamin A levels found in feeds for different sheep classes. Milk replacers were found to have the highest levels of vitamin A (up to 60,000 IU/kg feeds as fed) followed by lamb starter and creep feeds, with up to 23,500 IU/kg feeds as fed.

  Based on these further considerations, the proposed modifications are set out in the table below.

  Class	Current (IU/day)	Proposed (IU/kg of total diet DM)	Revised (IU/kg of total diet DM)
  Lambs for rearing (< 2 months old)	75,000	16,000	65,000
  All other sheep classes	75,000	10,000	25,000

  Vitamin D

  After review of the scientific literature, current levels of vitamin D in sheep feed, current feeding practices within the sheep industry (including flushing and indoor rearing models), and consideration of the suggested values from all respondents, the CFIA intends to amend the proposed maximum vitamin D value to 7,700 IU/kg of the total diet DM for lambs for rearing (< 2 months old), and 4,400 IU/kg of the total diet DM for all other classes of sheep.

  The proposed modification is set out in the table below.

  Class	Current (IU/day)	Proposed (IU/kg of total diet DM)	Revised (IU/kg of total diet DM)
  Lambs for rearing (< 2 months old)	7,500	2,200	7,700
  All other sheep classes	7,500	2,200	4,400

  Vitamin E

  After careful review of the scientific literature, current levels of vitamin E in sheep feed, current feeding practices within the sheep industry, and consideration of the suggested values from all respondents, the CFIA intends to maintain the current maximum vitamin E value of no maximum specified (NMS).

  Class	Current (IU/day)	Proposed (IU/kg of total diet DM)	Revised (IU/kg of total diet DM)
  Sheep (All)	No requirement specified (NRS)	1,250	No maximum specified (NMS)

Proposed maximum nutrient values in goat feeds

• Macrominerals
• Trace minerals
• Vitamins

Macrominerals

Calcium (Ca) and phosphorus (P)

3 respondents provided comments regarding the proposed maximum calcium value for goats. 2 respondents felt the proposed maximum calcium value was too low and should be increased. 3 respondents provided comments regarding the proposed maximum phosphorus value for goats. 2 respondents felt the proposed maximum phosphorus value was too low and should be increased.

• CFIA response to the proposed maximum nutrient values for calcium and phosphorus in goat feeds

  Calcium

  After carefully reviewing and considering the responses received and the suggested maximum value of calcium from all respondents, the CFIA intends to amend the maximum calcium value in goat diets to account for high calcium levels in forages (legume forages and hays). 2 respondents provided information on the levels of certain nutrients (for example, calcium) in forages that are used typically in goat diets. Since forages (alfalfa, legume, and hay forages), which may consist of a high percentage of the total diet for goats, can contain elevated levels of calcium, there is the possibility of the proposed maximum calcium value of 1.5% of the total diet DM being exceeded. The higher maximum calcium value of 2% total diet DM would allow for greater flexibility when formulating diets during normal feeding practices. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 2% total diet DM for calcium for all goat classes.

  The proposed modification is set out in the table below.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  2	1.5	2

  Phosphorus

  After carefully reviewing and considering the responses received and the suggested maximum value of phosphorus from all respondents, the CFIA intends to amend the maximum phosphorus value in goat diets to account for high phosphorus levels in by-product feed ingredients (distiller grain products, wheat middlings, wheat millrun, etc.). 2 respondents provided information on the elevated levels of phosphorus in the by-product feed ingredients, and clarified that these feed ingredients can be the sole ration on farms, and represent a high percentage in creep feeds and grower and finisher diets. Since these feed ingredients can contain elevated levels of phosphorus, there is the possibility of the proposed maximum phosphorus value of 0.6% of the total diet DM being exceeded. The higher maximum phosphorus value of 1% total diet DM would allow for greater flexibility when formulating diets during normal feeding practices. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 1% total diet DM for phosphorus for all goat classes.

  The proposed modification is set out in the table below.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  1	0.6	1

  It is important to note that the maximum nutrient values are not target values. The feed industry should not be aiming for, or targeting, the maximum values for nutrients. The industry should be formulating diets that are balanced in nutrients, including the correct calcium to phosphorus ratio. The nutrient profile of the ingredients should be known and typical of what is available and used within the industry. In addition, having a diet that is formulated with the correct calcium to phosphorus ratio is important and tends to mitigate toxicity. Many adverse effects related to phosphorus toxicity are observed when the calcium intake is marginal or low. Therefore, the correct calcium to phosphorus ratio and an adequate amount of calcium in the diet can mitigate these adverse effects.

