The Establishment-based Risk Assessment model for feed mills: the science behind it

The risks to food safety and our animal and plant resources have changed considerably in recent years and continue to change rapidly. At the same time, the Canadian industry has to be more efficient and innovative to compete in a global economy. In this context, the Canadian Food Inspection Agency (CFIA) began to evolve the way it manages risk, supports industry's ability to compete globally, and embraces technology to provide more efficient and responsive service.

The CFIA committed to better use its data, reports and surveillance information to find unusual trends related to its mandate. This allows the agency to focus on risk and support program design, planning, compliance and enforcement efforts. In support of agency priorities, the CFIA developed an Establishment-based Risk Assessment model for commercial and on-farm feed mills (ERA-Feed Mill) to allocate inspection resources based on feed safety risks. This risk assessment will be used to determine the level of oversight needed to manage the risks. The ERA-Feed Mill model was developed by CFIA staff in collaboration with experts from academia and industry. The development of the model also drew on the experience acquired while developing the ERA model for domestic food establishments and the ERA model for hatcheries.

The ERA-Feed Mill model comprises 3 different groups of risk factors: inherent risk factors, mitigation factors and compliance factors. Data for the first 2 components will be collected through questionnaire. Data on compliance factors will be extracted from CFIA databases.

After a cycle of data collection and analysis by the ERA-Feed Mill model, the risk results will provide input into the agency's risk-informed approach to manage feed safety risks. This includes the prioritization of inspection, oversight strategies and priorities, and work planning.

The scientific approach and practical applications to develop the ERA-Feed Mill model since 2018 are presented below. Annex 1 presents the scientific advisory committee members and the technical working group members involved in the ERA-Feed Mill model development.

Scientific approach and applied use

Identification of factors associated with feed safety risk

The goal was to find the most meaningful feed safety risk factors that could be used in a risk assessment model for feed mills. Several chemical and biological hazards were considered. An initial literature review and advice from an expert panel were used to develop a comprehensive list of risk factors that could contribute to the feed safety risk attributed to Canadian commercial and on-farm feed mills manufacturing different types of feeds (premixes, mixed feeds, medicated feeds) intended for livestock.

Selection of risk factors for the Establishment-based Risk Assessment model for feed mills

For a quantitative risk assessment model, a limited number of risk factors are needed. Other criteria were considered to select risk factors, such as:

  • the clarity of their definition
  • the merging of risk factors sharing similar concepts
  • the inclusion of only measurable risk factors (for example the probability that this factor can be objectively assessed during an inspection process)
  • the availability of data sources

The final list of risk factors is presented in figure 1 and the process followed for their identification and selection is available in Food Control. Briefly, risk factors are grouped into inherent risk factors, mitigation factors and compliance factors.

Inherent risk factors represent those associated with a specific type of operation or process. These factors take into account:

  • the type of ingredients used by the mill (for example, medication, proteins of animal origin)
  • practices like manufacturing feeds for several animal species
  • the type of feed being manufactured (that is mash feed)
  • the volume of production

Mitigation factors are the measures or strategies that a feed mill uses to reduce the inherent risk. They are used to reduce the risk of contamination of the livestock and food products derived from the livestock such as their meat, milk or eggs. Examples of these strategies include:

  • controlling the safety of ingredients through suppliers with a feed safety recognized certification
  • measures to control cross-contamination, such as dedicated production lines for medicated feed
  • having an implemented and certified feed safety assurance program

Compliance factors refer to a feed establishment's track record with respect to how well it has complied with regulatory requirements. This is assessed using the feed mill's historical and current data such as information on inspection results, history of enforcement actions, complaints related to feed safety and recalls.

Figure 1: Final list of risk factors included in the ERA-Feed Mill model

Final list of risk factors included in the ERA-Feed Mill model. Description follows.
Description for image – List of risk factors included in the ERA-Feed Mill model

This figure depicts the final list of risk factors included in the ERA-Feed Mill model. The first box represents the inherent risk factors which are those associated with a specific type of facility and processes. The second box represents the mitigation factors which are the measures or strategies that a feed mill has implemented to control the inherent risks and to reduce the overall risk of a feed safety issue. The third box represents the compliance factors which refer to a feed mill's track record on how well it has complied with regulatory requirements. The list under the inspector assessment is the list of preventive control plan (PCP) sub-elements that the ERA-Feed Mill should consider under the CFIA's integrated Agency Inspection Model (iAIM).

Risk factors' criteria weighting for the Establishment-based Risk Assessment model for feed mills

The goal was to estimate the relative importance of selected criteria used to measure the risk factors included in the ERA-Feed Mill model based on their impact on feed safety. Overall, 203 criteria were presented to 28 Canadian experts during a 2-round face-to-face expert elicitation to estimate their relative risk to feed safety. There was broad consensus among participating experts on the relative risk given to the various criteria. Respondents' professional profile didn't have an influence on the results. Median values for each criterion are used in the ERA-Feed Mill model. The peer-reviewed scientific paper is available in the Journal of Food Protection.