Magnesium, sodium, potassium, and sulfur

3 respondents provided comments regarding the proposed maximum potassium value for goats. 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 goats.

• CFIA response to the proposed maximum nutrient values for magnesium, sodium, potassium, and sulfur in goat feeds

  Magnesium

  No comment was received indicating a concern with the maximum nutrient value of 0.6% of the total diet DM for magnesium for goats. As such, the CFIA will proceed with a maximum nutrient value of 0.6% of the total diet DM for magnesium as identified in the proposal.

  Sodium

  No comment was received indicating a concern with the maximum nutrient value of 1.6% of the total diet DM for sodium for goats. As such, the CFIA will proceed with a maximum nutrient value of 1.6% of the total diet DM for sodium as identified in the proposal.

  Potassium

  After carefully reviewing and considering the responses received and the suggested maximum value of potassium from all respondents, the CFIA intends to amend the maximum potassium value in goat diets to account for high potassium levels in forages. Forages can make up a significant portion of the goat diet. No risk to animal health or food safety would be anticipated with the maximum nutrient value of 3% total diet DM for potassium.

  Respondents provided data that forages contain high potassium levels (between 1 to 4% potassium) and having a total diet for goats, in which forages are the majority of their diet, containing potassium levels below 2%, would be too restrictive and often impossible to meet based on current feeding practices.

  CFIA is aware that there are high levels of potassium in forages and there is variability in the levels of potassium in forages. Therefore, knowing the range of potassium and other nutrients in forages will help to formulate a total diet that is safe and meets the nutritional requirements of the intended livestock species. The higher levels of potassium in the diet may result in the need for increases in the magnesium levels in the diet.

  The proposed modification is set out in the table below.

  Current (% of complete feed, as fed)	Proposed (% of total diet DM)	Revised (% of total diet DM)
  No requirement specified (NRS)	2	3

  Sulfur

  No comment was received indicating a concern with the maximum nutrient value of 0.4% of the total diet DM for sulfur for goats. As such, the CFIA will proceed with a maximum nutrient value of 0.4% of the total diet DM for sulfur as identified in the proposal.

Trace minerals

Cobalt, copper, iodine, and iron

3 respondents provided comments regarding the proposed maximum nutrient value for cobalt and that the maximum nutrient value for cobalt was too low. 3 respondents provided comments regarding the proposed maximum nutrient value for iodine and that the maximum nutrient value for iodine was too low. No comment was provided regarding the proposed maximum nutrient values for copper and iron for goats.

• CFIA response to the proposed maximum nutrient values for cobalt, copper, iodine, and iron in goat feeds

  Cobalt

  In light of the limited data for the levels of cobalt in forages and grains, and after carefully reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum cobalt value in goat diets to 5 mg/kg of total diet DM.

  1 respondent provided information that some nutritionists are supplementing up to 5 mg/kg DM of cobalt for receiving diets and up to 3 mg/kg DM for finishing diets. The revised maximum cobalt value of 5 mg/kg of total diet DM would align with current feeding practices and the use of cobalt in certain goat diets.

  No animal or food safety issue has been shown with the increase to 5 mg/kg of total diet DM for cobalt. The MTL of 25 mg/kg DM intake set for cobalt for goats was derived from NRC 2005 values for sheep. The cobalt requirement for goats is 0.6 mg/day or less (NRC 2007). While the revised maximum cobalt value is below the extrapolated sheep MTL, it provides sufficient room to formulate feeds to meet the nutritional requirements of goats. It is important to note that the inclusion of supplemental cobalt in feeds in excess of the requirements is not recommended since cobalt and cobalt compounds pose a risk to workers during mixing and feeding due to their dusting potential and presumed carcinogenicity after inhalation. Reducing unnecessary amounts being used in feeds reduces worker exposure and the associated risks. The careful handling of cobalt and cobalt compounds, especially highly concentrated sources, is recommended due to worker safety concerns.

  The proposed modification is set out in the table below.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  10	1	5

  Copper

  No comment was received indicating a concern with maximum nutrient value of 40 mg/kg for copper for goats. As such, the CFIA will proceed with a maximum nutrient value of 40 mg/kg for copper as identified in the proposal.

  Iodine

  In light of the limited data for the levels of iodine in forages and feeds, and after carefully reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum iodine value in lactating goat feeds to 2.5 mg/kg of the total diet DM and amend the proposed maximum iodine value in feeds for all other goat classes to 10 mg/kg of the total diet DM.

  No risk to animal health or food safety would be anticipated with the maximum iodine value being amended to 2.5 mg/kg of total diet DM for lactating goats and 10 mg/kg total diet for all other classes of goats.

  Iodine can transfer from feeds into foods of animal origin; in particular iodine can transfer into milk. Since Canadians consume goat's milk and dairy products made with sheep and goat milk, there are food safety concerns with iodine levels in goat diets and the transfer of iodine into milk. Studies have shown that concentrations of iodine in milk vary and are influenced by a number of factors, including feeding (for example, ration formulations, ingredients with inherently high levels of iodine), but also milking practices (for example, application methods of teat sanitizers, washing and dipping procedures). The amended maximum iodine value of 2.5 mg/kg total diet DM for lactating goats should not result in any food safety concerns.

  The amended maximum iodine value of 10 mg/kg total diet DM for all other classes of goats should not result in any animal health or food safety concerns provided the total diet is well balanced and meets the nutritional requirements of the intended livestock species. The amended maximum iodine value of 10 mg/kg total diet DM is well below the MTL of 50 mg/kg for goats.

  The proposed modifications are set out in the table below.

  Class	Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  Lactating goats	10	1.3	2.5
  All other goat classes	10	2	10

  Iron

  No comment was received indicating a concern with the maximum nutrient value of 500 mg/kg for iron for goats. As such, the CFIA will proceed with a maximum nutrient value of 500 mg/kg for iron as identified in the proposal.

Manganese, selenium, and zinc

3 respondents provided comments regarding the proposed maximum nutrient values for manganese and selenium for goats. In all instances, respondents felt the proposed maximum nutrient values were too low and should be increased. 3 respondents provided comments regarding the proposed maximum zinc value for goats. 2 respondents felt the proposed maximum zinc value was too low and should be increased.

• CFIA response to the proposed maximum nutrient value for manganese, selenium, and zinc in goat feeds

  Manganese

  After reviewing the information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum manganese value in goat diets to 300 mg/kg total diet DM.

  No risk to animal health or food safety would be anticipated with the maximum manganese value being increased to 300 mg/kg total diet DM for goat diets. This value is less than the MTL of 2,000 mg/kg DM established for cattle and sheep (NRC 2005) and extrapolated to goats. The requirement for manganese is 95 mg/day or less for goats (NRC 2007). While the revised maximum manganese value is below the MTL, it provides sufficient room to formulate feeds to meet the nutritional requirements of goats.

  It is important to note that the inclusion of manganese in feeds in excess of the requirements is not recommended as manganese and manganese compounds pose a risk to workers during handling. Manganese compounds are considered eye irritants and some are considered skin irritants and dermal sensitizers. The presence of nickel in manganese-containing compounds may result in contact dermatitis. It is known that exposure to manganese in dust and exposure to nickel contained in these manganese-containing compounds can pose a risk to workers and users by inhalation. Reducing unnecessary amounts being used in feeds reduces worker exposure and the associated risks.

  The proposed modification is set out in the table below.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  200	150	300

  Selenium

  In light of the limited data and high variability (including regional differences) of selenium levels in feeds and forages, and after carefully reviewing the scientific literature and considering the suggested values from all respondents, the CFIA intends to maintain the proposed total maximum selenium value in goat diets of 1 mg/kg of total diet DM.

  NRC 2007 calculated the requirement in the diet for selenium by the factorial method to be less than 0.5 mg/kg diet DM to achieve a weight gain of 300 g/day. Overall, intake requirements provided by the NRC are 1.88 mg/day or less. This level is known to prevent deficiencies. The MTL for dietary selenium in goats extrapolated from sheep is 5 mg/kg DM in consideration of animal health; lower levels are necessary to avoid excessive accumulation in edible tissues (NRC 2005).