Design of the Establishment-based Risk Assessment model algorithm for feed mills

The feed safety impact is first allocated to individual feed mills based on the volume of feed they distribute in Canada. The algorithm then considers the presence or absence of specific feed safety criteria to adjust the level of risk of the feed mill (figure 2).

Figure 2: ERA-Feed Mill model arrow illustration

ERA-Feed Mill model arrow illustration. Description follows.
Description for image – ERA-Feed Mill model arrow illustration

This figure illustrates the model design as an arrow. First, the contribution of a feed mill to the total volume of feed distributed in Canada is considered. Then, the relative risk is calculated by considering the assessment criteria applicable to a specific feed mill for each cluster: inherent risk factors, the mitigation factors, and the compliance factors represented by the first, second and third boxes, respectively. This then generates the risk at the feed mill level represented by the last box.

Testing of the model (pilot project)

The objectives of the pilot project were to get risk results and validate the data collection tool. In 2019, 38 commercial feed mills were randomly selected to take part in the pilot project and 31 participated. An improved version of the data collection tool was developed from results of the analyses of pilot project data and feedback from feed mills and inspectors.

From September to November 2020, the same information was collected from 31 randomly selected on-farm feed mills operated by livestock producers. Analyses are ongoing to test the applicability of the model and ensure the data collection tool and supporting documents are suitable for both on-farm feed mills and commercial feed mills.

Performance assessment of the Establishment-based Risk Assessment model outputs for feed mills

The objectives of this step are to estimate the agreement between the risk assessments provided by the ERA-Feed Mill model and CFIA senior inspectors, and to refine the model based on the identification of major discrepancies. 26 CFIA senior inspectors participated in the performance assessment for commercial feed mills in fall 2020.

For each feed mill that participated in the pilot project, information related to the risk factors used as inputs in the ERA-Feed Mill model are summarized in a 2-page document. Each expert categorized 10 feed mills for their risk to the feed safety, including:

  • 8 randomly selected feed mills from the pilot project
  • 2 controls (1 with the lowest risk and 1 with the highest risk)

The controls were created by the ERA-Feed Mill technical working group. Analyses are ongoing.

National commercial feed mills and on-farm feed mills data collection

At this step, the tested questionnaire will be used to collect information for inherent and mitigation factors. This information will be added to the data on compliance factors in CFIA systems in order to assess the risk of Canadian feed mills. The national data collection with commercial feed mills started in November 2020 and will continue until January 2021. In order to collect the required information, feed mill representatives are invited to complete an online questionnaire. The national data collection for on-farm feed mills will follow at a later date. After a cycle of data collection and analysis by the ERA-Feed Mill model, the risk results will be used in inspection planning and will provide input into the agency's risk-based approach to managing feed safety risks.

The Establishment-based Risk Assessment model for food establishments (ERA-Food) was developed following the same scientific approach. This approach was also used to develop the Establishment-based Risk Assessment model for hatcheries (ERA-Hatchery). The ERA technical working group is also currently adapting the ERA model for food importers (Importer Risk Assessment model).

Annex I – The scientific advisory committee members and the technical working group for the Establishment-based Risk Assessment model for feed mills, as of December 2021

ERA-Feed Mill scientific advisory committee members
Name Affiliation
Sylvain Quessy, chief scientist Université de Montréal
John Smillie University of Saskatchewan
Rick Holley University of Manitoba
André Dumas The Center for Aquaculture Technologies Canada
Stephanie Collins University of Dalhousie
Egan Brockhoff Canadian Pork Council
My-Lien Bosch Animal Nutrition Association of Canada
Catherine Italiano Canadian Food Inspection Agency
Philip Snelgrove Canadian Food Inspection Agency
Anna Mackay Canadian Food Inspection Agency
ERA-Feed Mill technical working group
Name Affiliation
Manon Racicot Canadian Food Inspection Agency
Romina Zanabria Canadian Food Inspection Agency
Geneviève Comeau Canadian Food Inspection Agency
Virginie Lachapelle Canadian Food Inspection Agency
Sharon Calvin Canadian Food Inspection Agency
Alexandre Leroux Canadian Food Inspection Agency
Ornella Wafo Noubissie Canadian Food Inspection Agency
Jennifer Kormos Canadian Food Inspection Agency
Eric T Ward-Belhumeur Canadian Food Inspection Agency
Past members
France Provost Canadian Food Inspection Agency
Mohamed Rhouma Canadian Food Inspection Agency
Shawn MacEachern Canadian Food Inspection Agency

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