  Feedback from stakeholders indicated that a total selenium maximum of 1 mg/kg was achievable in feeds for other terrestrial livestock species. The EU has set a total selenium level of 0.5 mg/kg of complete feeds with a moisture content of 12% for all animal species. The EU maximum level limits the content of organic forms of selenium to 0.2 mg/kg. CFIA is proposing a maximum selenium value for goat diets that is higher than the current maximum level set by the EU and aligns with CFIA's proposed total maximum selenium value of 1 mg/kg total diet DM for other terrestrial livestock species, including beef and dairy cattle, swine, and poultry.

  Setting maximums for selenium on a total diet rather than on an added selenium basis aligns with how the standards are set for all nutrients. Recent work by Environment and Climate Change Canada under the Chemical Management Plan highlights the need for risk management measures to reduce selenium releases caused or influenced by humans into water. This would include releases from agriculture, including releases from feeds. A standard based on total selenium rather than added selenium limits inputs in feeds, thereby reducing agricultural releases. It also addresses the need to limit selenium transfer to foods of animal origin. The CFIA provided Health Canada's Food Directorate with data on the transfer of selenium to foods of animal origin through feeds. Health Canada has indicated that 1 mg/kg total selenium in the diet should not result in selenium levels of concern in foods of animal origin. The data provided by CFIA covered studies using both organic and inorganic sources of selenium in diets and accounted for intrinsic and added selenium identified in diets.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  0.3 (added)	1 (total)	1

  Zinc

  After carefully reviewing the scientific literature and information provided and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum zinc value in goat diets to 250 mg/kg total diet DM.

  No direct risk to animal health or food safety would be anticipated with the maximum zinc value being amended to 250 mg/kg for goat diets. Goat diets containing a maximum of 250 mg/kg of zinc represent about 4 to 50 times the dietary nutrient requirements for goats (which is between 5 to 63 mg/kg diet DM based on type of animal and production phase), and this amended value is still below the NRC 2005 MTL of 500 mg/kg of the DM for cattle and poultry, and 300 mg/kg of the DM for sheep. The revised maximum is set lower than the MTL (300 mg/kg DM; NRC 2005) to address potential antimicrobial resistance and environmental concerns.

  The proposed modification is set out in the table below.

  Current (mg/kg of complete feed, as fed)	Proposed (mg/kg of total diet DM)	Revised (mg/kg of total diet DM)
  250	150	250

Vitamins

Vitamin A, vitamin D, and vitamin E

3 respondents provided comments regarding the proposed maximum nutrient values for vitamin A, and all respondents expressed concerns that the proposed value was too low. 3 respondents provided comments regarding the proposed maximum nutrient values for vitamin D, and 2 respondents expressed concerns that the proposed value was too low. No comment was provided regarding the proposed maximum vitamin E value for goats.

• CFIA response to the proposed maximum nutrient values for vitamin A, vitamin D, and vitamin E in goat feeds

  Vitamin A

  After carefully reviewing the scientific literature, the current levels of vitamin A in goat feeds, and the current feeding practices within the goat industry, and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum vitamin A value to 65,000 IU/kg of total diet DM for kids for rearing (< 2 months old) and 25,000 IU/kg of total diet DM for all other goat classes.

  The vitamin A requirement for goats is between 628 RE/day (2090 IU/day of retinol) and 6,825 RE/day (22800 IU/day of retinol). The current maximum value of vitamin A in Table 4 of the Feeds Regulations is set at 40,000 IU/day. NRC 1987 suggested a presumed upper safe limit of 45,000 IU/kg diet. Animal health is not the main concern posed by vitamin A in goat diets. Since vitamin A accumulates and is stored in the liver, food safety concerns need to be considered. In 2013 and 2015, EFSA identified that liver consumption may pose a risk to adult consumers.

  Respondents provided a range of current vitamin A levels found in feeds for different goat classes. Milk replacers were found to have the highest levels of vitamin A (up to 60,000 IU/kg feeds as fed) followed by kid starter and creep feeds with up to 16,500 IU/kg feeds as fed.

  Based on these further considerations, the proposed modifications are set out in the table below.

  Class	Current (IU/day)	Proposed (IU/kg of total diet DM)	Revised (IU/kg of total diet DM)
  Kids for rearing (< 2 months old)	40,000	16,000	65,000
  All other sheep classes	40,000	10,000	25,000

  Vitamin D

  After reviewing the scientific literature, the current levels of vitamin D in goat feeds, and the current feeding practices within the goat industry (including flushing), and considering the suggested values from all respondents, the CFIA intends to amend the proposed maximum vitamin D value to 7,700 IU/kg of the total diet DM for growing kids, and 4,400 IU/kg of the total diet DM for all other classes of goats.

  The proposed modification is set out in the table below.

  Class	Current (IU/day)	Proposed (IU/kg of total diet DM)	Revised (IU/kg of total diet DM)
  Growing kids	3,000	2,200	7,700
  All other goat classes	3,000	2,200	4,400

  Vitamin E

  After careful review of the scientific literature, current levels of vitamin E in goat feed, and current feeding practices within the goat industry, and considering the suggested values from all respondents, the CFIA intends to maintain the current maximum vitamin E value of no maximum specified (NMS).

  Class	Current (IU/day)	Proposed (IU/kg of total diet DM)	Revised (IU/kg of total diet DM)
  Goat (All)	No requirement specified (NRS)	1,000	No maximum specified (NMS)

Additional respondent feedback

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 feeds. 3 respondents also provided comments with regards to the maximum levels being flexible to encompass current feeding practices and animal production systems in the minor livestock species industry.

• CFIA response to determining compliance for maximum nutrient values based on total diet

  Compliance verification and enforcement of labelled nutrient guarantees for prescribed maximums would evaluate the information on the associated feed label, including the directions for use indicating the amount of the mixed feeds to be included in the total diet. The safe use of feeds is a shared responsibility. The directions for use on the labelled feeds along with the guaranteed analysis, when used together, should result in values below prescribed maximums. Producers should make use of the labelled directions as well as knowledge of the nutrient contents of other components of their animals' diets to ensure that they are feeding below the maximums. In the event that a feed has guaranteed analysis and directions for use that bring into question room for specific nutrients in forages, and in the absence of available region- or producer-specific forage data from the feed mill or from a particular producer, the CFIA may consider NRC values for forages. If there is specific forage data from a producer or feed mill that better represents the region or particular feeding program, this can be provided to a CFIA inspector and used. This should allow for greater flexibility across the country to account for geographic differences in forage, and even in cases where mixtures of forages are being used.

  As these proposed maximums would be included in a document to be incorporated by reference in the Regulations, the values may be adjusted from time to time to keep up with science and new production technologies. Over-formulating nutrients in feeds with respect to maximums is a hazard and feed mills would be expected to have preventive controls in place to avoid this. These controls might include such things as nutrient testing and purchase agreements so as to know the nutrient contents of inputs as well as knowledge of the needs of producers they are servicing. Nutrient maximums are not targets to reach when formulating feeds; rather, feeds should be formulated to meet the nutrient requirements of the animals for whom they are intended.

• CFIA response to factors to consider when setting maximum levels for nutrients

  Respondents expressed their concerns that the maximum levels for nutrients based on total diet, especially for minor livestock species, must be flexible to encompass current feeding practices used in the feed industry and accommodate new developments in animal nutrition and animal production. CFIA appreciates that comments were received with regards to a number of factors (current feeding practices, including flushing, prior to breeding; different rearing practices for sheep; the decrease in the use of antibiotics; the role of nutrition to ensure animal health; limited or variable data on the levels of nutrients in feeds and forages; regional and seasonal differences in nutrient levels in forages; etc.) to consider when setting maximum levels for nutrients. CFIA also has a greater understanding of the flexibility needed when setting maximum nutrient values, since the option to use of customer formula feeds to exceed nutrient maximums will no longer be possible.

  CFIA has reviewed the information received and has provided greater flexibility in the maximum nutrient values based on these factors while, at the same time, still ensuring that the maximum nutrient values will not result in animal health, food safety, or environmental concerns.

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 Small Ruminant (Sheep and Goat) Feeds will be available for public review and comment at the time of the Canada Gazette publication.

Appendix I – Proposed maximum nutrient values in sheep feeds

• Sheep classes and range of dry matter (DM) intakes
• Macrominerals
• Trace minerals
• Vitamins

Sheep classes and range of dry matter (DM) intakes

Macrominerals

Trace minerals

Vitamins

Appendix II – Proposed maximum nutrient values for goat feeds

• Goat classes and range of dry matter (DM) intakes
• Macrominerals
• Trace minerals
• Vitamins

Goat classes and range of dry matter (DM) intakes

Macrominerals

Trace minerals

Vitamins